Section 25 of the Central Goods and Services Tax Act, 2017 lays down the procedure for GST registration. It explains when a person who is liable to registration must apply, the State or Union territory in which registration is required, the basic registration structure, voluntary registration, treatment of multiple registrations, the requirement of PAN, registration of non-resident taxable persons, suo moto registration by the proper officer, Unique Identity Number for specified entities, and the grant or rejection of registration.
Section 25 should be read along with Sections 22, 23 and 24. Section 22 deals with persons liable for registration based primarily on the applicable turnover conditions, Section 23 identifies persons who are not liable for registration in specified circumstances, and Section 24 deals with compulsory registration in specified cases. Once it is established that registration is required, Section 25 provides the legal framework for obtaining that registration.
The practical registration process is further governed by the CGST Rules, 2017, particularly the rules dealing with application, verification, approval, certificates and special categories of applicants. CBIC’s current registration-rules material provides the application and verification framework, including Form GST REG-01, REG-02, REG-03, REG-04, REG-05 and REG-06.
What is Section 25 of the CGST Act?
Section 25 is titled “Procedure for registration.”
The section does not itself contain every procedural detail required to complete a GST registration application. Instead, it establishes the statutory framework and authorises the detailed procedure to be prescribed through the CGST Rules.
The major areas covered by Section 25 include:
- Application for registration within the prescribed time
- Registration in every State or Union territory where liability arises
- Special timing for casual taxable persons and non-resident taxable persons
- Separate registration for Special Economic Zone units and developers
- Registration for supplies from territorial waters
- Single registration in a State or Union territory, subject to separate registration for multiple places of business
- Voluntary registration
- Treatment of separately registered persons as distinct persons
- PAN requirement
- Special documents for non-resident taxable persons
- Registration by the proper officer when a liable person fails to register
- Unique Identity Number for specified entities
- Verification and approval or rejection
- Issue of registration certificate
- Deemed grant of registration where the statutory conditions are satisfied
Section 25(1) – Application for GST Registration
Section 25(1) provides that every person who is liable to registration under Section 22 or Section 24 must apply for registration in every State or Union territory in which the person is liable to registration.
The application must generally be made within 30 days from the date on which the person becomes liable to registration.
This is one of the most important time limits under the GST registration provisions.
Example
Suppose a business becomes liable for GST registration on 10 September.
The person generally has to apply for registration within 30 days from the date on which the liability arises.
The registration process and the effective date of registration are governed by Section 25 and the applicable rules.
A taxpayer should therefore not wait unnecessarily after becoming liable for registration.
Registration is Required in Every Applicable State or Union Territory
Section 25(1) does not provide for one single GST registration that automatically covers every State and Union territory.
Where a person becomes liable for registration in a particular State or Union territory, the person has to apply in that jurisdiction in accordance with the GST law.
For businesses operating in several States, this means that registration requirements have to be examined separately for the relevant States or Union territories.
The registration framework is therefore closely connected with the location of the business and the applicable place-of-business and supply provisions.
Special Rule for Casual Taxable Persons and Non-Resident Taxable Persons
Section 25(1) contains a special requirement for a casual taxable person and a non-resident taxable person.
Such a person must apply for registration at least five days before the commencement of business.
This is different from the ordinary 30-day application period applicable to persons who become liable under the normal registration framework.
Example
A foreign business plans to make taxable supplies in India beginning on 20 October.
As a non-resident taxable person, it should not wait until after starting business and then apply under the ordinary 30-day rule. The special requirement under Section 25 applies.
The registration rules also prescribe special application and advance-tax-deposit procedures for non-resident taxable persons.
Special Economic Zone Registration
Section 25 also contains a specific provision for a person having a unit in a Special Economic Zone (SEZ) or being an SEZ developer.
Such a person is required to apply for a separate registration for the SEZ unit or developer, distinct from the place of business located outside the SEZ in the same State or Union territory.
This is important because an SEZ unit is not simply treated as another ordinary place of business for GST registration purposes.
Example
Suppose a company has:
- A normal manufacturing unit in a State
- A separate SEZ unit in the same State
The SEZ unit has its own registration requirement under the specific provisions of Section 25.
