Ask anybody what the GST registration limit is and you will be told forty lakh. Open the Act and it is not there. Section 22(1) fixes the figure at twenty lakh rupees of aggregate turnover in a financial year, and at ten lakh rupees for a supplier making taxable supplies from a special category State. Those are the Act numbers, and if you supply services at all they are the numbers that govern you. The forty lakh is real, but it is an exemption granted by a notification under section 23(2), it reaches only a person engaged in the exclusive supply of goods, and it carries four exclusions that almost nobody repeats. One of those exclusions is worth printing on its own, because it is so specific. The exemption does not apply to a supplier of ice cream and other edible ice, of pan masala, or of anything in Chapter 24, which is tobacco. An ice cream parlour at twenty-five lakh is outside the forty lakh and over the twenty. It has to register, and it will not find that out from any page quoting the headline figure. Then the provision that makes all of this academic for a great many businesses. Section 24 requires registration notwithstanding section 22(1) — for anybody making an inter-State taxable supply, anybody selling through a marketplace that collects tax at source, anybody liable under reverse charge, a casual or non-resident taxable person, an agent, an Input Service Distributor, every e-commerce operator. One sale across a State border, or one listing on a marketplace, and your turnover stops being the question. And two things about the process that are worth knowing before you file. The date of submission is not the day you press submit: under rule 8(4A) it is the date of Aadhaar authentication, or the fifteenth day from Part B, whichever is earlier. And if the officer does nothing at all, rule 9(5) deems your application approved — inaction here is not delay, it is a grant.
What is on this page
One figure travels with this subject through every market in the country, and the people repeating it have no reason at all to doubt it.
Forty lakh. Under forty lakh, no GST. It is on the walls of accountants offices, it is in the mouths of trade association secretaries, and it is the first thing a shopkeeper tells another shopkeeper who asks.
It is not in the Act. Not in section 22, not in section 23, not anywhere in the statute. And for a large number of businesses it was never available at all.
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Open the provision that creates the liability and the number you find is a different one.
Central Goods and Services Tax Act, 2017, section 22(1) — every supplier shall be liable to be registered under this Act in the State or Union territory, other than special category States, from where he makes a taxable supply of goods or services or both, if his aggregate turnover in a financial year exceeds twenty lakh rupees. Proviso — where such person makes taxable supplies of goods or services or both from any of the special category States, he shall be liable to be registered if his aggregate turnover in a financial year exceeds ten lakh rupees.
So the statutory position has two figures and neither of them is forty.
Twenty lakh of aggregate turnover in a financial year, in a State or Union territory other than a special category State. Ten lakh where the taxable supplies are made from a special category State, those being the States specified in sub-clause (g) of clause (4) of article 279A of the Constitution.
The Explanation adds something people forget when they do the arithmetic: aggregate turnover includes all supplies made by the taxable person, whether on his own account or made on behalf of all his principals. An agent counting only his own margin is counting the wrong figure.
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The forty lakh is not invented and it is not a myth. It exists, and it is worth knowing exactly what it is.
Section 23 of the Act lists persons not liable to be registered, and sub-section (2) gives the Government a power: on the recommendations of the Council, it may by notification specify further categories of persons who shall be exempt from obtaining registration.
That power was exercised. A notification issued under it exempts a person engaged in the exclusive supply of goods whose aggregate turnover in the financial year does not exceed forty lakh rupees.
Which places the figure in a different legal category from the one it is usually quoted in, and the difference is not academic.
A section applies to everybody it describes. A notification applies on its own terms, to the category it specifies, with whatever exclusions it carries, from whatever date it takes effect, and it can be amended or superseded by another notification without any change to the Act.
This is why the forty lakh is so often quoted without its conditions. A person reading the Act will not find it. A person reading a summary of the notification will usually be given the headline and not the four exclusions that follow it.
Three consequences, and the third is the one that costs money.
The first is that the Act figure never went away: twenty lakh, and ten in a special category State, remains the operative threshold for anybody the notification does not reach. The second is that the notification is narrower than the Act provision it sits beside. The third, and the one with a price on it, is that a business relying on forty lakh has to be inside the notification, not merely under its number.
Being under forty lakh is not the test. Being a person the notification applies to, and being under forty lakh, is the test. A great many businesses satisfy the second half and fail the first.
The first and widest limit on the notification is in its opening words.
It exempts a person engaged in the exclusive supply of goods. Exclusive is doing the work. A person who supplies services, or who supplies goods and services together, is not a person engaged in the exclusive supply of goods, and the exemption does not reach him.
So for every service provider in the country — every consultant, every contractor, every tutor, every repairer, every designer, every transporter, the registration threshold is and always was twenty lakh, or ten lakh from a special category State. If you supply services and somebody has told you forty lakh, they have quoted you a notification that does not apply to you.
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Then come the exclusions, and they are the reason this page spends its first third on a single figure.
The notification names four classes of person to whom the exemption does not apply. Each of them is a complete answer to a business that thought it was safe, and three of the four are commoner than the people relying on the headline figure imagine.
