GST Registration — MMDA Colony Mogappair & Mogappair

Section 22 of the Central Goods and Services Tax Act 2017 sets the threshold-based registration trigger. A person whose aggregate turnover in a financial year exceeds ₹40 lakh for exclusive goods suppliers in Tamil Nadu or ₹20 lakh for service or mixed suppliers is liable to be registered in every State from which they make taxable supplies. Aggregate turnover is computed PAN-wise across India and includes taxable, exempt, exports and inter-State supplies but excludes inward supplies on reverse charge.

Section 24 overrides the threshold under Section 22 and mandates registration regardless of turnover for inter-State taxable suppliers, casual taxable persons, persons liable under reverse charge, e-commerce operators and sellers on e-commerce platforms required to collect TCS under Section 52, non-resident taxable persons, TDS deductors under Section 51, Input Service Distributors and persons supplying through e-commerce operators.

Section 25 lays out the procedural framework — every person liable under Section 22 or Section 24 must apply for registration within thirty days from the date of becoming liable, in every State from which they make a taxable supply. Voluntary registration is permitted under Section 25(3). The proper officer grants registration after verification under Rule 9. Multiple business verticals within the same State can opt for separate registrations under Section 25(2) read with Rule 11.

Rule 8 of the CGST Rules prescribes Form GST REG-01 as the application for registration. Part A captures PAN, mobile and email — the system validates these and generates a Temporary Reference Number (TRN). Part B captures business details, promoters, authorised signatory, principal place of business, additional places, goods and services with HSN/SAC codes, bank account details and verification.

Rule 9 requires the proper officer to examine the REG-01 application within seven working days. If everything is in order the registration is granted and the GSTIN issued in Form REG-06. If any information is found deficient, a notice in Form REG-03 is issued and the applicant must reply in REG-04 within seven working days. If no reply is received or the reply is unsatisfactory, the application is rejected in Form REG-05.

The Rule 8(4A) framework requires the promoter or authorised signatory to undergo Aadhaar authentication. If Aadhaar authentication is not opted for, physical verification of the business premises under Rule 25 is mandatory before registration is granted. Aadhaar authentication is the faster path for most applicants.

What is GST registration and when is it required

Statutory basis under Section 22

GST registration in India is governed by Sections 22 to 30 of the Central Goods and Services Tax Act 2017 read with corresponding State GST legislation. The trigger for compulsory registration under Section 22 is an aggregate annual turnover of ₹40 lakh for exclusive suppliers of goods in Tamil Nadu (per Notification 10/2019-Central Tax) and ₹20 lakh for service or mixed suppliers. Aggregate turnover under Section 2(6) is the sum of all taxable supplies, exempt supplies, exports of goods and services, and inter-State supplies of a person having the same Permanent Account Number, computed on an all-India basis. Once a person crosses this threshold in any financial year, the obligation to register arises within thirty days under Section 25(1). Section 24 of the CGST Act overrides Section 22 entirely for specified categories including inter-State taxable suppliers, casual taxable persons, persons supplying through e-commerce operators, and reverse-charge liable persons — these categories must register regardless of turnover.

Voluntary registration option

A person whose aggregate turnover is below the threshold can still register voluntarily under Section 25(3) of the CGST Act. Once voluntary registration is granted, all provisions of GST law apply to such a person as they would to any registered person — including monthly returns, ITC eligibility for inputs, and the obligation to issue tax invoices. Voluntary registration is commonly chosen by B2B service providers and traders who want to enable ITC pass-through to their corporate clients, by exporters who need to file LUTs and claim refunds, and by startups that want to capture ITC on early-stage procurement before revenue commencement. Once obtained, voluntary registration cannot be casually surrendered — REG-16 cancellation follows the same procedure as any other cancellation under Section 29.

Special cases — multi-State branches business verticals SEZ

Separate State registration

Section 25(1) of the CGST Act requires every person making taxable supplies from a State to obtain a separate registration in that State. The principle is one registration per State per PAN, with sub-cases for multi-vertical entities. A business with a Tamil Nadu base expanding into Karnataka, Andhra Pradesh and Telangana needs four separate GSTINs — one in each State of operation — even though all four are under the same PAN. Each State registration files its own monthly returns, maintains its own electronic ledgers, and is independently subject to scrutiny by the respective State commissionerate. Inter-State stock transfer between own branches is treated as a supply under Schedule I and requires invoicing and e-way bills.

Multiple registrations within the same State

Section 25(2) read with Rule 11 of the CGST Rules permits a person to obtain more than one registration in the same State for distinct business verticals. A business vertical is defined in the rules as a distinguishable component of an entity engaged in supplying an individual product or service or a group of related products or services that is subject to risks and returns that are different from those of other business verticals. The classic example is a manufacturer with both an industrial-products arm and a consumer-products arm; another is a real-estate developer with both a residential project and a commercial project. Each vertical obtains its own GSTIN under the same PAN; ITC cannot be cross-utilised between verticals but the Input Service Distributor mechanism under Section 20 can be used for shared input services.