The company therefore needs to consider the separate registration framework rather than assuming that its ordinary State registration covers the SEZ unit.
Supply From Territorial Waters
Section 25 contains an explanation dealing with supplies made from the territorial waters of India.
A person making such a supply is required to obtain registration in the coastal State or Union territory where the nearest point of the appropriate baseline is located.
This provision provides a specific jurisdictional rule for transactions involving territorial waters.
It is particularly relevant to businesses whose operations involve offshore locations, vessels or activities connected with India’s territorial waters.
Section 25(2) – Single Registration in a State or Union Territory
Section 25(2) provides the general principle that a person seeking registration under the CGST Act shall be granted a single registration in a State or Union territory.
However, the law also permits separate registration for each place of business within the same State or Union territory, subject to the prescribed conditions.
This is an important change from the original GST framework, under which the provision referred to separate registrations for business verticals. The current statutory framework focuses on multiple places of business.
The relevant registration rules prescribe the conditions and procedure for obtaining separate registrations for multiple places of business within the same State or Union territory.
Separate Registration for Multiple Places of Business
A business may have more than one place of business within the same State or Union territory.
Subject to the applicable conditions, it may obtain separate GST registrations for such places.
For example, a company may have:
- Head office in Delhi
- Warehouse in another location in Delhi
- Branch or separate place of business elsewhere in Delhi
The business can examine whether the relevant conditions for separate registration are satisfied.
The CGST Rules prescribe the conditions and application procedure for such separate registrations.
Important Point
Separate registration for multiple places of business is not simply an automatic right to create as many GST registrations as a taxpayer wishes.
The conditions prescribed under the CGST Rules must be satisfied.
Therefore, businesses should examine the applicable rules before applying for separate registration for multiple places of business.
Separate GST Registrations and Distinct Persons
Section 25(4) contains an important consequence for persons who have more than one GST registration.
A person who has obtained, or is required to obtain, more than one registration, whether in one State or Union territory or in more than one State or Union territory, is treated as a distinct person in respect of each registration for GST purposes.
This concept has significant implications for transactions between separately registered establishments.
Example
Suppose Company A has:
- GST registration in Delhi
- GST registration in Haryana
Although both registrations belong to the same legal entity, the establishments are treated as distinct persons for the purposes of the CGST Act.
Therefore, transactions between the two registrations may be treated as supplies where the conditions of the GST law are satisfied.
Section 25(5) – Establishments in Different States or Union Territories
Section 25(5) further provides that where a person has an establishment in another State or Union territory, such establishments are treated as establishments of distinct persons for GST purposes.
This provision is important for companies and other organisations operating across multiple States.
For example, a company having its principal establishment in Delhi and another establishment in Haryana cannot simply treat all transactions between the two locations as internal transactions without considering GST implications.
The distinct-person concept must be considered.
Section 25(3) – Voluntary GST Registration
Section 25 also allows a person to obtain GST registration voluntarily, even when the person is not otherwise liable to registration under Section 22 or Section 24.
This is provided under Section 25(3).
Once a person voluntarily obtains registration, the provisions of the CGST Act applicable to a registered person apply to that person.
This means voluntary registration is not merely a certificate without compliance responsibilities.
Example
Suppose a small business is not required to register because it has not crossed the applicable registration threshold and does not fall under a compulsory-registration category.
The business may nevertheless choose to obtain GST registration voluntarily.
Once registration is granted, it must comply with the applicable requirements for registered persons.
These can include:
- Issuing tax invoices where applicable
- Charging and paying GST on taxable supplies
- Filing applicable returns
- Maintaining required records
- Complying with input tax credit conditions
- Following other GST compliance requirements
Why Would a Business Choose Voluntary Registration?
There can be practical business reasons for obtaining GST registration voluntarily.
For example, a business may want to:
- Conduct business as a registered taxable person
- Deal with customers who require GST-compliant documentation
- Participate in transactions where GST registration is commercially important
- Claim eligible input tax credit, subject to the applicable conditions
- Establish a formal GST compliance structure
However, voluntary registration also creates compliance responsibilities.
Therefore, a business should consider the advantages and obligations before applying voluntarily.
