Procedure for Registration

1. What Section 25 does

Section 25 does not determine the underlying taxability of a business. It governs how registration is obtained, where it is obtained, when the application must be made and how the resulting registration is treated.

The starting point is Sections 22 and 24. Once a person becomes liable to register, Section 25(1) requires an application in every State or Union Territory in which the liability arises, normally within thirty days. Section 25 also covers voluntary registration, multiple registrations, distinct-person treatment, PAN and identity requirements, special entities and the consequences of failure to register.

India Code's current text records Section 25 as in force and states that Sections 22–25 commenced on 22 June 2017. citeturn0search0

2. Complete statutory structure

The current text contains these provisions, including the separate SEZ registration proviso and deemed-grant mechanism. citeturn0search0

3. The 30-day registration rule

Every person liable to registration under Section 22 or Section 24 must apply in each State or Union Territory in which the person is liable within thirty days from the date on which the person becomes liable.

This is not necessarily thirty days from the date on which the business was incorporated or started. The trigger is the date on which the statutory registration liability arises.

India Code expressly states the 30-day rule. citeturn0search0

4. Casual taxable person and non-resident taxable person

Section 25(1) creates a special timing rule for casual taxable persons and non-resident taxable persons: the application must be made at least five days before commencement of business.

This differs from the ordinary thirty-day rule. It is designed to ensure that special-category taxpayers are registered before commencing taxable operations.

The Telangana GST registration handbook also confirms the five-day rule for CTP/NRTP applications. citeturn0search18

5. Separate registration for SEZ unit / SEZ developer

A person having a unit in a Special Economic Zone or being an SEZ developer must apply for a separate registration, distinct from a place of business located outside the SEZ in the same State or Union Territory.

This is important for businesses operating both normal domestic units and SEZ units in the same State. The existence of one GSTIN for the State does not eliminate the separate-registration requirement for the SEZ unit/developer.

The registration handbook published by the Telangana Commercial Taxes Department explains the separate SEZ registration requirement. citeturn0search18

6. Supplies from territorial waters

Section 25 contains a specific explanation for supplies made from the territorial waters of India. The person must obtain registration in the coastal State or Union Territory where the nearest point of the appropriate baseline is located.

This avoids uncertainty over the territorial registration location where the place from which the supply is made is physically in territorial waters rather than on ordinary land territory.

7. One registration in a State or Union Territory

Section 25(2) establishes the basic principle that a person seeking registration receives a single registration in a State or Union Territory.

However, the proviso allows separate registration for each place of business in the same State/UT, subject to the prescribed conditions. Therefore, “one State = always one GSTIN” is an incomplete statement.

The detailed conditions for separate registrations are contained in the registration rules and must be checked before creating additional GSTINs.

8. Multiple places of business

Businesses may have factories, branches, warehouses, project offices or other places of business within the same State. Section 25(2) permits separate registrations subject to prescribed conditions.

CBIC's registration rules provide the conditions for separate registrations for multiple business locations. citeturn0search1

9. Voluntary registration under Section 25(3)

A person who is not liable to register under Section 22 or Section 24 may voluntarily register.

The consequence is important: once voluntarily registered, the provisions of the CGST Act applicable to a registered person apply to that person.

Voluntary registration is therefore a business decision with compliance consequences, not merely an identity certificate.

10. Distinct persons — Sections 25(4) and 25(5)

Where a person has more than one GST registration, each registration is treated as a distinct person for GST purposes.

Similarly, establishments of the same person in different States or Union Territories are treated as establishments of distinct persons.

11. PAN requirement

Section 25(6) generally requires a person to have a Permanent Account Number issued under the Income-tax Act to be eligible for grant of GST registration.

There is a specific proviso for persons required to deduct tax under Section 51: a Tax Deduction and Collection Account Number may be used in lieu of PAN in the specified manner.

This reinforces the PAN-linked architecture of GST registration while recognising special registration categories.

12. Aadhaar and identity authentication

Section 25 contains provisions dealing with Aadhaar-number-related authentication and verification, together with Government notification powers for exceptions. The operational requirements are implemented through the registration rules and portal process.

The correct professional approach is to distinguish the statutory identity requirement from the portal authentication procedure. The latter can be updated through rules, notifications and portal functionality without changing the basic registration architecture.

13. Non-resident taxable person — alternative documents

Section 25(7) provides that a non-resident taxable person may be granted registration on the basis of such other documents as may be prescribed, notwithstanding the general PAN provision.

The registration rules separately prescribe the application process for non-resident taxable persons, including passport/identification documentation and the special advance-tax mechanism.

The rules provide for FORM GST REG-09 and an application at least five days before commencement. citeturn0search22

14. Failure to register — officer-initiated registration

Section 25(8) protects the administration's ability to register a person who is liable but has failed to obtain registration.

