Registration FAQ

Q 1. What is advantage of taking registration in GST?
Ans. Registration under Goods and Service Tax (GST)
regime will confer following advantages to the business:
• Legally recognized as supplier of goods or
services.
• Proper accounting of taxes paid on the input
goods or services which can be utilized for
payment of GST due on supply of goods or
services or both by the business.
• Legally authorized to collect tax from his
purchasers and pass on the credit of the taxes
paid on the goods or services supplied to
purchasers or recipients.

Q 2. Can a person without GST registration claim
ITC and collect tax?
Ans. No. A person without GST registration can neither
collect GST from his customers nor claim any input tax credit
of GST paid by him.

Q 3. What will be the effective date of
registration?
Ans. Where the application for registration has been
submitted within thirty days from the date on which the
person becomes liable to registration, the effective date of
registration shall be date of his liability for registration.
3. Registration
28 Where an application for registration has been submitted
by the applicant after thirty days from the date of his
becoming liable to registration, the effective date of
registration shall be the date of grant of registration.
In case of suomoto registration, i.e. taking registration
voluntarily while being within the threshold exemption limit
for paying tax, the effective date of registration shall be the
date of order of registration.

Q 4. Who are the persons liable to take a
Registration under the Model GST Law?
Ans. Any supplier who carries on any business at any
place in India and whose aggregate turnover exceeds
threshold limit as prescribed in a year is liable to get
himself registered. However, certain categories of persons
mentioned in Schedule III of MGL are liable to be registered
irrespective of this threshold.
An agriculturist shall not be considered as a taxable person
and shall not be liable to take registration. (As per section
9 (1))
Q 5. What is aggregate turnover?
Ans. As per section 2 (6) of the MGL, aggregate turnover
includes the aggregate value of:
(i) all taxable and non-taxable supplies,
(ii) exempt supplies, and
(iii) exports of goods and/or service of a person
having the same PAN.
The above shall be computed on all India basis and excludes
taxes charged under the CGST Act, SGST Act and the IGST
Act.
Aggregate turnover does not include value of supplies on
which tax is levied on reverse charge basis, and value of
inward supplies.

Q 6. Which are the cases in which registration is
compulsory?
Ans. As per paragraph 5 in Schedule III of MGL, the
following categories of persons shall be required to be
registered compulsorily irrespective of the threshold limit:
a) persons making any inter-State taxable supply;
b) casual taxable persons;
c) persons who are required to pay tax under reverse
charge;
d) non-resident taxable persons;
e) persons who are required to deduct tax under
section 37;
f) persons who supply goods and/or services
on behalf of other registered taxable persons
whether as an agent or otherwise;
g) input service distributor;
h) persons who supply goods and/or services,
other than branded services, through electronic
commerce operator;
i) every electronic commerce operator; j) an aggregator who supplies services under his brand name or his trade name; and
k) such other person or class of persons as may be
notified by the Central Government or a State
Government on the recommendations of the
Council.

Q 7. What is the time limit for taking a Registration
under Model GST Law?
Ans. Any person should take a Registration, within
thirty days from the date on which he becomes liable to
registration, in such manner and subject to such conditions
as may be prescribed.

Q 8. If a person is operating in different states, with
the same PAN number, whether he can operate with a
single Registration?
Ans. No. Every person who is liable to take a Registration
will have to get registered separately for each of the States
where he has a business operation and is liable to pay
GST in terms of Sub-section (1) of Section 19 of Model GST
Law.

Q 9. Whether a person having multiple business
verticals in a state can obtain for different
registrations?
Ans. Yes. In terms of Sub-Section (2) of Section 19, a person
having multiple business verticals in a State may obtain a
separate registration for each business vertical, subject to
such conditions as may be prescribed.

Q 10. Is there a provision for a person to get himself
voluntarily registered though he may not be liable to
pay GST?
Ans. Yes. In terms of Sub-section (3) of Section 19, a person,
though not liable to be registered under Schedule III, may
get himself registered voluntarily, and all provisions of this
Act, as are applicable to a registered taxable person, shall
apply to such person.

Q 11. Is possession of a Permanent Account Number
(PAN) mandatory for obtaining a Registration?
Ans. Yes. Every person shall have a Permanent Account
Number issued under the Income Tax Act, 1961 (43 of
1961) in order to be eligible for grant of registration under
Section 19 of the Model GST Law.
However as per section 19 (4A) of MGL, PAN is not
mandatory for a non-resident taxable person who may be
granted registration on the basis of any other document as
may be prescribed.

Q 12. Whether the Department through the proper
officer, can suo-moto proceed with registration of a
Person under this Act?
Ans. Yes. In terms of sub-section (5) of Section 19, where a
person who is liable to be registered under this Act fails to
obtain registration, the proper officer may, without prejudice
to any action that is, or may be taken under the MGL, or under
any other law for the time being in force, proceed to register
such person in the manner as may be prescribed.