Section 25(6) – PAN Requirement
Section 25(6) provides that every person must have a Permanent Account Number (PAN) issued under the Income-tax Act, 1961 in order to be eligible for GST registration.
There is a specific exception for persons required to deduct tax under Section 51.
Such a person may use a Tax Deduction and Collection Account Number (TAN) instead of PAN for the purpose of registration.
PAN and GSTIN
PAN plays an important role in the GST registration system.
For ordinary applicants, the GST registration process begins with the declaration and validation of PAN, along with mobile number, email address and the relevant State or Union territory in the prescribed application process. CBIC’s registration rules provide for these details through Part A of Form GST REG-01.
Section 25(7) – Registration of Non-Resident Taxable Persons
Section 25(7) provides an exception to the normal PAN requirement for a non-resident taxable person.
A non-resident taxable person may be granted registration on the basis of such other documents as may be prescribed.
The CGST Rules prescribe a separate application mechanism for non-resident taxable persons.
Under the registration rules, a non-resident taxable person generally applies electronically in FORM GST REG-09 and provides the prescribed supporting documents. The rules also contain special requirements relating to advance payment of tax.
Section 25(8) – Suo Moto Registration by the Proper Officer
What happens if a person who is liable for GST registration does not apply?
Section 25(8) addresses this situation.
Where a person liable to be registered under the CGST Act fails to obtain registration, the proper officer may proceed to register that person in the prescribed manner.
This is commonly referred to as suo moto registration.
The power to register the person does not remove other consequences that may arise under the GST law for failing to comply with the registration requirement.
How Suo Moto Registration Works
The CGST Rules provide a procedure under which the proper officer may, following proceedings such as an enquiry, inspection, survey or search, find that a person is liable for registration but has failed to apply.
The officer may then issue temporary registration in FORM GST REG-11.
The person is subsequently required to complete the prescribed registration process, subject to the applicable rules.
Therefore, a taxpayer should not assume that failing to apply for GST registration will simply leave the business outside the GST system.
Section 25(9) – Unique Identity Number
Section 25(9) deals with Unique Identity Number (UIN).
Certain specialised entities are granted UIN rather than ordinary GST registration.
The provision specifically covers:
- Specialised agencies of the United Nations Organisation
- Certain Multilateral Financial Institutions and Organisations notified under the United Nations (Privileges and Immunities) Act, 1947
- Consulates
- Embassies of foreign countries
It also allows other persons or classes of persons notified by the Commissioner to receive a UIN in the prescribed manner.
Purpose of a Unique Identity Number
The UIN mechanism is primarily relevant for specified entities that are entitled to claim refunds of GST paid on notified supplies.
The UIN allows the GST system to identify such entities for the prescribed purposes, including refund claims relating to eligible supplies.
This is different from an ordinary GSTIN issued to a taxable person carrying on taxable business activities.
Section 25(10) – Grant or Rejection of Registration
Section 25(10) provides that registration or a Unique Identity Number shall be granted or rejected after due verification, in the manner and within the period prescribed.
The detailed verification procedure is provided through the CGST Rules.
The proper officer examines the application and accompanying information and documents.
Where the application is complete and satisfactory, registration may be approved.
Where clarification or additional information is required, the applicant may receive a notice requesting the required clarification or documents.
CBIC’s current registration-rules material provides the corresponding electronic forms and procedural timelines.
GST Registration Application – FORM GST REG-01
For ordinary applicants, FORM GST REG-01 is the principal application form for GST registration.
The registration rules provide a two-part process.
Part A
The applicant provides details including:
- PAN
- Mobile number
- Email address
- State or Union territory
These details are verified through the common portal.
Part B
After successful verification, the applicant uses the temporary reference number generated through the portal to submit Part B of FORM GST REG-01 electronically, along with the prescribed documents and information.
An electronic acknowledgement is then issued in FORM GST REG-02.
Verification and Clarification of GST Registration Application
If the proper officer finds that the application contains deficiencies or requires clarification, a notice may be issued electronically in FORM GST REG-03.
The applicant can respond through FORM GST REG-04 with the required clarification, information or documents.
