25.1.1 Registration procedure for person liable to registration u/s 22 or 24

Example 1 — Based on Turnover (Section 22)

Mr. A is a trader in Gujarat.

His aggregate turnover crosses ₹40 lakhs on 10th August 2025.

As per Section 22, he becomes liable to register when turnover crosses ₹40 lakh.

 

Application requirement:

Mr. A must apply for GST registration by 9th September 2025 (i.e., within 30 days).

He must apply in Gujarat, as that’s the State where he is operating.

 

Example 2 — Compulsory Registration (Section 24)

M/s XYZ Pvt. Ltd. in Delhi starts supplying goods inter-State to Haryana on 1st July 2025.

As per Section 24(i), inter-State suppliers are mandatorily required to register (irrespective of turnover).

 

Application requirement:

XYZ Pvt. Ltd. must apply for GST registration in Delhi (where its place of business is located) by 31st July 2025 (within 30 days from liability date).

 

25.1.2 CTP/NRTP shall apply within 5 days

Example-1 Casual Taxable Person

M/s Art Expo Traders, based in Mumbai, plans to set up a temporary stall at an exhibition in Delhi from 10th December 2025 to sell paintings.

They have no fixed place of business in Delhi, hence they are a Casual Taxable Person there.

As per the proviso to Section 25(1):

They must apply for GST registration at least 5 days before 10th December 2025,
i.e., on or before 5th December 2025.

 

Example 2 — Non-Resident Taxable Person

Global Tech Ltd., a company based in Singapore, plans to participate in a tech fair in Bengaluru on 20th January 2026 to sell software licences.

Since it has no fixed place of business in India, it qualifies as a Non-Resident Taxable Person (NRTP).

Requirement under proviso to Section 25(1):

It must apply for GST registration at least 5 days before 20th January 2026, i.e., on or before 15th January 2026.

 

25.1.3 Separate Registration is required for SEZ Unit

Example-1

Company X has its headquarters and manufacturing unit in State A, and that unit is outside any SEZ.

Company X also has a separate unit located inside a notified SEZ in the same State A.

Both units make taxable supplies (either goods or services) in the course of business.

Under the 2nd proviso:

Company X will have to apply for one GST registration for its non-SEZ unit (the regular place of business).

It must also apply for a separate registration for the SEZ unit (even though both are in State A).

This ensures the SEZ unit is treated as a distinct registration for GST purposes.

 

25.1.4 Registration of person making supply from territorial waters of India

Example-1

A company “Seaworld Exports Pvt Ltd” located on a ship anchored in Indian territorial waters off the coast of Tamil Nadu (near the baseline off Chennai).

They supply goods from that ship (i.e., from the territorial waters).

The nearest baseline point on Indian land is in the coastal State of Tamil Nadu.

Under this Explanation:

Even though the supply is from the ship in territorial waters (not strictly on land), the registration must be taken in Tamil Nadu, because that is the coastal State whose baseline is nearest.

So Seaworld Exports must apply for GST registration in Tamil Nadu.

 

25.2.1 Multiple Registration for each PoB in State/UT subject to conditions

Example-1

XYZ Manufacturing Pvt. Ltd. has:

a factory in Pune (Maharashtra), and

a sales depot in Nagpur (also Maharashtra).

Normally, XYZ would have one GST registration for Maharashtra.

But the company wants to maintain separate compliance for factory and depot.

✅ Applying Section 25(2) + Rule 11:

XYZ can apply for two separate registrations in Maharashtra:

GSTIN 1 → Factory (Pune)

GSTIN 2 → Depot (Nagpur)

 

25.3 Voluntary Registration

Example-1

Rahul runs a small stationery shop with a turnover of ₹12 lakh per year, which is below the GST threshold limit (₹20 lakh in most states).

So, he is not required to register under GST.

However, he sells to corporate clients who prefer dealing with GST-registered suppliers.
So Rahul decides to apply for GST registration voluntarily under Section 25(3).

Consequences:

Rahul must issue GST invoices and charge GST on his supplies.

He must file monthly/quarterly GST returns.

He can now claim Input Tax Credit (ITC) on GST paid on his business purchases.

 

25.4 Suo-moto Registration by Proper Officer

Mr. Raj operates a store in Delhi and his turnover crosses ₹40 lakhs — above the GST registration limit.
But he does not apply for GST registration.

➡ GST department receives data from Income Tax, digital payments, or local survey
➡ Officer verifies and finds he is liable for registration

Action Taken under Sec 25(8 r/w Rule 16(1):

• Officer issues GST REG-12
• System issues temporary GSTIN to Mr. Raj
• Mr. Raj is instructed to file regular GST registration application (REG-01)
• Once done, temporary GSTIN is replaced with normal GSTIN

👉 Even if Mr. Raj doesn’t take registration himself, he cannot avoid GST — department will register him forcibly.

 

25.4.2.1 Person shall apply for Regular Registration within 90 days

Example-1

Temporary registration granted on 10 December 2024

Mr. A must apply for regular registration on or before 9 March 2025

 

25.5.1 Registered Branch treated as Distinct Person for each separate registration

Example-1

ABC Pvt. Ltd. has its PAN ABCDE1234F.