They are set out in the notification itself rather than hidden somewhere else, which makes their general absence from the advice people receive the more striking. Anybody quoting you the figure has either read them and left them out, or has not read the notification at all. Asking which is a fair test of the advice.
Before the detail, the working order, because doing it in the wrong order is how the mistake gets made.
Do not start with your turnover. Start with the question whether you are in a compulsory category at all, because if you are, no threshold assists you. Then ask whether you supply goods exclusively. Then, and only then, compare a figure.
Stated as a sequence: section 24 first, the exclusive-supply-of-goods question second, the remaining three exclusions third, and a number fourth. Almost every wrong answer we are shown on this subject is that sequence run backwards: it starts from the figure and never reaches the provisions that make the figure irrelevant.
Threshold last, not first. That single reordering prevents most of the errors on this subject.
Set out as the notification sets them out.
Notification No. 10/2019-Central Tax, dated 7 March 2019, issued under section 23(2) and in force from 1 April 2019 — the exemption for a person engaged in the exclusive supply of goods whose aggregate turnover in the financial year does not exceed forty lakh rupees shall not apply to: (i) persons required to take compulsory registration under section 24; (ii) persons engaged in the supply of ice cream and other edible ice, whether or not containing cocoa (tariff item 2105 00 00), pan masala (tariff item 2106 90 20), or all goods of Chapter 24, being tobacco and manufactured tobacco substitutes; (iii) persons engaged in making intra-State supplies in the States of Arunachal Pradesh, Manipur, Meghalaya, Mizoram, Nagaland, Puducherry, Sikkim, Telangana, Tripura and Uttarakhand; and (iv) persons exercising the option under section 25(3), or registered persons who intend to continue with their registration.
Read the second exclusion again, because it is the most concrete thing on this page and the one most likely to apply to somebody reading it.
Three trades are named by tariff item. An ice cream parlour. A pan masala dealer. Anybody selling tobacco or its manufactured substitutes. For all three, the forty lakh exemption simply does not exist, and the threshold is the Act figure of twenty lakh.
An ice cream business turning over twenty-five lakh is outside the exemption and over the Act threshold. It must be registered. It will never discover that from a page quoting the headline figure, and it will usually discover it from an officer.
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The choice of trades is not arbitrary, and understanding the logic helps you predict where else care is needed.
All three sit in categories the tax administration watches closely, for reasons of rate, of evasion history, or of policy. Pan masala and tobacco carry compensation cess and a long enforcement record. Ice cream has been the subject of its own rate and classification disputes for years.
The lesson for a reader in some other trade is not that the list will grow, but that a notification can carve out a named class of goods at any time, and that a figure quoted without checking its current exclusions is a figure quoted on trust.
The third exclusion is geographic and it catches businesses that have nothing unusual about their trade at all.
The exemption does not apply to persons making intra-State supplies in ten named States and Union territories: Arunachal Pradesh, Manipur, Meghalaya, Mizoram, Nagaland, Puducherry, Sikkim, Telangana, Tripura and Uttarakhand.
Why those ten and not others is a policy choice rather than a principle, and the list has no obvious internal logic that would let you predict it. Which is itself the point: it has to be read, not reasoned about. A trader who assumes the list tracks the special category States in section 22 will get Telangana and Puducherry wrong in one direction and will get nothing useful in the other.
Two points about that list, because it is easy to misread in both directions.
It is not the same as the special category States in section 22, and the two should not be conflated. Telangana and Puducherry, for instance, appear in this notification list. So a goods business in one of these ten is on the Act figure rather than on forty lakh, and a reader in Telangana or Uttarakhand who has been working on the headline number has been working on the wrong one for years.
The exclusion is framed around intra-State supplies in those States, so it is about where the supply is made rather than about where the proprietor lives. For a trader operating in two States, the question is asked State by State, which is also how the registration itself works.
The fourth exclusion is the least surprising and still worth stating.
The exemption does not apply to a person who exercises the option to register voluntarily under section 25(3), or to a registered person who intends to continue with the registration. In other words, you cannot use the exemption to shed a registration you chose to take, or to walk away from one you already hold.
Voluntary registration is a real decision with real consequences — returns become due whether or not there is turnover, and return filing becomes a standing obligation rather than an occasional one. It is often the right choice, for input credit or because customers insist on it, and an exporter or a zero-rated supplier may need it simply to be able to claim a refund at all. It is still a door that does not swing both ways easily.
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Which leaves the first of the four, the one listed first in the notification and the one that disposes of the threshold question entirely for a very large number of businesses.
The exemption does not apply to persons required to take compulsory registration under section 24. And section 24 is not a short list.
It is listed first for a reason. The other three exclusions take particular trades, particular States and particular choices out of the exemption; this one takes out an entire statutory category, and it is a category defined by what a business does rather than by how much it earns. For a growing business, this is the exclusion it will walk into without noticing.
The section opens with words that settle the argument before it starts.
The drafting convention is worth noting because it recurs across this Act. A section opening with notwithstanding a specified provision is not adding a case to that provision; it is standing outside it. So there is no reading of section 24 on which a turnover argument survives, and no notification under section 23(2) that can reach a person section 24 describes, which is exactly what the first exclusion in that notification confirms.
