Section 24 of the Central Goods and Services Tax Act, 2017 deals with compulsory GST registration in certain cases. It identifies specific categories of persons who are required to obtain GST registration even when they may not otherwise become liable under the normal turnover-based provisions of Section 22.
This makes Section 24 an important part of the GST registration framework. Section 22 generally deals with registration based on the applicable turnover threshold, while Section 23 provides exclusions for specified persons. Section 24, on the other hand, lists situations where registration becomes compulsory because of the nature of the person’s activities.
The opening words of Section 24 are important: the specified categories are required to be registered “notwithstanding anything contained in sub-section (1) of section 22.” In other words, the normal threshold under Section 22 does not by itself prevent compulsory registration where Section 24 applies.
However, Section 24 should not be read in isolation. Several categories have subsequently received specific exemptions or special procedures through Government notifications. For example, specified suppliers making intra-State supplies of goods through electronic commerce operators can avail a waiver from mandatory registration subject to prescribed conditions.
What is Section 24 of the CGST Act?
Section 24 is titled “Compulsory registration in certain cases.”
The provision covers specified categories of persons who are required to obtain GST registration under the Act.
The current statutory categories include:
- Persons making any inter-State taxable supply.
- Casual taxable persons making taxable supplies.
- Persons required to pay tax under reverse charge.
- Persons required to pay tax under Section 9(5).
- Non-resident taxable persons making taxable supplies.
- Persons required to deduct tax under Section 51.
- Persons making taxable supplies on behalf of other taxable persons, whether as an agent or otherwise.
- Input Service Distributors.
- Specified persons supplying goods or services through an electronic commerce operator required to collect tax at source under Section 52.
- Electronic commerce operators required to collect tax at source under Section 52.
- Persons supplying online information and database access or retrieval services from outside India to a person in India, other than a registered person.
- Persons supplying online money gaming from outside India to a person in India.
- Such other persons or classes of persons as may be notified by the Government on the recommendations of the GST Council.
The important point is that these categories are based on the nature of the person’s activity or legal responsibility, rather than simply on turnover.
Section 24 and Section 22 – What is the Difference?
Section 22 and Section 24 are closely connected but serve different purposes.
Section 22 – Normal Registration Liability
Section 22 generally determines when a supplier becomes liable for GST registration based on the applicable conditions and aggregate turnover.
Section 24 – Compulsory Registration
Section 24 identifies particular categories where registration is compulsory because of the nature of the transaction, business model or statutory responsibility.
For example, a person making a taxable inter-State supply falls within Section 24(i), subject to applicable provisions and exemptions. The person cannot simply rely on the normal Section 22 turnover threshold without checking Section 24.
Therefore, GST registration analysis should not be based only on annual turnover.
Section 24( i ) – Persons Making Inter-State Taxable Supply
Section 24(i) covers persons making any inter-State taxable supply.
An inter-State taxable supply generally involves a taxable supply where the place of supply and location of the supplier are in different States or Union territories, or otherwise falls within the inter-State supply provisions of the IGST Act.
For example, suppose a business located in Delhi makes a taxable supply to a customer in Haryana and the transaction qualifies as an inter-State supply.
The supplier needs to examine Section 24(i) and the applicable registration exemptions rather than relying only on the normal turnover threshold.
Important Point About Inter-State Supplies
The provision refers specifically to inter-State taxable supply.
Therefore, it is important to establish whether the transaction is actually an inter-State taxable supply under the IGST Act.
A transaction should not be treated as falling under Section 24(i) merely because the customer and supplier are in different locations. The applicable place-of-supply rules and taxability must be examined.
Section 24(ii) – Casual Taxable Persons
Section 24(ii) covers casual taxable persons making taxable supplies.
A casual taxable person is generally a person who occasionally undertakes transactions involving taxable supplies in a State or Union territory where the person does not have a fixed place of business.
This provision is particularly relevant for businesses participating in:
- Trade fairs
- Exhibitions
- Temporary commercial events
- Occasional sales activities
- Other temporary business activities in another State or Union territory
A person who regularly carries on business from a fixed place in the State may not fall within the definition of a casual taxable person merely because the business is temporary in some other sense.
The actual facts and statutory definition have to be considered.
Example of a Casual Taxable Person
A manufacturer based in Maharashtra participates in a trade exhibition in Delhi and makes taxable supplies from that activity.
