Section 28 – Amendment of Registration under the CGST Act, 2017

Section 28 of the Central Goods and Services Tax Act, 2017 deals with the amendment of GST registration. Once a person obtains GST registration, the information provided at the time of registration may change during the course of business. For example, a business may change its legal name, move its principal place of business, add another place of business, change its partners or directors, or update contact and banking details.

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GST law therefore provides a mechanism through which registered persons can update their registration particulars without obtaining an entirely new registration in every situation.

Section 28 establishes the legal framework for making these amendments, while Rule 19 of the CGST Rules, 2017 provides the detailed procedure, time limit, forms and treatment of different types of changes. Under the current Rule 19, an amendment application is generally required to be submitted within 15 days of the change in the registration particulars.

What is Section 28 of the CGST Act?

Section 28 is titled “Amendment of registration.”

The provision requires every registered person and a person to whom a Unique Identity Number (UIN) has been assigned to inform the proper officer about changes in the information furnished at the time of registration or subsequently amended.

The information has to be provided in the prescribed form, manner and within the prescribed period.

Section 28 also establishes an important distinction between registration particulars that require approval by the proper officer and those for which approval is not required.

The proper officer may approve or reject an amendment based on the information submitted by the taxpayer or information otherwise ascertained by the officer. However, the officer cannot reject an amendment application without giving the applicant an opportunity of being heard.


Why is Amendment of GST Registration Required?

GST registration contains important information identifying the registered taxpayer and the business.

If this information changes but the GST registration is not updated, the registration certificate may no longer accurately represent the taxpayer’s current business details.

For example, a registered business may:

  • change its legal name;
  • change its principal business address;
  • open an additional place of business;
  • add or remove a partner;
  • change its directors;
  • change its authorised signatory;
  • update its mobile number or email address;
  • change bank account details; or
  • make other changes in the information provided during registration.

GST law provides the amendment mechanism so that the registration records can be kept updated. CBIC also explains that some registration fields can be amended online without official intervention, while certain core fields require approval.


Who Can Apply for Amendment of GST Registration?

The amendment provisions apply to:

  1. Registered persons, and
  2. Persons assigned a Unique Identity Number (UIN).

Section 28(1) requires these persons to inform the proper officer about changes in the information furnished at registration or subsequently.

The application is made electronically through the GST common portal in the prescribed form.

Under the current Rule 19, the amendment application is filed in FORM GST REG-14.


Time Limit for Amendment of GST Registration

One of the most important requirements under Rule 19 is the time limit.

Where there is a change in any of the particulars furnished in the registration application or subsequently amended, the registered person is required to submit an application for amendment within 15 days of the change.

The application is filed electronically in FORM GST REG-14 along with documents relating to the change, wherever required.

Example

Suppose a company changes its principal place of business on 1 September.

The registered person should submit the amendment application within the prescribed 15-day period from the date of the change.

The exact supporting documents will depend upon the nature of the amendment.


Core and Non-Core Fields in GST Registration

For practical purposes, GST registration amendments can broadly be understood through two categories:

  • Core fields, where approval of the proper officer is required; and
  • Other fields, where the registration certificate stands amended upon submission of the application, subject to the applicable rules.

Rule 19 specifically identifies certain important changes that require approval.


Core Fields Requiring Approval

Under Rule 19, the following major categories of changes require verification and approval by the proper officer, provided the change does not warrant cancellation of registration under Section 29.

1. Change in Legal Name of Business

If the legal name of the business changes without requiring cancellation of the registration, the taxpayer needs to amend the GST registration.

The proper officer verifies the amendment and, where appropriate, approves it.

The amendment is made effective from the date of the event warranting the amendment.

2. Change in Principal Place of Business

A change in the principal place of business is another important amendment.

The taxpayer must update the GST registration when the principal place of business changes.

Because the principal place of business is a core registration field, the amendment requires approval by the proper officer under Rule 19.

3. Change in Additional Place of Business

A registered person may have one or more additional places of business.

If an additional place is added, deleted or otherwise changed, the registration particulars may need to be amended.

Rule 19 treats the address of the principal place of business and additional place or places of business as core amendment fields.

4. Addition, Deletion or Retirement of Partners

Where a partnership business changes its partners, the GST registration particulars may need to be updated.