It has operations in:

Maharashtra – GSTIN 27ABCDE1234F1Z5

Karnataka – GSTIN 29ABCDE1234F1Z2

Even though the company is the same, each GSTIN is a distinct person under GST.

Scenario

The Maharashtra unit sends goods worth ₹50,00,000 to the Karnataka unit.

Implications

This is treated as a supply between distinct persons.

Maharashtra must issue a tax invoice and charge IGST on the transfer.

Karnataka unit can claim ITC of that IGST.

 

25.5.3 Supply between related person or branch in course of business

Example-1

Raghubir Fabrics transfers 1000 shirts from his factory located in Lucknow to his retail showroom in Delhi so that the same can be sold from there. The factory and retail showroom of Raghubir Fabrics are registered in the States where they are located. Although no consideration is charged, supply of goods from factory to retail showroom constitutes supply.

 

25.5.4 Stock/ branch transfers without consideration between single Registration is not supply

Example-1

Raghubir Fabrics transfers 1000 shirts from his factory located in Lucknow to his retail showroom in Kanpur so that the same can be sold from there.

It has taken one registration in the State of Uttar Pradesh declaring Lucknow factory as its principal place of business and Kanpur showroom as its additional place of business.

Since no consideration is charged, supply of goods from factory to retail showroom in same State under single registration does not constitute supply.

However, in the above example, if Raghubir Fabrics obtains separate registrations for Lucknow factory and Kanpur showroom, stock transfer between the Lucknow factory and Kanpur showroom will constitute supply.

 

25.11.1 Deemed approval, If PO does not take any action within specified period

Example-1 Normal case

Mr. Verma files his GST registration on 10th January using REG-01.

He completed Aadhaar authentication and uploaded correct details, so no physical verification triggered.

Officer must approve within 7 working days → deadline is 19th January.

Suppose the officer does nothing by 19th — no approval, no rejection.

👉 Under Rule 9(5)(i), Mr. Verma’s application is deemed approved on 19th.

 

Example-2 Physical verification case

Ms. Sharma applied on 5th Feb, but because she did not complete Aadhaar authentication, the officer decides physical verification of her place of business is required.

Extended time limit now applies → up to 30 days (5th March) for approval.

Suppose the officer neither approves nor rejects by 5th March.

👉 Under Rule 9(5)(ii), her application is deemed approved on 5th March.

 

Example-3 After a deficiency notice

Mr. Singh files his application on 1st April.

Officer issues a notice on 4th April asking for proof of business location.

Mr. Singh replies with the correct documents on 8th April.

Now the officer has 7 working days (up to 17th April) to verify and approve. If he fails to act by 17th:

👉 Under Rule 9(5)(iii), the application is deemed approved on 17th April.

 

25.12 Automated electronic approval of registration application within 3 days

Example-1

Priya runs a small garment business in Delhi.

She applies for GST registration on 1 Nov 2025 using Form REG-01 u/r 8.

Her PAN and Aadhaar are valid and match the portal records.

She has no prior GST compliance or return issues.

The portal’s analytic engine checks her details and assigns a low-risk score.

As per Rule 9A, the GST system will auto-approve her registration electronically by 3 Nov 2025 without any manual scrutiny.

 

 

25.13.2.1 Person who has not opted for Aadhar authentication

Example-1

Priya files her GST REG-01 and selects the Rule 14A option, but does not complete Aadhaar authentication of the primary signatory.

She cannot be granted Rule 14A registration until Aadhaar authentication is done.

 

25.13.2.2 One Registration Per PAN per State/UT

Example-1

Aman has a business in Gujarat and obtains a GST registration under Rule 14A.

He cannot get another Rule 14A registration in Gujarat under the same PAN.

 

25.13.3.3 Amendments in Registration Particulars before withdrawal

Example-1

After getting Rule 14A registration, Suresh changes his business address. He must first amend the address under Rule 19 before filing GST REG-32 for withdrawal.

 

25.13.4 Regular return to be filed after withdrawal

Example-1

Withdrawal order issued on 15 Feb.

From 1 Mar, Sunil must report his higher output tax liability (e.g., ₹3 lakh).

 

25.13.5 Restriction on amendment of prior details of outward supplies

Example-1

After applying for withdrawal on 10 Feb, but before 1 Mar, Anil cannot revise his output tax data to show over ₹2.5 lakh for previous periods

 

25.14.2 Effective Date of Registration

Example-1 [Application filed within 30 days]

Mr. Ramesh is required to get GST registration from 1st March (he crossed threshold).

He files his application on 20th March (within 30 days).

His application is approved on 5th April.

Effective date of his registration = 1st March, not 5th April.

This means he must file returns and pay tax from 1st March.

 

Example-2 [Application filed after 30 days]

Ms. Mehta was liable to register from 1st May but filed her GST application on 15th June (more 30 days late).

Her application is approved on 22nd June.

Her registration becomes effective from 22nd June, not 1st May.