If the person does not have a fixed place of business in Delhi and the circumstances satisfy the definition of a casual taxable person, the registration provisions applicable to casual taxable persons need to be considered.
Section 24(iii) – Persons Required to Pay Tax Under Reverse Charge
Section 24(iii) covers persons who are required to pay tax under reverse charge.
Under reverse charge, the liability to pay GST can shift from the supplier to the recipient for specified supplies.
Therefore, a person who is required to discharge GST under a reverse-charge provision needs to examine compulsory registration requirements under Section 24(iii), subject to specific exemptions or notifications that may apply.
The GST Council has specifically discussed the interaction between reverse-charge registration and the registration exemption framework.
Why Reverse Charge Matters
Under the normal forward-charge mechanism, the supplier generally collects and pays GST.
Under reverse charge, the recipient may become responsible for paying the tax.
Because this changes the person responsible for tax payment, Section 24 specifically addresses persons required to pay tax under reverse charge.
Section 24(iv) – Persons Required to Pay Tax Under Section 9(5)
Section 24(iv) covers a person required to pay tax under Section 9(5) of the CGST Act.
Section 9(5) deals with specified categories of services supplied through an electronic commerce operator where the Government may notify the electronic commerce operator as the person liable to pay tax as if the operator were the supplier.
Therefore, a person determining registration liability should check whether the transaction falls within the notified framework under Section 9(5).
This category is different from Section 24(ix), which concerns suppliers making supplies through an electronic commerce operator required to collect tax at source under Section 52.
Section 24(v) – Non-Resident Taxable Persons
Section 24(v) covers non-resident taxable persons making taxable supplies.
A non-resident taxable person is a person who occasionally undertakes transactions involving taxable supplies of goods or services or both, whether as principal, agent or in another capacity, but who has no fixed place of business or residence in India.
Such persons are subject to special GST registration provisions.
Example
Suppose a foreign business without a fixed place of business in India comes to India to participate in a commercial event and makes taxable supplies.
The business may fall within the provisions applicable to a non-resident taxable person.
The person should examine the special registration requirements before commencing taxable activities in India.
Section 24(vi) – Persons Required to Deduct Tax Under Section 51
Section 24(vi) covers persons who are required to deduct tax under Section 51, whether or not they are separately registered under the Act.
Section 51 deals with tax deduction at source under GST.
Therefore, a person who falls within the statutory framework requiring GST TDS must examine registration under Section 24(vi).
The purpose of this provision is to ensure that persons having a statutory obligation to deduct GST at source are brought within the GST registration framework applicable to TDS deductors.
The CGST registration rules separately provide for registration of persons required to deduct tax under Section 51 and collect tax under Section 52.
Section 24(vii) – Persons Making Taxable Supplies on Behalf of Others
Section 24(vii) covers persons who make taxable supplies of goods or services or both on behalf of other taxable persons, whether as an agent or otherwise.
This provision is important in agency and representative business arrangements.
For example, a person may sell goods on behalf of another taxable person under an agency arrangement.
The fact that the goods may ultimately belong to another person does not automatically remove the intermediary or agent from the registration framework.
The exact contractual arrangement and whether the activities fall within the statutory provisions should be examined.
Example
Suppose Company A appoints an agent to make taxable supplies on its behalf.
If the agent falls within Section 24(vii), the agent may be required to obtain GST registration even if the agent’s own turnover would otherwise appear to be below the normal threshold.
Section 24(viii) – Input Service Distributor
Section 24(viii) covers an Input Service Distributor (ISD).
The current ISD framework is particularly important because Section 20 requires the relevant office receiving invoices for input services for or on behalf of distinct persons to function within the ISD mechanism where the statutory conditions apply.
The GST Council’s recommendations relating to the amended ISD framework specifically refer to registration of an office as an Input Service Distributor under Section 24(viii).
An ISD is therefore not treated like an ordinary supplier deciding registration solely by looking at its turnover.
Why ISD Registration Matters
An ISD receives invoices relating to input services and distributes eligible input tax credit to the appropriate distinct persons in accordance with the statutory mechanism.
Because the purpose of an ISD is credit distribution rather than ordinary outward supply, Section 24 separately addresses its registration requirement.
Section 24(ix) – Suppliers Through Electronic Commerce Operators
Section 24(ix) covers persons who supply goods or services or both through an electronic commerce operator required to collect tax at source under Section 52, subject to the statutory wording and specified exclusions for supplies covered by Section 9(5).
