GST registration and amendments
Registration looks like a one-off task that was finished years ago. In practice it is the thing that quietly goes wrong: a threshold crossed in a new state, a director change never filed, a registration cancelled for non-filing that nobody applied to revoke in time. This guide covers when registration is compulsory, the faster routes introduced in November 2025, what has to be amended and how quickly, and what happens when a registration is cancelled.
The threshold is not one number, and the exceptions are counterintuitive
Section 22 of the Central Goods and Services Tax Act sets the base threshold at aggregate turnover of ₹20 lakh in a financial year, reduced to ₹10 lakh for supplies made from a special category state. Since 1 February 2019, only four states remain special category for this purpose: Manipur, Mizoram, Nagaland and Tripura.
A separate notification, Notification 10/2019-Central Tax, raises the threshold to ₹40 lakh, but only for a person exclusively supplying goods. It does not apply to service providers at all, it does not apply to anyone required to register compulsorily, it does not apply to suppliers of ice cream, pan masala or tobacco, and it does not apply in ten named states and union territories.
Put together, the position for a supplier of goods is:
| Threshold for a supplier of goods only | Where |
|---|---|
| ₹40 lakh | Most states and union territories, including Assam, Himachal Pradesh, Jammu and Kashmir, and Ladakh |
| ₹20 lakh | Arunachal Pradesh, Meghalaya, Puducherry, Sikkim, Telangana, Uttarakhand |
| ₹10 lakh | Manipur, Mizoram, Nagaland, Tripura |
For a supplier of services, or of goods and services together, the threshold is ₹20 lakh everywhere except Manipur, Mizoram, Nagaland and Tripura, where it is ₹10 lakh.
Aggregate turnover is computed on a PAN basis across all of India, including exempt supplies, exports and inter-state supplies. It is not the turnover of the state you are asking about. A business well under the threshold in a new state can already be over it nationally.
When registration is compulsory whatever your turnover
Section 24 overrides the threshold entirely. The entries that catch ordinary businesses are inter-state taxable supply of goods, liability to pay under reverse charge, casual taxable person status, agents supplying on behalf of another taxable person, Input Service Distributors, and anyone required to deduct or collect tax at source.
Three exemptions matter, because they are the difference between one registration and several:
- Inter-state supply of services does not trigger compulsory registration. Notification 10/2017-Integrated Tax, as amended, exempts a person supplying services across state lines whose all-India aggregate turnover stays within the ordinary threshold. There is no equivalent exemption for inter-state supply of goods: one inter-state sale of goods and registration is compulsory from that point.
- Suppliers of services through an e-commerce operator are similarly exempt up to the threshold, under Notification 65/2017-Central Tax as amended.
- Suppliers of goods through an e-commerce operator were given a waiver of the Section 24(ix) requirement by Notification 34/2023-Central Tax with effect from 1 October 2023, subject to conditions.
The conditions on that waiver are restrictive and easily breached, and all four have to hold:
- Aggregate turnover stays within the ordinary Section 22(1) registration threshold for the state, whether that is ₹40 lakh, ₹20 lakh or ₹10 lakh.
- The person makes no inter-state supply of goods.
- The person supplies goods through an e-commerce operator in one state or union territory only.
- The person holds a valid PAN, declares it together with the business address on the common portal, and obtains an enrolment number before making any supply.
The first inter-state order an otherwise intra-state seller accepts takes the waiver away, and registration becomes compulsory under Section 24 from the first rupee of sales.
Two new registration routes, both three working days, and they are not the same thing
Notification 18/2025-Central Tax, dated 31 October 2025, inserted two new rules with effect from 1 November 2025. A great deal of commentary describes them as one scheme. They are different, and the difference decides which one you should be using.
Rule 9A: automatic, risk-based, nothing to opt into
Where the common portal identifies an application as low risk on its own data analysis and risk parameters, registration is granted electronically within three working days. There is no turnover test, no tax-liability ceiling and no election. You cannot apply for it; the system either flags you or it does not.