Central Goods and Services Tax Act, 2017, section 24 — notwithstanding anything contained in sub-section (1) of section 22, the following categories of persons shall be required to be registered under this Act.
Notwithstanding section 22(1). The threshold is in section 22(1). So for everybody section 24 describes, the threshold is not merely exceeded, it is irrelevant.
The categories run to twelve clauses, and most of a page like this one is spent on four of them because those four catch ordinary small businesses that would never think of themselves as special cases.
Grouped by what actually triggers them rather than in the order the section lists them, they fall into four kinds. Where the supply crosses a border: an inter-State taxable supply, or a supplier sitting outside India selling online services into India to somebody unregistered. Where the presence is temporary or foreign: the casual taxable person with no fixed place of business in the State, and the non-resident taxable person with none in the country. Where somebody else is in the chain: an agent supplying for a principal, an Input Service Distributor, a seller on a marketplace whose operator collects tax at source, and the operator itself. Where the person withholds rather than supplies: the deductor, and the collector. Reverse charge and section 9(5) liability sit across those groups. The clauses themselves are quoted on our trade licence page, and we have not reproduced that list a second time here.
The first clause is the shortest and the most consequential: persons making any inter-State taxable supply.
Any. Not habitually, not predominantly, not above some value. One despatch across a State border is an inter-State taxable supply, and from that point the person is within a category registered notwithstanding the threshold.
A trader with eight lakh of turnover who sends one consignment to the next State has become liable to register, and the turnover figure he has been relying on has stopped being relevant. This is the clause that catches small manufacturers expanding for the first time, and it catches them at exactly the moment they are least likely to take advice.
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The second of the four that matter is newer in practical importance and is now probably the commonest route into compulsory registration for a very small business.
Persons who supply goods or services, other than supplies on which the operator is liable under section 9(5), through an electronic commerce operator who is required to collect tax at source under section 52, must be registered. And separately, every electronic commerce operator must be registered in its own right.
So a home baker listing on a marketplace, a craftsperson on a handicraft platform, a trader on a large retail site: all of them are inside the compulsory category from the first listed sale, whatever the figures. The platform knows this, which is why it asks for a registration number before it will onboard you. That request is not bureaucracy; it is the platform complying with the section that makes it collect tax at source.
The third is quieter and surprises people because it attaches to a purchase rather than to a sale.
Persons who are required to pay tax under reverse charge must be registered. Reverse charge shifts the liability from the supplier to the recipient for notified supplies and in notified situations, so a business can be brought inside the compulsory category by what it buys.
Whether a particular inward supply attracts it is a question of rate and notification, which is squarely a tax professional question and not ours. What this page can tell you is where to look: if anybody has told you that you are liable to pay tax on something you purchased, the registration question has already been answered for you.
Two categories defined by the shape of the presence rather than by its size.
A casual taxable person is somebody who occasionally transacts in a State where he has no fixed place of business — the exhibitor at a trade fair, the contractor on a single out-of-State job, the seasonal stallholder. A non-resident taxable person is somebody with no fixed place of business in India at all. Both must register, and both have a different and tighter timetable, dealt with further down this page.
Both categories also carry a registration of limited duration rather than an indefinite one, and both are commonly discovered too late by businesses that think of themselves as doing something small and temporary. A single exhibition stall in another State is the classic instance: small in value, short in duration, and squarely inside a compulsory category.
Two more, both structural.
Somebody who supplies for a principal rather than for himself is inside the compulsory category, and the clause reaches arrangements described as agency and arrangements not described that way at all. Read it beside the Explanation to section 22 and the position is consistent: the turnover is counted on the principal, and the person doing the supplying is separately liable in his own right. How that plays out in a drafted arrangement is dealt with on our agency agreement page.
An Input Service Distributor must be registered, and the section says so whether or not separately registered under the Act, which means the ISD registration is in addition to rather than instead of the ordinary one.
The agent clause is wider than the word suggests. It covers a person making taxable supplies on behalf of another, whether as an agent or otherwise, so a consignment arrangement, a del credere agency and a variety of distribution structures can fall inside it on their substance rather than on their label. What the parties called the arrangement is not the test.
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Two categories that exist because of what the person has to withhold rather than what it supplies.
A person required to deduct tax under section 51 must be registered, again whether or not separately registered under the Act. That catches the government departments, local authorities and notified persons who deduct on payments to suppliers. And the collecting side is the e-commerce operator already mentioned, required to collect tax at source under section 52.
Neither is a threshold question. A deductor with no supplies of its own at all is still required to be registered for the purpose of deducting.
One clause reaches outside India altogether, and it is worth knowing because the businesses it catches frequently do not know it exists.
Persons supplying online information and database access or retrieval services from a place outside India to a person in India, other than a registered person, must be registered. A software subscription, a learning platform, a stock image library selling to Indian consumers: that is the clause.
For a reader in India the clause matters in the mirror. It explains why a foreign supplier asks for your registration number, and why supplying to a registered person rather than a consumer changes the position.
Which is the conclusion the first half of this page has been building towards, and it deserves to be stated once in plain terms.