Historically, this provision created a broad compulsory registration requirement for suppliers selling through certain electronic commerce operators.
However, this area has been modified through subsequent Government notifications.
Important Exemption for Certain Suppliers of Goods
The GST Council recommended a waiver from mandatory registration under Section 24(ix) for certain persons making intra-State supplies of goods through electronic commerce operators up to the applicable threshold, subject to conditions.
Notification No. 34/2023-Central Tax dated 31 July 2023 was issued to waive the mandatory registration requirement for specified persons supplying goods through ECOs, subject to conditions.
The GST Council later noted that Notification No. 34/2023, along with related notifications, established a special procedure and conditions for unregistered persons supplying goods through electronic commerce operators.
Therefore, it is no longer accurate to simply state that every person selling goods through an e-commerce platform must obtain GST registration regardless of turnover.
The current position must be examined along with the applicable notification and conditions.
Conditions Matter
A supplier seeking the benefit of the waiver for specified intra-State supplies of goods through an ECO must satisfy the conditions prescribed under the relevant notification and special procedure.
GSTN has also provided a facility for enrolment of eligible unregistered suppliers of goods supplying through e-commerce operators.
Therefore, an online seller should check the applicable conditions before deciding that GST registration is unnecessary.
Suppliers of Services Through E-Commerce Platforms
The registration position for suppliers of services through e-commerce platforms also requires attention to the applicable notifications.
Notification No. 65/2017-Central Tax provides an exemption from compulsory registration for specified suppliers of services through an electronic commerce platform, subject to the conditions specified in the notification.
The exemption does not apply universally to every type of service. In particular, the notification framework excludes suppliers of services covered by Section 9(5).
Therefore, an online service provider should check:
- The type of service supplied.
- Whether the service is covered by Section 9(5).
- The applicable turnover threshold.
- Whether the supplier satisfies the conditions of the relevant notification.
Section 24(x) – Electronic Commerce Operators
Section 24(x) covers electronic commerce operators who are required to collect tax at source under Section 52.
An electronic commerce operator is generally a person who owns, operates or manages a digital or electronic facility or platform for electronic commerce.
Section 24(x) is therefore relevant to the platform itself, while Section 24(ix) deals with specified suppliers using such platforms.
This distinction is important.
Supplier vs E-Commerce Operator
Consider an online marketplace.
There may be two different parties:
E-commerce operator: The platform that facilitates electronic commerce.
Supplier: The person selling goods or services through that platform.
Section 24 contains separate provisions for these two roles.
The registration requirements should therefore not be confused.
Section 24(xi) – OIDAR Services From Outside India
Section 24(xi) covers every person supplying online information and database access or retrieval services (OIDAR) from a place outside India to a person in India, other than a registered person, subject to the statutory provision.
OIDAR services are technology-based services delivered through information technology over the internet or an electronic network where the nature of the service makes it essentially automated and dependent on information technology.
Examples can include certain:
- Online digital content
- Online database services
- Digital data storage
- Online advertising services
- Downloadable digital products
- Other qualifying electronically supplied services
The exact classification must be determined under the applicable definition in the IGST Act.
Why Registered Recipients Are Mentioned
Section 24(xi) specifically refers to supplies from outside India to a person in India other than a registered person.
This distinction is important because the GST law contains specific mechanisms for determining who is liable to pay tax in different OIDAR transactions.
Therefore, a foreign OIDAR supplier should determine the GST status of the recipient and the applicable tax mechanism before deciding its registration requirements.
Section 24(xia) – Online Money Gaming From Outside India
Section 24(xia) was introduced to address persons supplying online money gaming from a place outside India to a person in India.
This provision was introduced as part of the legislative changes relating to online gaming and came into effect from 1 October 2023.
The provision specifically covers a supplier located outside India making online money gaming supplies to persons in India.
This is separate from the OIDAR registration provision.
Why Online Money Gaming Has a Separate Provision
The CGST Act was amended in 2023 to introduce specific definitions and tax provisions concerning online gaming and online money gaming.
Consequently, Section 24(xia) specifically requires registration for a person supplying online money gaming from outside India to a person in India.
The GST Council’s 52nd meeting documents also discussed the special registration procedure and FORM GST REG-10 for persons supplying online money gaming from outside India to persons in India.
Section 24(xii) – Other Persons Notified by the Government
Section 24(xii) provides flexibility to the Government.
It covers:
“such other person or class of persons as may be notified by the Government on the recommendations of the Council.”