Q 13. Whether the proper Officer can reject an
Application for Registration?
Ans. Yes. In terms of sub-section 7 of MGL, the proper
officer can reject an application for registration after due
verification. However, it is also provided in sub-section
8 of Section 19, the proper officer shall not reject the
application for registration or the Unique Identity Number
without giving a notice to show cause and without giving
the person a reasonable opportunity of being heard.

Q 14. Whether the Registration granted to any
person is permanent?
Ans. Yes, the registration Certificate once granted is
permanent unless surrendered, cancelled, suspended or
revoked.

Q 15. Is it necessary for the UN bodies to get
registration under MGL?
Ans. All UN bodies Consulate or Embassy of foreign
countries and any other class of persons so notified would
be required to obtain a unique identification number (UIN)
from the GST portal. The structure of the said ID would
be uniform across the States in conformity with GSTIN
structure and the same will be common for the Centre and
the States. This UIN will be needed for claiming refund of
taxes paid by them and for any other purpose as may be
prescribed in the GST Rules.

Q 16. What is the responsibility of the taxable person
supplying to UN bodies?
Ans. The taxable supplier supplying to these organizations
is expected to mention the UIN on the invoices and treat
such supplies as supplies to another registered person
(B2B) and the invoices of the same will be uploaded by the
supplier.
Q 17. Is it necessary for the Govt. organization to get
registration?
Ans. A unique identification number (ID) would be given
by the respective state tax authorities through GST portal
to Government authorities / PSUs not making outwards
supplies of GST goods (and thus not liable to obtain GST
registration) but are making inter-state purchases.
Q 18. Who is a Casual Taxable Person?
Ans. Casual Taxable Person has been defined in Section
2 (21) of MGL. It means a person who occasionally
undertakes transactions in a taxable territory where he
has no fixed place of business.

Q 19. Who is a Non-resident Taxable Person?
Ans. A taxable person residing outside India and coming to
India to occasionally undertake transaction in the country
but has no fixed place of business in India is a non-resident
taxable person in terms of Section 2 (69) of the MGL.

Q 20. What is the validity period of the Registration
certificate issued to a Casual Taxable Person and non-
Resident Taxable person?
Ans. The certificate of registration issued to a “casual
taxable person” or a “non-resident taxable person” shall
be valid for a period of ninety days from the effective date
of registration. However, the proper officer, at the request
of the said taxable person, may extend the validity of the
aforesaid period of ninety days by a further period not
exceeding ninety days.

Q 21. Is there any Advance tax to be paid by a Casual
Taxable Person and Non-resident Taxable Person at
the time of obtaining registration under this Special
Category?
Ans. Yes. While a normal taxable person does not have to
make any deposit of money to obtain registration, a casual
taxable person or a non-resident taxable person shall, at
the time of submission of application for registration under
sub-section (1) of section 19, make an advance deposit of
tax in an amount equivalent to the estimated tax liability
of such person for the period for which the registration is
sought. If registration is to be extended beyond the initial
period of ninety days, an advance additional amount of tax
equivalent to the estimated tax liability is to be deposited
for the period for which the extension beyond ninety days
is being sought.