Turnover is one test among several, and it is the last one to apply rather than the first. If any clause of section 24 fits you, your turnover is not the question and no notification exempts you. If none fits, then you ask whether you supply goods exclusively, and whether any of the other three exclusions reaches you, and only then do you compare a figure.
This is the whole of the advice we give before anything is filed, and we give it in writing. It is also why we will not answer whether you need to register over a telephone call: the answer depends on what you supply, to whom, from where, through what channel, and in which State, and five of those six have nothing to do with the number everybody asks about first.
Having established that you are liable, the next question is the one that decides whether a late registration is a formality or a problem.
Liability under this Act is not created by the application. It arises on a date fixed by the provisions, and the application follows it. So the useful question is never when you applied; it is when you became liable.
Two dates are therefore in play from the beginning and they are easy to confuse. The date liability arose, which is fixed by the provisions and is usually the date a threshold was crossed or a section 24 activity began. And the date of submission of the application, which rule 8 computes in its own way. The first governs exposure; the second governs the officer timetable.
Every exposure for an unregistered period is measured from the date liability arose, not from the date anybody noticed. Fixing that date is the first entry in the file.
The period itself is short and it is stated in the section that governs the procedure.
Central Goods and Services Tax Act, 2017, section 25(1) — every person who is so liable shall apply for registration in every such State or Union territory in which he is so liable within thirty days from the date on which he becomes liable to registration, in the manner and on the conditions the Rules lay down.
Note the words every such State or Union territory. A registration is State-wise. A business liable in three States applies three times, and a single registration does not travel.
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Two categories work on the opposite principle, and for them the application comes first.
The proviso to the same sub-section requires a casual taxable person and a non-resident taxable person to apply for registration at least five days prior to the commencement of business.
So the exhibitor who plans to open a stall at a fair next week has already missed the period if he starts the paperwork on the day the fair opens. Five clear days before trading begins, not five days after, and a casual taxable person also has an advance deposit of tax to make before the acknowledgement issues at all.
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The application is in two parts, and the first is short enough to do in a sitting.
Part A of FORM GST REG-01 declares the permanent account number, the mobile number, the email address and the State or Union territory. It is filed on the common portal, directly or through a notified Facilitation Centre.
Certain categories are outside this route and apply differently: a non-resident taxable person, a person required to deduct tax under section 51, a person required to collect tax under section 52, and certain suppliers of online services from outside India. An Input Service Distributor makes a separate application of its own.
What happens next is automatic and it is worth understanding because it is where most applications stall on the first day.
The permanent account number is validated against the database maintained by the Central Board of Direct Taxes, and the mobile number and email address are verified through one-time passwords sent to each.
Which means the name, the constitution and the status on your income-tax record have to match what you are declaring here. A firm whose PAN still shows a dissolved constitution, or a name with a spelling that differs from the income-tax record, fails at this step and the failure is not fixable in the GST application. It is fixable only on the income-tax side first.
On successful verification a temporary reference number is generated and communicated to the applicant.
It is not a registration and it confers nothing. What it does is hold the application open so that Part B can be filed against it, and for a casual taxable person it is also the number against which the advance deposit of tax under section 27 is made.
Two practical cautions attach to it. It has a limited life, so an application left half-filed can expire and have to be begun again from Part A. And it is issued against the mobile number and email address declared in Part A, which is the first point at which using an intermediary address rather than your own starts to cause problems that surface months later.
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Using the temporary reference number, Part B of FORM GST REG-01 is filed with the documents specified, signed or verified through an electronic verification code.
The documents vary by constitution, but one is common to every application and causes most of the difficulty: proof of the principal place of business. Ownership papers where the premises are owned, or a rent agreement with a landlord NOC where they are not. Where a company or an LLP is filing, a digital signature is needed, and where somebody other than the proprietor is to act, an authorisation letter for the authorised signatory.
A bank account is not needed to make the application, and applicants frequently delay because they think it is. It is required to be furnished after registration, so the sensible sequence is to apply and then settle the current account documentation, rather than to let the thirty days run while a bank is chosen.
At this point the application asks a question that reads like a convenience and is in fact a fork in the procedure.
Do you opt for Aadhaar authentication. The Rules treat opting in and not opting in as two different routes with two different consequences, and neither of them avoids verification.
If you opt in, authentication is done at the time of submitting the application. If you do not, a photograph has to be taken and your original documents verified at a notified Facilitation Centre, and the application is not complete until that is done.
And here is a detail that governs everything which follows and that is almost never explained.
CGST Rules, 2017, rule 8(4A) — where an applicant, other than a person notified under section 25(6D), opts for authentication of the Aadhaar number, it shall be done while submitting the application, and the date of submission of the application in such cases shall be the date of authentication of the Aadhaar number, or fifteen days from the submission of the application in Part B of FORM GST REG-01, whichever is earlier.
So the date from which the officer periods are counted is a computed date, not the day you pressed submit. If authentication succeeds on the day, that is the date. If it does not happen, the fifteenth day from Part B becomes the date by operation of the rule.
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There is a further step that applies to some applicants and not others, and which one you are is not a choice you make.
Where an applicant who has opted for Aadhaar authentication is identified on the common portal, on the basis of data analysis and risk parameters, the application is followed by an additional process.