This means that the Government can notify additional categories of persons for compulsory registration based on GST Council recommendations.
Therefore, the list in Section 24 should always be read along with subsequent notifications and amendments.
Is GST Registration Under Section 24 Required Regardless of Turnover?
In general, Section 24 is designed to make registration compulsory for specified categories notwithstanding the normal turnover-based registration provision in Section 22.
However, this does not mean that every clause operates without any exemption or modification.
The Government has issued notifications that modify or waive compulsory registration requirements for specified categories under prescribed conditions.
The clearest example is the waiver for certain unregistered persons supplying goods through electronic commerce operators.
Therefore, the correct approach is:
First identify the Section 24 category → then check the relevant exemption notification or special procedure → then determine whether registration is actually required.
Section 24 and Section 23 – Important Relationship
Section 23 deals with persons not liable for registration, while Section 24 deals with compulsory registration.
This relationship has been important in the development of GST law because specific exemptions have sometimes been issued under Section 23(2) to address categories that would otherwise fall under Section 24.
For example, the GST Council discussed the interaction between Section 23 and Section 24 while recommending the waiver for certain suppliers making intra-State supplies of goods through electronic commerce operators.
Therefore, a person should not simply read Section 24 and conclude that registration is compulsory without checking whether a specific exemption notification applies.
Section 24 and Section 25 – Registration Procedure
Section 24 determines who may be required to register in specified circumstances.
Section 25 deals with the procedure for registration.
The CGST registration rules provide the application mechanism and relevant forms for different categories of applicants.
For example, the registration rules provide specific procedures for persons required to deduct tax under Section 51 and collect tax under Section 52.
Special procedures also exist for non-resident taxable persons and certain suppliers located outside India.
Therefore, after establishing liability under Section 24, the person should follow the applicable registration procedure rather than treating Section 24 as the registration application provision itself.
Practical Examples of Section 24
Example 1 – Inter-State Taxable Supply
A taxable supplier in Delhi makes an inter-State taxable supply to a customer in another State.
The supplier should examine Section 24(i) and the applicable registration provisions rather than relying only on the normal turnover threshold.
Example 2 – Reverse Charge
A person becomes liable to pay GST under an applicable reverse-charge provision.
The person should examine Section 24(iii), along with any applicable exemption or notification.
Example 3 – Non-Resident Taxable Person
A foreign business without a fixed place of business in India occasionally makes taxable supplies in India.
The provisions applicable to a non-resident taxable person become relevant, including compulsory registration under Section 24(v).
Example 4 – GST TDS Deductor
A person is required to deduct tax under Section 51.
Section 24(vi) specifically covers persons required to deduct tax under Section 51.
Example 5 – Agent
An agent makes taxable supplies on behalf of another taxable person.
The agent needs to examine Section 24(vii) and determine whether the arrangement falls within the compulsory registration provision.
Example 6 – Input Service Distributor
A qualifying office functions as an Input Service Distributor and receives input-service invoices for distribution of input tax credit.
Section 24(viii) makes registration as an ISD relevant to the arrangement.
Example 7 – Online Seller
A person sells goods through an electronic commerce operator.
The supplier should examine Section 24(ix), but must also check the specific waiver and special procedure applicable to certain unregistered suppliers of goods through ECOs.
Example 8 – Foreign Online Gaming Supplier
A supplier located outside India provides online money gaming to a person in India.
Section 24(xia) specifically addresses this category.
Common Mistakes Regarding Section 24
Mistake 1 – Looking Only at Turnover
One of the most common mistakes is assuming that GST registration depends only on annual turnover.
Section 24 specifically identifies categories where compulsory registration can arise independently of the normal Section 22 threshold.
Mistake 2 – Assuming Every Inter-State Transaction Requires Registration Without Checking the Nature of Supply
Section 24(i) refers to inter-State taxable supply.
The transaction must therefore actually qualify as a taxable inter-State supply.
Mistake 3 – Ignoring Notifications
Section 24 must be read with relevant Government notifications.
The e-commerce supplier exemption is an important example of why simply reading the statutory text may not provide the complete practical position.
Mistake 4 – Confusing an E-Commerce Operator With a Supplier
Section 24(ix) and Section 24(x) address different persons.
The supplier using an ECO and the ECO itself can have separate registration obligations.
Mistake 5 – Treating All Online Sellers the Same
The registration position can depend on whether the person supplies goods or services, whether the supplies are intra-State or inter-State, whether the ECO is required to collect TCS, and whether a specific exemption applies.