If the officer is satisfied with the response, the registration can be approved.
If the applicant does not provide the required response within the prescribed period, or the officer is not satisfied with the response, the application may be rejected through FORM GST REG-05, with reasons recorded as prescribed.
Grant of GST Registration Certificate
Once registration is approved, the registration certificate is issued electronically in FORM GST REG-06.
The certificate contains the GST registration details, including the principal place of business and additional places of business, as applicable.
A GSTIN is assigned to the registered person in the prescribed format.
GSTIN – Goods and Services Tax Identification Number
The GSTIN is the identification number assigned to a registered person.
The registration rules specify the structure of GSTIN, including:
- State code
- PAN or TAN-related characters as applicable
- Entity code
- Checksum character
The GSTIN is used for GST compliance and transactions such as invoicing, return filing and other interactions with the GST system.
Effective Date of GST Registration
The effective date of registration depends on when the application is submitted in relation to the date on which registration liability arises.
Under the registration rules, where an application is submitted within 30 days from the date on which the person becomes liable to registration, the registration is generally effective from the date on which the person became liable.
Where the application is submitted after that 30-day period, the effective date is generally the date of grant of registration under the prescribed rules.
This distinction makes timely application particularly important.
Aadhaar Authentication and GST Registration
The GST registration system includes Aadhaar authentication requirements for applicable applicants, subject to the statutory and procedural framework and specified exceptions.
The CGST Rules contain provisions concerning Aadhaar authentication and the consequences where authentication is not completed or is not opted for.
Depending on the applicant and applicable risk parameters, physical verification of the place of business may also become relevant. CBIC has issued instructions concerning risk-based physical verification and the manner in which such verification is to be conducted.
Therefore, applicants should provide accurate information and complete the applicable authentication process when required.
Physical Verification of the Place of Business
GST registration is not always completed solely through online document verification.
In specified circumstances, the proper officer may undertake physical verification of the place of business.
The circumstances can include cases involving Aadhaar authentication requirements, risk-based identification or situations where the officer considers physical verification necessary in accordance with the prescribed procedure.
CBIC’s recent instructions emphasise risk-based verification and the prescribed documentation of physical verification.
This is why applicants should ensure that the declared principal place of business is genuine and that supporting documents are accurate.
Deemed Grant of Registration – Section 25(12)
Section 25(12) contains an important safeguard for applicants.
It provides that registration or a Unique Identity Number shall be deemed to have been granted after the expiry of the prescribed period under Section 25(10), if no deficiency has been communicated to the applicant within that period.
The detailed procedural rules prescribe the relevant periods and circumstances for processing applications.
The current CBIC registration rules provide a deemed-approval mechanism where the proper officer does not take the prescribed action within the applicable period.
What Happens if the GST Registration Application Has a Deficiency?
If an application contains incomplete information, missing documents or other deficiencies, the proper officer can seek clarification.
The applicant may receive FORM GST REG-03.
The applicant then has to respond through FORM GST REG-04 within the prescribed period.
If the response is satisfactory, registration can be approved.
If the applicant fails to respond or the officer is not satisfied with the response, the application can be rejected through FORM GST REG-05 in accordance with the prescribed procedure.
Special GST Registration for TDS and TCS Persons
Persons required to deduct tax under Section 51 or collect tax under Section 52 follow a separate registration procedure under the CGST Rules.
They apply electronically through FORM GST REG-07.
The proper officer may grant registration after due verification and issue the registration certificate in FORM GST REG-06.
This is different from the ordinary registration process followed by a normal taxable supplier.
Registration of Non-Resident Taxable Persons
Non-resident taxable persons also follow a special registration procedure.
Under the CGST Rules, a non-resident taxable person applies electronically in FORM GST REG-09 and is required to provide the prescribed documents.
The rules also provide for an advance deposit of tax equivalent to the estimated tax liability for the period for which registration is sought, in accordance with the relevant provisions.
The application must generally be submitted at least five days before commencement of business, consistent with Section 25(1).
GST Registration for OIDAR Suppliers From Outside India
The GST Rules also contain a separate registration mechanism for persons supplying online information and database access or retrieval services from outside India to non-taxable online recipients in India.