This includes:

  • addition of a partner;
  • deletion of a partner; or
  • retirement of a partner.

The change is subject to the prescribed amendment procedure and approval where applicable.

5. Change in Directors or Other Persons Responsible for Day-to-Day Affairs

Rule 19 also covers addition, deletion or retirement of persons responsible for the day-to-day affairs of the business.

Depending on the type of entity, this can include:

  • directors;
  • Karta;
  • Managing Committee;
  • Board of Trustees;
  • Chief Executive Officer; or
  • an equivalent person responsible for day-to-day affairs.

These are treated as core registration particulars for amendment purposes.


Non-Core Registration Amendments

Not every change requires approval by the proper officer.

Rule 19 provides that where the change relates to particulars other than those specifically identified as core fields, the certificate of registration stands amended upon submission of FORM GST REG-14 on the common portal.

CBIC has also explained that examples of fields that can generally be amended without approval include information such as:

  • telephone number;
  • email ID; and
  • bank account details.

However, the taxpayer must still follow the prescribed online verification requirements wherever applicable.


Change in Authorised Signatory’s Mobile Number or Email

Rule 19 contains a specific requirement for changes in the mobile number or email address of the authorised signatory.

Such changes are to be carried out only after online verification through the common portal in the manner prescribed under Rule 8.

This additional verification requirement helps ensure that important communication details connected with the authorised signatory are properly authenticated.


What Happens if the Change in Constitution Changes the PAN?

This is an important exception to the normal amendment procedure.

If a change in the constitution of a business results in a change in the Permanent Account Number (PAN) of the registered person, the existing registration cannot simply be amended.

The taxpayer is required to apply for fresh GST registration in FORM GST REG-01.

Example

Suppose a business structure changes in such a way that the PAN of the taxable person changes.

In such a case, amendment of the old GST registration is not the appropriate route. A fresh registration application is required.

Therefore, taxpayers should first determine whether a proposed change merely changes registration particulars or actually results in a change of PAN.


Can a GST Registration Amendment Be Made From an Earlier Date?

Rule 19(1A) contains an important restriction regarding the effective date of amendments.

A particular registration amendment generally cannot take effect from a date earlier than the date on which the FORM GST REG-14 application is submitted on the common portal.

An exception can be made through an order of the Commissioner, for reasons recorded in writing and subject to conditions specified in that order.

This means taxpayers should not assume that every amendment can automatically be given an earlier effective date merely by entering an earlier date in the application.


Procedure for Amendment of GST Registration

The amendment process can be understood through the following steps.

Step 1: Identify the Change

First, the registered person should identify what information in the GST registration has changed.

For example:

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  • business address;
  • legal name;
  • partner;
  • director;
  • contact details;
  • bank account;
  • additional place of business; or
  • other registration information.

Step 2: Collect Supporting Documents

The taxpayer should collect documents supporting the proposed change.

The documents depend upon the nature of the amendment.

For example, an address change may require appropriate proof of the new premises, while a change in the constitution or responsible persons may require relevant constitutional or entity documents.

Step 3: File FORM GST REG-14

The amendment application is filed electronically in FORM GST REG-14 through the GST common portal.

The application must be submitted within the prescribed 15-day period from the change.

Step 4: Verification

For core fields, the proper officer examines the application and supporting documents.

If everything is satisfactory, the officer approves the amendment.

Step 5: Amendment Certificate

After approval, the amended registration information becomes available electronically.

For core amendments, the proper officer issues FORM GST REG-15.

For non-core fields covered by Rule 19, the certificate stands amended upon submission of the application, subject to the prescribed requirements.


Approval of Core Amendments by Proper Officer

Where a core field is being amended, Rule 19 provides that the proper officer should approve the amendment after due verification within 15 working days from receipt of the application in FORM GST REG-14. The officer then issues the order in FORM GST REG-15.

The amendment takes effect from the date of occurrence of the event warranting the amendment, subject to the provisions of Rule 19, including the restriction contained in Rule 19(1A).


What If the Proper Officer Finds a Problem?

The proper officer may believe that:

  • the amendment is not warranted; or
  • the documents submitted are incomplete; or
  • the documents submitted are incorrect.

In such a situation, Rule 19 provides a notice mechanism.

The officer may issue FORM GST REG-03 within the prescribed period and ask the registered person to explain why the amendment application should not be rejected.