Mistake 6 – Ignoring Special Rules for Foreign Digital Suppliers
OIDAR and online money gaming supplied from outside India have specific provisions.
A foreign supplier should examine the relevant provisions rather than applying ordinary domestic registration rules.
Key Documents and Information to Examine Before Registration
A person determining whether Section 24 applies should generally examine:
- Nature of goods or services supplied
- Location of supplier
- Location of recipient
- Whether the supply is taxable
- Whether the supply is intra-State or inter-State
- Annual aggregate turnover
- Whether reverse charge applies
- Whether the person is an agent
- Whether the person operates through an electronic commerce operator
- Whether the person is an electronic commerce operator
- Whether TDS or TCS obligations apply
- Whether the person qualifies as an Input Service Distributor
- Whether the supplier is resident or non-resident
- Whether OIDAR or online money gaming provisions apply
- Relevant exemption notifications and special procedures
This approach helps prevent registration decisions based on only one factor.
Section 24 – Quick Comparison of Compulsory Registration Categories
| Section 24 Clause | Category |
|---|---|
| 24(i) | Persons making inter-State taxable supplies |
| 24(ii) | Casual taxable persons making taxable supplies |
| 24(iii) | Persons required to pay tax under reverse charge |
| 24(iv) | Persons required to pay tax under Section 9(5) |
| 24(v) | Non-resident taxable persons making taxable supplies |
| 24(vi) | Persons required to deduct tax under Section 51 |
| 24(vii) | Persons making taxable supplies on behalf of other taxable persons |
| 24(viii) | Input Service Distributors |
| 24(ix) | Specified suppliers through electronic commerce operators required to collect TCS |
| 24(x) | Electronic commerce operators required to collect TCS |
| 24(xi) | Specified OIDAR suppliers from outside India to persons in India |
| 24(xia) | Persons supplying online money gaming from outside India to persons in India |
| 24(xii) | Other persons or classes notified by the Government |
The statutory categories are reflected in the current text of Section 24.
Section 24 – Key Takeaways
The most important points to remember are:
- Section 24 deals with compulsory GST registration in specified cases.
- It operates notwithstanding the normal turnover-based provision in Section 22(1).
- Inter-State taxable suppliers are covered under Section 24(i), subject to applicable provisions and exemptions.
- Casual taxable persons making taxable supplies are covered under Section 24(ii).
- Persons required to pay GST under reverse charge are covered under Section 24(iii), subject to applicable exemptions.
- Persons liable under Section 9(5) are covered under Section 24(iv).
- Non-resident taxable persons making taxable supplies are covered under Section 24(v).
- GST TDS deductors covered by Section 51 fall under Section 24(vi).
- Persons making taxable supplies on behalf of other taxable persons are covered under Section 24(vii).
- Input Service Distributors are covered under Section 24(viii).
- Section 24(ix) deals with specified suppliers using electronic commerce operators required to collect TCS.
- Section 24(x) deals with electronic commerce operators required to collect TCS.
- Section 24(xi) deals with specified OIDAR suppliers located outside India.
- Section 24(xia) specifically covers online money gaming supplied from outside India to persons in India.
- Section 24(xii) allows the Government to notify additional categories.
- Specific exemptions and special procedures can modify the practical registration requirement for particular categories.
- The waiver for certain unregistered suppliers of goods through ECOs is an important example of why Section 24 should always be read with the latest applicable notifications.
Conclusion
Section 24 of the CGST Act, 2017 is one of the most important provisions dealing with GST registration because it identifies categories of persons who may be required to register even when the normal turnover-based test under Section 22 would not otherwise result in registration.
The section covers a wide range of situations, including inter-State taxable supplies, casual taxable persons, reverse-charge taxpayers, non-resident taxable persons, TDS deductors, agents, Input Service Distributors, specified e-commerce suppliers, e-commerce operators, foreign OIDAR suppliers and foreign online money gaming suppliers.
At the same time, the practical application of Section 24 cannot be determined by reading the section alone. Government notifications and special procedures have modified the registration requirements for particular categories. The exemption for certain unregistered suppliers of goods through electronic commerce operators is one significant example.
Therefore, before deciding whether GST registration is compulsory, a taxpayer should identify the applicable Section 24 category, examine the nature of the supply, and check the latest notifications, exemptions and conditions applicable to that category.
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