Such persons use the prescribed special registration procedure, including FORM GST REG-09A.
This is an example of how the general framework under Section 25 is supplemented by detailed rules for specialised categories.
Section 25 and Voluntary Registration – Important Difference
There is an important distinction between:
Mandatory registration: Registration is required because the person is liable under Section 22 or Section 24.
Voluntary registration: The person is not otherwise liable under Section 22 or Section 24 but chooses to register under Section 25(3).
In both situations, once registration is granted, the registered person becomes subject to the applicable provisions of the GST law.
Therefore, voluntary registration should not be confused with an exemption from compliance.
Section 25 and Separate Registrations – Practical Example
Suppose a company operates in Delhi and Haryana.
The company may have separate GST registrations in the two jurisdictions.
For GST purposes, the registrations are treated as distinct persons under Section 25(4).
If goods or services are supplied between the two registered establishments, the company must examine whether GST is applicable to the transaction under the provisions governing supplies between distinct persons.
This can be particularly important for:
- Head-office services
- Shared services
- Stock transfers where applicable
- Internal service arrangements
- Cost allocations
- Cross-State supplies
Section 25 and Compliance After Registration
Obtaining GST registration is not the end of the compliance process.
Once registration is granted, the registered person may have obligations relating to:
- Tax invoices
- GST returns
- Payment of tax
- Input tax credit
- Maintenance of records
- E-invoicing, where applicable
- E-way bill requirements, where applicable
- TDS or TCS, where applicable
- Registration amendments
- Cancellation or suspension provisions where applicable
Therefore, a person should apply for GST registration only after understanding the compliance responsibilities associated with being a registered person.
Common Mistakes in GST Registration Under Section 25
Mistake 1 – Missing the 30-Day Deadline
A person who becomes liable for registration under Section 22 or Section 24 should generally apply within 30 days.
Waiting too long can affect the effective date of registration and may create compliance issues.
Mistake 2 – Ignoring State-Wise Registration
GST registration is linked to the relevant State or Union territory.
A business operating in multiple jurisdictions should examine registration requirements separately.
Mistake 3 – Treating Voluntary Registration as Compliance-Free
Voluntary registration makes the person subject to the applicable provisions for registered persons.
Mistake 4 – Providing Incorrect Business Address Details
The principal place of business and additional places of business are important registration particulars.
Incorrect or unverifiable information can lead to clarification requests or physical verification.
Mistake 5 – Ignoring Separate Registration Rules
A business with multiple places of business in the same State or Union territory should examine the prescribed conditions before applying for separate registrations.
Mistake 6 – Assuming Every Applicant Follows FORM GST REG-01
Ordinary applicants generally use REG-01, but special categories such as TDS/TCS persons and non-resident taxable persons have separate prescribed forms and procedures.
Mistake 7 – Ignoring GST Registration Notifications and Rules
Section 25 provides the statutory framework, but many practical registration requirements are contained in the CGST Rules and related notifications.
Section 25 – Important Forms
| Form | Main Purpose |
|---|---|
| FORM GST REG-01 | Application for ordinary GST registration |
| FORM GST REG-02 | Acknowledgement of registration application |
| FORM GST REG-03 | Notice seeking clarification or additional information |
| FORM GST REG-04 | Reply to clarification notice |
| FORM GST REG-05 | Order of rejection of registration application |
| FORM GST REG-06 | Registration certificate |
| FORM GST REG-07 | Registration for specified TDS/TCS persons |
| FORM GST REG-09 | Registration application for non-resident taxable person |
| FORM GST REG-09A | Registration for specified OIDAR suppliers from outside India |
| FORM GST REG-11 | Temporary registration in specified cases of suo moto registration |
| FORM GST REG-12 | Application for Unique Identity Number |
The exact form applicable depends on the category of applicant and the relevant provisions of the CGST Rules.
Section 25 – Step-by-Step GST Registration Process
For an ordinary taxable person, the registration process can broadly be understood as follows:
Step 1 – Determine Registration Liability
First determine whether registration is required under Section 22 or Section 24, or whether voluntary registration under Section 25(3) is being sought.