It is also worth understanding what being flagged is not. It is not an allegation, it is not a finding about the business, and it does not imply that anything in the application is wrong. It is a system output based on parameters applied to the data, and the response to it is attendance rather than argument.
Nobody publishes the parameters, and nobody will tell you in advance whether you will be flagged. Treat it as a possibility in every application rather than as an exception, and plan the timetable on the slower assumption.
What the additional process consists of is set out in the rule itself.
Biometric-based Aadhaar authentication, and the taking of a photograph of the applicant, where the applicant is an individual, or of the individuals the Act identifies where the applicant is not an individual.
That means attending in person. It is not something that can be completed on the portal, and it is not something a consultant can do on your behalf.
For a non-individual applicant the photograph is of the individuals the Act identifies in connection with the entity rather than of the entity, so a company or a firm has to decide who is attending before the appointment rather than on the day. Where the named person is abroad or unavailable for a stretch, that is a scheduling problem to solve early, because nothing in the timetable is moving while it waits.
And with it, a document check of a kind the portal cannot perform.
Verification of the original copies of the documents uploaded with the application, at one of the Facilitation Centres notified by the Commissioner.
What counts as the original is the document itself, not a notarised copy and not a certified extract, unless the thing you uploaded was itself a certified copy. Where an original genuinely cannot leave a premises or a bank, say so in advance rather than arriving without it, because an appointment that ends without verification leaves the application incomplete on the rule quoted below.
Which is a practical instruction rather than a warning: carry the originals of everything you uploaded, not photocopies and not phone images. The commonest reason these appointments are wasted is an applicant arriving with the same scans that are already on the portal.
Then the sentence that tells you what the delay actually costs.
The rule provides that the application shall be deemed to be complete only after completion of the process laid down under this proviso.
Until the appointment is done, nothing is running in your favour. No officer period has begun, no deemed approval is accruing, and the application is not an application for the purpose of the timetable. An applicant who postpones a centre visit by three weeks has not delayed the decision by three weeks; he has not yet made a complete application.
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Which brings us to the route many applicants used to prefer, and to the reason it is no longer a route around anything.
An applicant who has not opted for Aadhaar authentication is required to have a photograph taken and the original documents verified at a notified Facilitation Centre, and the application is complete only after that successful verification.
The drafting here is deliberate. Rather than making Aadhaar authentication compulsory in terms, the Rules make the alternative to it more onerous, which achieves the same end without the constitutional difficulty of a mandate. The result for an applicant is that declining is a real option with a real cost rather than a loophole.
That requirement is recent enough to be worth dating, because advice written before it says the opposite.
It was inserted by Notification No. 12/2024-Central Tax with effect from 11 February 2025. Before it, declining Aadhaar authentication meant falling into the longer thirty day officer route; after it, declining also means attending a centre in person.
The date is worth carrying because of what it does to older material. Any guide, template or checklist written before February 2025 will describe declining Aadhaar authentication as a way of staying on the portal, and will be describing a position that no longer exists. On this subject the age of the source is as important as its accuracy was when written.
So the choice is no longer between authenticating and avoiding scrutiny. It is between authenticating electronically and attending in person, and the second is slower. Unless there is a specific reason not to, opt in.
A question readers always ask at this point, and the honest answer requires a little care.
The Rules contain a power to notify States and Union territories in which the biometric proviso will not apply, which implies a geography. Separately, the biometric process has been publicised as rolling out State by State through advisories on the common portal.
The question matters because the answer decides whether you should block out a morning for a centre appointment or expect to finish on the portal. For a business in a hurry, that is the difference between a week and a fortnight, and it is the one planning input a reader most wants from a page like this.
We are not going to give you a list of States, and the reason is a finding rather than caution.
The notification trail we read against the rule records the position one way; the State-by-State rollout announced through portal advisories describes it another. We could not reconcile the two from the sources available to us, and a list printed here would be wrong somewhere.
So the instruction is: confirm the position for your own State from the current advisory on the common portal, on the day you intend to file. We would rather tell you that we could not establish it than print ten State names and let you plan a timetable around them. This is the same rule we apply to every figure on this site, and on this subject it has to be applied more often than on any other.
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Once a complete application exists, the Rules put the officer on a timetable, and the timetable has teeth.
There are two tracks. A fast one for an application that is in order with authentication done, and a slower one that carries a visit to your premises. Which track you are on is decided by the same factors discussed above.
Both tracks share one feature worth noticing at the outset: the periods bind the officer and not the applicant. Nothing in them obliges you to do anything once a complete application is in. They exist to put an outer limit on how long the file can sit, and sub-rule (5) gives that limit its force.
The fast track first.
Where the application and the accompanying documents are found to be in order, the proper officer is to approve the grant of registration within seven working days from the date of submission of the application.
Working days, so weekends and holidays are outside the count, and from the date of submission as the rule computes it rather than as the screen reports it.
Seven working days is short enough that a complete, well-documented application often beats the timetable a client has been led to expect. It is also short enough that an incomplete one wastes it, because a query under the next sub-rule resets the useful part of the period. The quality of the file at submission is therefore the main thing within your control.