Rule 14A: optional, capped, and it locks you in
You opt in by selecting Rule 14A in Form GST REG-01. It is open to an applicant whose self-assessed monthly output tax on supplies to registered persons does not exceed ₹2.5 lakh, counting central, state, integrated tax and cess together. Business-to-consumer liability is excluded from the test. Aadhaar authentication is mandatory: decline it and you are not eligible at all.
Rule 14A carries two consequences that are easy to miss at the point of application. First, a person registered under Rule 14A cannot take a second Rule 14A registration in the same state on the same PAN, which makes it incompatible with a multiple-place-of-business structure inside one state. Second, withdrawal is not immediate: you apply in Form GST REG-32 and receive an order in REG-33, and you must first have filed returns for a minimum of one tax period where the application is made on or after 1 April 2026, or three months where it was made before that date. All pending returns must be filed and no cancellation proceedings may be pending.
The ordinary route under Rule 9 remains what it was: approval within seven working days, extended to thirty days where the applicant has not completed Aadhaar authentication or where the officer decides physical verification of the place of business is warranted. Deemed approval applies if the officer does not act in time.
Since 11 February 2025, declining Aadhaar authentication does more than slow the clock. It routes the applicant to a GST Suvidha Kendra for photo capture and original-document verification, and the application reference number is not generated at all unless that is completed within fifteen days of submitting Part B.
One registration per state, and the option of more than one within a state
Registration is state-specific. A single legal entity takes one GSTIN per state or union territory from which it makes taxable supplies, and must register in every such state. Supplies between two registrations of the same entity are supplies between distinct persons and are taxable.
Section 25(2) allows a person with multiple places of business within one state to take a separate registration for each. The old test of distinct business verticals was replaced by the simpler place-of-business test with effect from 1 February 2019. This is worth considering where two operations inside one state have genuinely different compliance profiles, and worth avoiding where they do not, because each additional registration is a full additional return cycle.
Note the interaction with the new fast route above: the Rule 14A restriction of one such registration per state per PAN means the simplified route and a multiple-registration structure inside a single state do not sit together.
Input Service Distributor registration is no longer optional
This is the registration change most likely to be missed by a business that has been registered for years. The Input Service Distributor mechanism, which used to be one of two ways of pushing the credit on common input services out to branches, became mandatory from 1 April 2025, by amendments to Sections 2(61) and 20 made by the Finance (No. 2) Act 2024 and brought into force by Notification 16/2024-Central Tax.
What that means in practice: where a head office procures a common input service from a third party for the benefit of branches registered in other states, the credit must now be distributed through a separate ISD registration. It cannot be handled informally, and it cannot be handled by cross-charge. The amended definition also brings input services on which tax is payable under domestic reverse charge into the ISD net.
ISD and cross-charge are not alternatives. ISD covers common input services bought in from third parties. Cross-charge covers services generated internally by one registration for another, such as an in-house legal, treasury or human resources function serving branches. Cross-charge is still required for those, and ISD cannot be used for them. ISD also cannot distribute credit on goods or capital goods. A business that has replaced one with the other has a gap on the side it dropped.
An ISD registration files Form GSTR-6 monthly, by the 13th. It does not file GSTR-1 or GSTR-3B.
A further extension of the ISD mechanism, to services on which integrated tax is payable under reverse charge under Sections 5(3) and 5(4) of the IGST Act, was made by the Finance Act 2025. Treat 17 September 2025 as the operative date for that element. The core mandate for domestic common input services runs from 1 April 2025, but the machinery for distributing inter-state reverse-charge credit only arrived when Rule 39(1A) was amended by Notification 13/2025-Central Tax on 17 September 2025.
Amendments: fifteen days, and the split that decides whether anyone reviews it
Any change in the particulars furnished at registration is applied for in Form GST REG-14 under Rule 19, within fifteen days of the change. What happens next depends entirely on which field changed.
| Field type | Examples | Process |
|---|---|---|
| Core | Legal name of the business where the PAN is unchanged; addition or removal of promoters, partners, directors or karta; change of principal place of business or an additional place of business within the same state | Requires the proper officer’s approval. The officer may issue a notice in REG-03 within fifteen working days; you reply in REG-04 within seven working days. Deemed approved if the officer does not act in time |
| Non-core | Authorised signatory, e-mail address, mobile number, bank account details, nature of goods or services supplied | Auto-approved on filing. No officer involvement |
A change of state is not an amendment. Because registration is state-specific, moving the principal place of business to another state means cancelling one registration and applying for another, not editing the existing one.