Step 2 – Identify the Relevant State or Union Territory
Determine the jurisdiction in which registration is required.
Step 3 – Prepare PAN and Basic Details
The applicant should have the required PAN and other basic information for the application.
Step 4 – Submit Part A of FORM GST REG-01
Provide PAN, mobile number, email address and State or Union territory through the GST common portal.
Step 5 – Complete Verification
The prescribed verification process is carried out for the information submitted.
Step 6 – Submit Part B of FORM GST REG-01
Complete the detailed application and upload the prescribed information and documents.
Step 7 – Application Acknowledgement
An acknowledgement is issued electronically in FORM GST REG-02.
Step 8 – Officer Verification
The proper officer examines the application.
If clarification is required, REG-03 may be issued.
Step 9 – Respond to Clarification
The applicant provides the required response through REG-04.
Step 10 – Grant or Rejection
If the application satisfies the applicable requirements, registration is granted and the certificate is issued in REG-06.
If the application is not satisfactorily completed, it may be rejected through REG-05 in accordance with the prescribed procedure.
Section 25 vs Section 22 vs Section 23 vs Section 24
| Section | Main Purpose |
|---|---|
| Section 22 | Persons liable for registration based on applicable conditions and turnover |
| Section 23 | Persons not liable for registration in specified circumstances |
| Section 24 | Compulsory registration in specified cases |
| Section 25 | Procedure for obtaining GST registration |
| Section 26 | Deemed registration under specified circumstances |
| Section 27 | Special provisions relating to casual taxable persons and non-resident taxable persons |
This sequence makes it easier to understand the GST registration chapter.
First, the law determines whether registration is required. Sections 22 and 24 are important for liability, while Section 23 provides specific exclusions.
Once registration liability exists, Section 25 explains how registration is obtained.
Key Takeaways of Section 25
The major points of Section 25 can be summarised as follows:
- Section 25 deals with the procedure for GST registration.
- A person liable under Section 22 or Section 24 generally has to apply within 30 days from becoming liable.
- Casual taxable persons and non-resident taxable persons must generally apply at least five days before commencement of business.
- An SEZ unit or SEZ developer requires separate registration as prescribed.
- A person making a supply from territorial waters has a specific registration jurisdiction under Section 25.
- The general rule is one registration in a State or Union territory.
- Separate registrations for multiple places of business are permitted subject to prescribed conditions.
- Persons having multiple registrations are treated as distinct persons for GST purposes.
- Voluntary registration is permitted under Section 25(3).
- PAN is generally required for GST registration, subject to the specific exception for Section 51 deductors.
- Non-resident taxable persons may use prescribed alternative documents instead of PAN.
- The proper officer can proceed with registration where a liable person fails to obtain registration.
- Specified international organisations, diplomatic missions and other notified entities may receive a Unique Identity Number.
- GST registration is granted or rejected after verification under the prescribed procedure.
- Registration certificates are issued in the prescribed form.
- Registration may be deemed granted when the statutory and prescribed conditions for deemed approval are satisfied.
Conclusion
Section 25 of the CGST Act, 2017 provides the legal framework for obtaining GST registration after a person becomes liable to register. It covers the application deadline, State or Union territory-wise registration, special provisions for casual and non-resident taxable persons, SEZ registration, voluntary registration, separate registrations for multiple places of business, PAN requirements, suo moto registration and Unique Identity Numbers.
For ordinary taxpayers, the registration process generally begins with determining liability and then submitting the prescribed application through the GST common portal. FORM GST REG-01 is used for ordinary registration, while special categories have separate procedures and forms. The application may be approved, clarification may be sought, or the application may be rejected depending on verification.
One of the most important practical points is the 30-day registration application period for persons becoming liable under Section 22 or Section 24. Casual taxable persons and non-resident taxable persons are subject to the separate five-day advance application requirement.
Section 25 also establishes the concept of voluntary registration and the distinct-person treatment of separately registered establishments. These provisions can have significant consequences for businesses operating across different States or maintaining multiple places of business.
Because the detailed registration procedure is contained in the CGST Rules as well as the Act, taxpayers should consider both Section 25 and the applicable rules, notifications and current GST portal requirements when applying for registration.
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