The slower track applies in three identified situations and substitutes a different period.
Where the applicant, other than a person notified under section 25(6D), has not undergone or has not opted for Aadhaar authentication; where an applicant who did opt is identified on the portal on the basis of data analysis and risk parameters for physical verification of the place of business; or where the proper officer, with the approval of an officer authorised by the Commissioner not below the rank of Assistant Commissioner, considers it necessary, registration is granted within thirty days of submission, after physical verification of the place of business and such verification of documents as the officer may deem fit.
One change to that process is worth knowing because it affects what you should do rather than what you should expect.
The requirement that the applicant be present at the physical verification was removed by Notification No. 38/2023-Central Tax. A verification can therefore be carried out and recorded without you there.
Three things follow, and all three cost nothing. Keep the declared premises in a state that matches the declaration. Keep the signage or board up, because its absence is routinely recorded. And make sure whoever is at the address knows an application has been made and who to telephone, since the officer will not wait for you to arrive.
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If the officer finds the application deficient, or wants something clarified, the Rules give him a form and a period for it.
A notice issues in FORM GST REG-03, within seven working days from the date of submission, or not later than thirty days in the cases where the slower track applies.
A notice at this stage is ordinary rather than ominous. It usually asks for a clearer address proof, a legible document, a reconciliation between the name on the application and the name on the income-tax record, or an explanation of the business activity described. None of those is a refusal, and the great majority of them are answered on the papers already in the file.
And then the period that belongs to you, which is the one worth writing in a diary.
The applicant is to furnish the clarification, information or documents sought, electronically in FORM GST REG-04, within seven working days of receiving the notice.
From receipt, not from the date on the notice, and not from the day somebody opened the portal and noticed it. Which makes the email address and mobile number declared in Part A operationally important: they are where this arrives, and a period that runs from receipt runs whether or not the recipient was watching.
There is an Explanation to that sub-rule which turns a query from a threat into an opportunity, and most applicants do not know it is there.
CGST Rules, 2017, rule 9(2), Explanation — the expression clarification includes modification or correction of particulars declared in the application for registration, other than the permanent account number, State, mobile number and electronic mail address declared in Part A of FORM GST REG-01.
So almost anything declared in Part B can be corrected in the reply. What cannot be touched is the four things fixed in Part A, and those four are precisely the ones that have to be right the first time.
If no reply comes, or the reply does not satisfy, the Rules provide for refusal, with two features worth noting.
The officer may, for reasons to be recorded in writing, reject the application and inform the applicant in FORM GST REG-05. The word was substituted from shall to may by Notification No. 62/2020-Central Tax, so rejection is a discretion rather than the automatic consequence of an unsatisfactory answer.
Reasons recorded in writing are also the material any challenge would be built on, and the reply to a query is where the record is made. We draft those as reply drafting work, and where a refusal has already issued the route is a separate one, dealt with on our GST appeal page.
Place Order — no advance, pay after work
And the provision that readers find hardest to believe, which closes this part of the page.
CGST Rules, 2017, rule 9(5) — if the proper officer fails to take any action, the application for grant of registration shall be deemed to have been approved — (a) within seven working days from the date of submission of the application, where the proviso to sub-rule (1) does not apply; (b) within thirty days from the date of submission, where that proviso applies; or (c) within seven working days from the date of receipt of the clarification, information or documents furnished by the applicant under sub-rule (2).
Inaction is approval. Not delay, not a pending file, not a reason to telephone the office. If the periods have run and nothing has happened, the application stands approved by force of the sub-rule, and the practical step is to look for the certificate rather than to chase a decision. A business whose status is in doubt at that point should also look at its notice history on the portal, because a notice issued and not received is the usual explanation for a file that appears to have stopped.
Something was added to the Rules in late 2025 that changes the shape of a first registration for a small supplier, and it is new enough that most accounts of the process do not mention it.
Rule 14A came into effect on 1 November 2025. It creates an optional route in which registration is granted electronically, without the officer stage, to an applicant who fits inside a monthly ceiling and who completes Aadhaar authentication.
Three working days from the application reference number, granted by the system rather than by a person. That is the whole offer, and it is a real one.
Place Order — no advance, pay after work
Stated as the three things that are actually different.
The grant is electronic and automatic, so there is no proper officer forming a view, no query, and no physical verification stage. The timetable is three working days from generation of the application reference number, conditional on Aadhaar authentication succeeding. And the uncertainty that this page spends most of its length on, namely whether you will be flagged, whether a centre visit is coming, whether thirty days applies instead of seven, does not arise.
For a small supplier who sells to businesses and wants a number quickly, this is the first genuinely faster route the Rules have offered. It is worth asking for by name, because an application prepared without it defaults into the ordinary stream.
The price is a ceiling, and the ceiling is on tax rather than on turnover, which is an unusual way to draw a line and is the part most people misread.