The practical failure here is almost never the form. It is that a director resigned, or a bank account was closed, eighteen months ago and nobody connected that to a GST filing obligation. An annual walk through the registration certificate against the current facts costs an hour and closes most of this exposure.
Cancellation, suspension and the revocation clock
A registration can be cancelled voluntarily, by application in Form GST REG-16, or by the department, most commonly for a continued failure to file returns. While cancellation proceedings are pending the registration can be suspended under Rule 21A, which stops you issuing tax invoices in the meantime.
Revocation of a departmental cancellation is applied for in Form GST REG-21 under Rule 23, within ninety days of service of the cancellation order. That period can be extended by the Commissioner, or an officer not below Additional or Joint Commissioner, on sufficient cause recorded in writing, by up to a further 180 days. Two conditions decide whether the application goes anywhere:
- Where cancellation was for failure to furnish returns, no revocation application can even be filed until all pending returns are furnished and all tax, interest, penalty and late fee are paid.
- Returns for the period from the date of the cancellation order to the date of the revocation order must then be furnished within thirty days of the revocation order.
If the registration is genuinely being closed, a final return in Form GSTR-10 is due within three months of the date of cancellation or the date of the cancellation order, whichever is later. It is missed constantly, because by then nobody is looking at the portal.
There is now a hard edge behind all of this. Since 1 December 2025 the portal permanently bars any GST return more than three years past its due date. A cancellation from several years ago whose pending returns have gone past that mark cannot simply be regularised by filing them. See Guide 2 for the unbarring route and what it requires.
The composition scheme, and why most growing businesses leave it
The composition scheme under Section 10 is open to a supplier of goods, a manufacturer or a restaurant with aggregate turnover in the preceding financial year up to ₹1.5 crore, reduced to ₹75 lakh in Arunachal Pradesh, Manipur, Meghalaya, Mizoram, Nagaland, Sikkim, Tripura and Uttarakhand. A separate option under Section 10(2A) is open to service providers with preceding-year turnover up to ₹50 lakh, at 6%.
Rates are 1% for manufacturers and traders, 5% for restaurants not serving alcohol, and 6% for the service option. The restrictions are what matter: no input tax credit, a bill of supply rather than a tax invoice, and no inter-state outward supply of goods. That last one is usually what ends it. A composition dealer who takes a single order from another state has to come out of the scheme.
Opt in by 31 March preceding the financial year in Form CMP-02. Pay quarterly in CMP-08 by the 18th of the month following the quarter, and file the annual return GSTR-4 by 30 June following the financial year. That last date moved from 30 April with effect from financial year 2024-25, and a good deal of published material still shows the old date.
Note also that Himachal Pradesh and Assam sit at ₹1.5 crore, not ₹75 lakh, despite being grouped with the lower-limit states in a lot of secondary writing.
What an engagement on this looks like
Registration footprint review
Which states you are registered in, which you should be, and which registrations are carrying obligations without carrying activity. Includes the ISD question, which is where we most often find a gap.
New state or new registration
Filing the application, choosing between the ordinary and simplified routes with the lock-in understood, handling Aadhaar or biometric verification, and responding to a REG-03 notice.
Cancellation and revocation
Recovering a registration cancelled for non-filing, including working out what can still be filed under the three-year bar and whether an unbarring application is needed first.
Send an enquiry
Tell us whether this is a new registration, a state you are about to enter, an amendment you think is overdue, or a cancellation you are trying to reverse. A partner replies within one business day.
This page is general information, not professional advice. Indian GST law changed substantially between 2024 and 2026, several changes are enacted but not yet notified into force, and how any of this applies depends on your own facts, your state and your sector. Take professional advice before acting on anything on this page. We are happy to be that adviser, but we do not act on a web page, ours or anyone else's, without one.