The proper officer may proceed to register the person in the prescribed manner. This is without prejudice to other action available under the GST law or another applicable law.

15. Unique Identity Number under Section 25(9)

Section 25(9) provides a separate identification mechanism for specified entities such as specialised agencies of the United Nations, notified multilateral financial institutions and organisations, foreign consulates/embassies and other notified persons/classes.

These entities are granted a Unique Identity Number (UIN) for specified purposes, including refund of taxes on notified supplies received by them.

This is different from an ordinary GSTIN. A UIN is a special identification mechanism rather than ordinary taxable-person registration.

The registration rules provide a separate UIN application mechanism, including FORM GST REG-12 and issuance of FORM GST REG-06. citeturn0search1

16. Verification, grant and deemed registration

Section 25(10) requires registration or UIN to be granted or rejected after due verification within the prescribed period.

Section 25(12) provides a deemed-grant mechanism where the prescribed period expires without a deficiency being communicated, subject to the statutory conditions.

The detailed time limits and officer actions are prescribed in the registration rules.

17. Certificate and effective date

Section 25(11) provides for issuance of the registration certificate in the prescribed form and from the prescribed date.

The registration rules distinguish applications filed within the 30-day period from applications filed after that period. CBIC's published registration rules state that where the application is submitted within thirty days from liability, registration is effective from the date the person became liable; where filed later, the effective date is generally linked to the date of grant, subject to the applicable rule. citeturn0search1

18. Section 25 and the Registration Rules

Section 25 gives the statutory framework; the CGST Rules supply the operating machinery.

CBIC's published registration rules contain the application and verification architecture, including Rule 8 and the special procedures for TDS/TCS and non-resident taxpayers. citeturn0search1turn0search21

19. Legislative development

India Code records 22 June 2017 as the commencement date for Section 25. citeturn0search0

20. Detailed practical examples

Example 1 — turnover threshold crossed

A business becomes liable under Section 22 on 10 September. The ordinary application deadline is within thirty days from that liability date.

Example 2 — Section 24 liability

A business becomes subject to a compulsory-registration category under Section 24 even though turnover is below the normal threshold. Section 25(1) still requires registration within the prescribed period.

Example 3 — voluntary registration

A small supplier is not liable under Sections 22/24 but voluntarily registers under Section 25(3). GST obligations applicable to registered persons then apply.

Example 4 — two States

A company has taxable business in Telangana and Karnataka. Where registration liability exists in both States, separate GST registrations are required.

Example 5 — multiple places in one State

A company has a head office, factory and warehouse in the same State. It may use one registration or seek separate registrations if the Rule 11 conditions are satisfied.

Example 6 — SEZ

A company has a normal unit and an SEZ unit in the same State. The SEZ unit requires separate registration under Section 25.

Example 7 — CTP

A business participates in a taxable exhibition in another State as a casual taxable person. Application must be made at least five days before commencement of business.

Example 8 — NRTP

A foreign business makes taxable supplies in India without a fixed place of business. It follows the NRTP registration process and special document requirements.

Example 9 — distinct persons

A Telangana GSTIN supplies services to its Karnataka GSTIN of the same legal entity. The two registrations are distinct persons for GST purposes and the transaction must be evaluated under the supply/valuation rules.

Example 10 — officer registration

A person liable to register repeatedly fails to apply. The proper officer may proceed to register the person under Section 25(8), without eliminating other statutory consequences.

21. Professional registration workflow

22. Internal controls for finance teams

23. Documentation checklist

• PAN / TAN where applicable.
• Constitution documents and authorised-signatory records.
• Proof of principal and additional places of business.
• Section 22/24 liability calculation.
• Section 23 exemption analysis where relevant.
• SEZ approval/registration documents where applicable.
• CTP/NRTP documents and advance-tax records.
• REG-01 / REG-09 / REG-12 or other applicable forms.
• ARN and acknowledgement.
• Clarification notices and replies.
• GST registration certificate and effective date.
• Records supporting voluntary-registration decision.
• Inter-GSTIN agreements/invoices for distinct-person transactions.

24. Common mistakes

• Counting thirty days from incorporation instead of the actual GST liability date.
• Ignoring the special five-day advance rule for CTP/NRTP.
• Using one GSTIN for a separate SEZ unit when separate registration is required.
• Assuming multiple places in one State automatically require separate GSTINs.
• Forgetting that voluntarily registered persons become subject to registered-person provisions.
• Treating two State registrations under one PAN as the same taxable person for every GST purpose.
• Ignoring distinct-person implications for inter-State internal supplies.
• Using PAN requirements without considering the special TDS/NRTP provisions.
• Failing to preserve ARN and officer correspondence.
• Assuming late filing has no effect on the registration effective date.
• Ignoring the officer's power to register a defaulting liable person.

25. Related provisions