CGST Rules, 2017, rule 14A — the route is open where the applicant’s self-assessed total output tax liability, taken across central tax, State or Union territory tax, integrated tax and compensation cess, on supplies made to registered persons, will not exceed two lakh fifty thousand rupees in a month. Aadhaar authentication is required for the primary authorised signatory and for at least one promoter or partner. The option is exercised by selecting it in FORM GST REG-01, and registration is then granted electronically within three working days of generation of the application reference number. A person registered under this rule in a State or Union territory may not take another registration under it in that same State or Union territory against the same permanent account number.
Withdrawal is possible and it is conditional, so the decision to opt in should be made knowing how the exit works rather than afterwards.
Every return due from the effective date of registration up to the date of the withdrawal application has to be filed first. Withdrawal is not available while an application to amend the registration is pending, while an application to cancel it is pending, or while cancellation proceedings under section 29 have been initiated or are pending.
Read those three bars together and the sequence they impose is obvious: clear the returns, settle any amendment, and only then apply to come out. A withdrawal filed on top of a pending amendment simply waits.
Place Order — no advance, pay after work
There is one more condition on withdrawal and it turns on a date that has now passed, which is exactly why it is worth stating rather than quietly dropping.
A person withdrawing before 1 April 2026 had to have filed returns for at least three months. A person withdrawing on or after that date needs returns for at least one tax period.
So the scheme was deliberately made stickier in its first months than it is now. For anybody opting in from here, the exit requirement is the lighter one, and that changes the calculation for a business unsure whether it will stay inside the ceiling.
Our part of this is documentation and sequencing, and the sequencing is where most of the value sits.
We establish first whether you are liable at all, which means working through section 24 before looking at any threshold, and then which threshold applies to you rather than the one in general circulation. We settle whether the simplified route under rule 14A fits, and say so in writing. We assemble the documents in the form the portal will accept them, which is a narrower thing than having the documents. We prepare the application, complete the Aadhaar step, and record the date of submission as the Rules compute it rather than as the portal displays it. And we answer a query in FORM GST REG-03 inside its own seven working days.
One thing we insist on, and it costs us arguments. The principal place of business declared in the application has to be a place the business actually occupies, with a document that supports the occupation. A declared address that cannot survive a visit is the single most common reason a registration is refused or later cancelled, and it is not a problem we will paper over at the application stage.
Four places where this stops being documentation, named in advance.
Representation before the proper officer on a query or a rejection. Anything to do with cancellation or revocation, which is its own exercise with its own windows and is dealt with on our GST cancellation page. A show cause notice or a demand, which belongs to the pages on those subjects. And an appeal, which is litigation and is set out on our GST appeal page.
We also give no view on your rate, your classification or your input credit position. Those are the questions a tax professional answers on your figures, and getting them wrong is expensive in a way that a registration never is.
Court work is for your advocate, whose fee is engaged and paid by you directly; we do not quote, collect or share it.
Place Order — no advance, pay after work
The output is a file and a certificate, and the file is the part that matters six months later.
| Item | Why it is in the file |
|---|---|
| Written liability note — section 24 first, then the threshold | It records why you registered when you did, which is the question a later notice asks |
| The application as filed, with its reference number | Every period in the Rules is computed from a date on it |
| The computed date of submission | Rule 8 fixes it by Aadhaar authentication or the fifteenth day, not by the screen |
| Address proof for the declared place of business | It is what a physical verification is checked against |
| Any FORM GST REG-03 query and the FORM GST REG-04 reply | Both carry their own seven working days |
| The certificate, with the effective date read off it | Liability, returns and credit all run from that date |
Each paper in it is checked against its source before it goes in, and anything that would be hard to obtain again has a certified true copy made while it is still to hand. A business that will accumulate returns, notices and amendments for years is better served keeping that set live than filing it away, and keeping it live is the whole of what legal file management does.
Send us what the business supplies, where its customers are, whether anything is sold through a marketplace, and the State it operates from. We will tell you in writing whether section 24 catches you regardless of turnover, which threshold applies to you if it does not, whether the simplified route under rule 14A fits, and what the declared place of business has to be supported by. If you are not liable, we will say that and charge you nothing for saying it.
Every figure on this page is traced to the provision or notification it comes from, and the most quoted figure of all turns out not to be in the Act. Governing law: the Central Goods and Services Tax Act, 2017, read with the Central Goods and Services Tax Rules, 2017. Section 22(1) requires every supplier to be registered in the State or Union territory, other than a special category State, from where he makes a taxable supply, if his aggregate turnover in a financial year exceeds twenty lakh rupees; the proviso sets the figure at ten lakh rupees for a supplier making taxable supplies from a special category State. The Explanation provides that aggregate turnover includes all supplies made by the taxable person, whether on his own account or made on behalf of all his principals, and that special category States are those specified in sub-clause (g) of clause (4) of article 279A of the Constitution. Sections 22(2), (3) and (4) deal with a person registered under an existing law, with the transferee of a business transferred as a going concern, and with a transferee under an approved scheme of amalgamation or demerger, who is liable from the date the Registrar of Companies issues the certificate of incorporation giving effect to the order. Section 23(1) exempts a person engaged exclusively in supplying goods or services not liable to tax or wholly exempt, and an agriculturist to the extent of produce out of cultivation of land; section 23(2) empowers the Government, on the Council’s recommendation, to specify by notification further categories of exempt persons.