Q 22. Whether Amendments to the Registration
Certificate is permissible?
Ans. Yes. In terms of Section 20, the proper officer may,
on the basis of such information furnished either by the
registrant or as ascertained by him, approve or reject
amendments in the registration particulars in the manner
and within such period as may be prescribed. It is to be
noted that permission of the proper officer for making
amendments will be required for only certain core fields
of information, whereas for the other fields, the registrant
can himself carry out the amendments.
Q 23. Whether Cancellation of Registration
Certificate is permissible?
Ans. Yes. Any Registration granted under this Act may
be cancelled by the Proper Officer, in circumstances
mentioned in Section 21 of the MGL. The proper officer
may, either on his own motion or on an application filed,
in the prescribed manner, by the registered taxable person
or by his legal heirs, in case of death of such person, cancel
the registration, in such manner and within such period as
may be prescribed.
Q 24. Whether cancellation of Registration under
CGST Act means cancellation under SGST Act also?
Ans. Yes. The cancellation of registration under one Act
(say CGST Act) shall be deemed to be a cancellation of
registration under the other Act (i.e. SGST Act). (Section
21 (6))
Q 25. Can the proper Officer Cancel the Registration
on his own?
Ans. Yes, in certain circumstances specified under section
21(2) of MGL, the proper officer can cancel the registration
on his own. Such circumstances include not filing return
for a continuous period of six months (for a normal taxable
36 person) or three months (for a compounding taxpayer),
and not commencing business within six months from
the date of registration. However, before cancelling the
registration, the proper officer has to follow the principles
of natural justice. (Section 21 (4))
Q 26. What happens when the registration is
obtained by means of wilful mis-statement, fraud or
suppression of facts?
Ans. In such cases, the registration may be cancelled
with retrospective effect by the proper officer. Section
21(3).
Q 27. Is there an option to take centralized
registration for services under MGL?
Ans. No.
Q 28. If the taxpayer has different business
verticals in one state, will he have to obtain separate
registration for each such vertical in the state?
Ans. No. However the taxpayer has the option to register
such separate business verticals independently in terms of
Section 19(2) of MGL.
Q 29. Who is an ISD?
Ans. ISD stands for Input Service Distributor and has
been defined under Section 2 (56) of MGL. It is basically
an office meant to receive tax invoices towards receipt of
input services and further distribute the credit to supplier
units proportionately.
37
Q 30. Will ISD be required to be separately registered
other than the existing taxpayer registration?
Ans. Yes. The ISD registration is for one office of
the taxpayer which will be different from the normal
registration.
Q 31. Can a taxpayer have multiple ISDs?
Ans. Yes. Different offices of a taxpayer can apply for ISD
registration.
Q 32. What could be the liabilities (in so far as
registration is concerned) on transfer of a business?
Ans. The transferee or the successor shall be liable to be
registered with effect from such transfer or succession and he
will have to obtain a fresh registration with effect from such
date. (Schedule III of MGL).
Q 33. Whether all assessees/dealers who are already
registered under existing central excise/service tax/
vat laws will have to obtain fresh registration?
Ans. No. GSTN shall migrate all such assessees/dealers
to the GSTN network and shall issue GSTIN number and
password. They will be asked to submit all requisite
documents and information required for registration in a
prescribed period of time. Failure to do so will result in
cancellation of GSTIN number.
The service tax assessees having centralized registration
will have to apply afresh in the respective states wherever
they have their businesses.
38 Q 34. Whether the job worker will have to be
compulsorily registered?
Ans. No. Section 43A of MGL does not prescribe any such
condition.
Q 35. Whether the goods will be permitted to be
supplied from the place of business of a job worker?
Ans. Yes. But only in cases where the job worker is
registered or the principal declares the place of business of
the job worker as his additional place of business.
Q 36. At the time of registration will the assessee
have to declare all his places of business?
Ans. Yes. The principal place of business and place of
business have been separately defined under section 2(78)
& 2(75) of MGL respectively. The taxpayer will have to
declare the principal place of business as well as the details
of additional places of business in the registration form.
Q 37. Is there any system to facilitate smaller dealers
or dealers having no IT infrastructure?
Ans. In order to cater to the needs of taxpayers who are
not IT savvy, following facilities shall be made available:-
Tax Return Preparer (TRP): A taxable person may prepare
his registration application /returns himself or can
approach the TRP for assistance. TRP will prepare the
said registration document / return in prescribed format
on the basis of the information furnished to him by the
taxable person. The legal responsibility of the correctness
39
of information contained in the forms prepared by the TRP
will rest with the taxable person only and the TRP shall not
be liable for any errors or incorrect information.
Facilitation Centre (FC): shall be responsible for the
digitization and / or uploading of the forms and documents
including summary sheet duly signed by the Authorized
Signatory and given to it by the taxable person. After
uploading the data on common portal using the ID and
Password of FC, a print-out of acknowledgement will be
taken and signed by the FC and handed over to the taxable
person for his records. The FC will scan and upload the
summary sheet duly signed by the Authorized Signatory.
Q 38. Is there any facility for digital signature in the
GSTN registration?
Ans. Taxpayers would have the option to sign the
submitted application using valid digital signatures (if
the applicant is required to obtain DSC under any other
prevalent law then he will have to submit his registration
application using the same). For those who do not have a
digital signature, alternative mechanisms will be provided
in the GST Rules on Registration.
Q 39. What will be the time limit for the decision on
the online application?
Ans. If the information and the uploaded documents
are found in order, the State and the Central authorities
shall approve the application and communicate the
approval to the common portal within three common
working days. The portal will then automatically
40 generate the Registration Certificate. In case no
deficiency is communicated to the applicant by both
the tax authorities within three common working days,
the registration shall be deemed to have been granted
[section 19(9) of MGL] and the portal will automatically
generate the Registration Certificate.
Q 40. What will be the time of response by the
applicant if any query is raised in the online
application?
Ans. If during the process of verification, one of the tax
authorities raises some query or notices some error, the
same shall be communicated to the applicant and to the
other tax authority through the GST Common Portal within
3 common working days. The applicant will reply to the
query / rectify the error / answer the query within a period
informed by the concerned tax authorities (Normally this
period would be seven days).
On receipt of additional document or clarification, the
relevant tax authority will respond within seven common
working days.
Q 41. What is the process of refusal of registration?
Ans. In case registration is refused, the applicant will be
informed about the reasons for such refusal through a
speaking order. The applicant shall have the right to appeal
against the decision of the Authority. As per sub-section
(10) of section 19 of MGL, any rejection of application for
registration by one authority (i.e. under the CGST Act /
41
SGST Act) shall be deemed to be a rejection of application
for registration by the other tax authority (i.e. under the
SGST Act / CGST Act).
Q 42. Will there be any communication related to
the application disposal?
Ans. The applicant shall be informed of the fact of grant or
rejection of his registration application through an e-mail
and SMS by the GST common portal. Jurisdictional details
would be intimated to the applicant at this stage.
Q 43. Can the registration certificate be downloaded
from the GSTN portal?
Ans. In case registration is granted, applicant can
download the Registration Certificate from the GST
common portal. ]

Source : Central Board of Excise & Custom