SEZ unit and developer registration

Special Economic Zone units and SEZ developers are required to obtain registration in the SEZ State separately from any registration the parent group may hold in the same State for non-SEZ operations. The SEZ-zone unit operates outside the customs territory of India and supplies into the SEZ from DTA suppliers are treated as zero-rated supplies under Section 16 of the IGST Act; supplies from SEZ to DTA are treated as inter-State supplies and attract IGST. SEZ units file the standard monthly GSTR-1 and GSTR-3B and apply for refunds of accumulated ITC under Section 54 with Rule 89 conditions. The SEZ-LoA (Letter of Approval) is captured as supporting documentation in REG-01.

Common registration mistakes and how to avoid them

Wrong PAN or constitution declaration

The most consequential REG-01 error is mismatch between the constitution declared in REG-01 and the legal constitution of the entity. A sole proprietor declaring constitution as Partnership invites rejection at REG-03 stage. A pre-incorporation company declared with its proposed name (without certificate of incorporation) is similarly rejected. Care must be taken to declare the exact constitution as on the date of REG-01 filing, with corresponding PAN and address proof aligned. For companies, the registered office address with MCA must match the principal place of business in REG-01 to the letter — any difference triggers Rule 9 deficiency notice. For partnerships, the partnership deed must be registered with the appropriate registrar where State law requires it (Tamil Nadu permits unregistered firms but registration is preferred for compliance robustness).

Address proof and NOC errors

Address proof errors are the second most common source of registration delay. The accepted address-proof documents are: latest electricity bill (not older than 60 days), property tax receipt, registered rent agreement (for rented premises), title deed (for owned premises), and consent letter / NOC from the owner along with the owner's address proof (for premises not in the applicant's name). A rent agreement on plain paper without registration is generally rejected for non-residential GST registration. The NOC from the owner must be on the owner's letterhead (for corporate owners) or on plain paper with notarisation (for individual owners). Where the property is jointly owned, NOC from all joint owners is preferred. Co-working space registration requires the operator's own rent agreement and electricity bill plus a notarised seat-allocation NOC.

HSN SAC and business activity declaration

REG-01 Part B requires declaration of the principal HSN code (for goods) or SAC code (for services) and up to four secondary HSN / SAC codes. Common mistakes include: declaring an HSN that does not match the actual business activity, using too generic a code (e.g. HSN 99 for services without sub-classification), or omitting a major business line entirely. Wrong HSN declaration at registration cascades into wrong rate disputes in subsequent returns and ITC questions on inputs. A short consultation with a tax practitioner to map the business activity to the correct HSN / SAC codes is well worth the time. For multi-vertical businesses, the HSN list should cover all verticals — Rule 19 amendment can add HSN codes later, but starting with the right list avoids subsequent compliance friction.

After registration — first compliance milestones

Display of GSTIN at place of business

Section 26 of the CGST Rules read with Rule 18 requires every registered person to display the certificate of registration (REG-06) at a prominent location of every place of business — principal and all additional places. The GSTIN must also be displayed on the name-board outside each place of business. Non-display attracts a general penalty under Section 125 (₹25,000 each for CGST and SGST). Many small traders overlook this requirement; while it rarely leads to material penalty proceedings, departmental visits do flag it.

Invoice format and tax invoice rules

Once registered, the registered person must issue tax invoices for taxable supplies in the format prescribed under Rule 46 of the CGST Rules. The tax invoice must carry: invoice number (consecutive, unique for the FY), date of issue, supplier GSTIN and name, recipient GSTIN and name (for B2B), recipient address, HSN / SAC code, description of goods or services, quantity / unit (for goods), value of supply, taxable value after discount, applicable rate of GST, amount of CGST + SGST or IGST, place of supply (for inter-State), reverse-charge applicability (if any), and signature of the supplier or authorised representative. Composition taxpayers issue bills of supply (Rule 49) instead of tax invoices. Specific timelines apply for issuance — for goods, before or at the time of removal; for services, within 30 days of supply.

Setting up books of accounts under Rule 56

Rule 56 of the CGST Rules prescribes the books of accounts to be maintained by every registered person at the principal place of business and at every additional place. The records include: register of production / manufacture (for manufacturers), register of inward and outward supplies, register of stock, register of input tax credit availed, register of output tax payable and paid. Records must be retained for at least 72 months from the due date of furnishing the annual return for the year (effectively six years). Electronic record-keeping is permitted but a print-out or generation-on-demand capability is required. For jewellers, Rule 56(18) prescribes a stock register specific to high-value precious-metal supplies.

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