The forty lakh figure comes from that notification power and not from section 22. Notification No. 10/2019-Central Tax, dated 7 March 2019, issued under section 23(2) and in force from 1 April 2019, exempts from registration any person engaged in exclusive supply of goods whose aggregate turnover in the financial year does not exceed forty lakh rupees — and then takes four classes of person back out of the exemption. It does not apply to persons required to take compulsory registration under section 24. It does not apply to persons supplying ice cream and other edible ice, whether or not containing cocoa (tariff item 2105 00 00), pan masala (tariff item 2106 90 20), or all goods of Chapter 24, being tobacco and manufactured tobacco substitutes. It does not apply to persons making intra-State supplies in Arunachal Pradesh, Manipur, Meghalaya, Mizoram, Nagaland, Puducherry, Sikkim, Telangana, Tripura or Uttarakhand. And it does not apply to a person exercising the option under section 25(3) or to a registered person seeking to continue his registration. Section 24 then requires registration notwithstanding section 22(1) for, among others, anyone making an inter-State taxable supply, casual and non-resident taxable persons, those liable under reverse charge or under section 9(5), deductors under section 51, persons supplying for a principal, Input Service Distributors, persons supplying through an electronic commerce operator required to collect tax at source under section 52, every electronic commerce operator, and persons supplying online information and database access or retrieval services from outside India to an unregistered person in India.
On the application and the timetable, section 25(1) requires a person liable under section 22 or section 24 to apply in every such State or Union territory within thirty days from the date on which he becomes liable, with a proviso requiring a casual taxable person and a non-resident taxable person to apply at least five days prior to the commencement of business. Rule 8 requires Part A of FORM GST REG-01 declaring the permanent account number and the State, the number being validated against the Central Board of Direct Taxes database and the mobile number and electronic mail address verified by one-time password, whereupon a temporary reference number is issued and Part B is filed with the documents. Rule 8(4A) provides that where an applicant other than a person notified under section 25(6D) opts for Aadhaar authentication, it is to be done at the time of submitting the application, and the date of submission is the date of authentication of the Aadhaar number or fifteen days from the submission of Part B, whichever is earlier. Its first proviso provides that where such an applicant is identified on the common portal, on the basis of data analysis and risk parameters, the application is to be followed by biometric-based Aadhaar authentication and taking of a photograph, together with verification of the original documents uploaded with the application at a notified Facilitation Centre, and that the application shall be deemed to be complete only after completion of that process. Its second proviso, inserted by Notification No. 12/2024-Central Tax with effect from 11 February 2025, applies the photograph and original-document verification at a Facilitation Centre to an applicant who has not opted for Aadhaar authentication. Rule 8(4B) empowers the Government to notify States or Union territories in which the proviso to sub-rule (4A) will not apply, and the notification trail we read records that position differently from the State-by-State rollout the common portal has advertised; we therefore give no list of States here and say instead that the position for your State must be confirmed from the current advisory on the portal. Rule 8(5) provides for the acknowledgement in FORM GST REG-02, and rule 8(6) provides that a casual taxable person is given a temporary reference number for the advance deposit of tax under section 27, the acknowledgement being issued only after that deposit.
On the officer’s side, rule 9(1) requires the proper officer, where the application and documents are found in order, to approve the grant of registration within seven working days from the date of submission. Its proviso substitutes thirty days, and requires physical verification of the place of business and such verification of documents as the officer deems fit, where the applicant other than a person notified under section 25(6D) has not undergone or has not opted for Aadhaar authentication, where an applicant who did opt is identified on the portal on the basis of data analysis and risk parameters for physical verification, or where the proper officer with the approval of an officer authorised by the Commissioner not below the rank of Assistant Commissioner considers it necessary; the requirement that the applicant be present at that verification was removed by Notification No. 38/2023-Central Tax. Rule 9(2) allows a notice in FORM GST REG-03 within seven working days, or not later than thirty days in the proviso cases, requiring a reply in FORM GST REG-04 within seven working days; its Explanation provides that clarification includes modification or correction of particulars declared, other than the permanent account number, State, mobile number and electronic mail address declared in Part A. Rule 9(3) allows approval within seven working days of receipt of that reply. Rule 9(4) provides that the officer may, for reasons to be recorded in writing, reject the application and inform the applicant in FORM GST REG-05, the word having been substituted for shall by Notification No. 62/2020-Central Tax. And rule 9(5) provides that if the proper officer fails to take any action, the application shall be deemed to have been approved — within seven working days of submission where the proviso to sub-rule (1) does not apply, within thirty days where it does, and within seven working days of receipt of the clarification. Rule 14A is quoted in the box above; the simplified route took effect on 1 November 2025, and the withdrawal condition requiring returns for at least three months applied to a withdrawal before 1 April 2026, with one tax period sufficing on or after that date. Cancellation and revocation, a show cause notice, and an appeal are each dealt with on their own pages rather than a second time here. Rates, classification and input tax credit are outside this page entirely. Every figure, form number and period above should be confirmed against the current text and the current portal advisory before an application is filed, because this is the fastest-moving compliance subject on this site.
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