Reply to Amendment Notice

If FORM GST REG-03 is issued, the registered person is required to submit a reply in FORM GST REG-04.

Rule 19 provides a period of seven working days from the date of service of the notice for furnishing the reply.

The taxpayer should carefully address the issue raised in the notice and provide the necessary clarification or documents.


Rejection of Amendment Application

If the taxpayer’s reply is not satisfactory, or if the taxpayer does not submit a reply within the prescribed period, the proper officer may reject the amendment application.

The rejection order is issued in FORM GST REG-05.

However, Section 28 contains an important procedural safeguard: the proper officer cannot reject an application for amendment without giving the person an opportunity of being heard.


What Happens If the Officer Does Not Take Action?

Rule 19 also provides a deemed amendment mechanism.

If the proper officer does not take action:

  • within 15 working days from submission of the application; or
  • within 7 working days from receipt of the taxpayer’s reply to the show cause notice,

the certificate of registration stands amended to the extent applied for, and the amended certificate is made available to the registered person on the common portal.

This provision is important because the amendment process does not remain indefinitely pending merely because the officer has not taken action within the prescribed period.


Amendment of Registration Across Multiple Registrations Under the Same PAN

Rule 19 contains a specific provision concerning certain amendments in a State or Union Territory.

Changes relating to:

  • the legal name of the business; and
  • addition, deletion or retirement of specified persons responsible for the day-to-day affairs of the business,

in a particular State or Union Territory are applicable to all registrations of the registered person in that State or Union Territory obtained under the relevant chapter on the same PAN.

This is important for taxpayers who have multiple GST registrations linked to the same PAN within a State or Union Territory.


Example of Amendment of GST Registration

Suppose ABC Private Limited is registered under GST.

The company shifts its principal office from one location to another.

Because the principal place of business is a core registration field, ABC Private Limited cannot simply change the address without following the prescribed amendment process.

The company should:

  1. identify the effective date of the change;
  2. collect appropriate documents relating to the new premises;
  3. file FORM GST REG-14 within the prescribed period;
  4. submit the required supporting documents;
  5. wait for verification by the proper officer;
  6. respond to FORM GST REG-03 if a clarification is requested; and
  7. obtain the amended registration certificate in the prescribed manner.

If the application is approved, the officer issues FORM GST REG-15.


Example of a Non-Core Amendment

Suppose a registered taxpayer changes the business email address.

This type of information falls within the category of particulars other than the core fields specifically identified in Rule 19.

The taxpayer submits the amendment through FORM GST REG-14 on the common portal.

Under Rule 19, the registration certificate stands amended upon submission for such non-core particulars, subject to the specific online verification requirements that apply to authorised-signatory contact details.


Amendment vs Fresh GST Registration

One of the most important practical questions is whether a change should be handled through amendment or through a fresh registration.

Amendment is generally relevant when:

  • the PAN remains the same;
  • registration continues to be applicable; and
  • the change can be accommodated within the existing registration.

Fresh registration is required where:

A change in the constitution of the business results in a change of PAN.

Rule 19 specifically requires the taxpayer to apply for fresh registration in FORM GST REG-01 in such a situation.

This distinction prevents taxpayers from incorrectly trying to modify a GST registration that belongs to a different PAN.


Important GST Forms Related to Amendment of Registration

Several forms are relevant to the amendment process.

FormPurpose
FORM GST REG-14Application for amendment of registration particulars
FORM GST REG-15Order approving amendment of registration
FORM GST REG-03Notice seeking clarification regarding amendment
FORM GST REG-04Reply to the amendment notice
FORM GST REG-05Order rejecting the amendment application
FORM GST REG-01Fresh registration application where a change in constitution results in a change of PAN

The current Rule 19 specifically prescribes REG-14 as the amendment application and REG-15 as the approval order.


Difference Between Core and Non-Core Amendments

ParticularCore AmendmentOther/Non-Core Amendment
Proper officer approvalGenerally requiredNot required under Rule 19 for prescribed non-core particulars
ExamplesLegal name, principal/additional business address, specified partners/directors/responsible personsOther registration particulars, subject to specific verification requirements
ApplicationFORM GST REG-14FORM GST REG-14
Officer orderFORM GST REG-15Generally not required
VerificationOfficer verification appliesCertificate stands amended upon submission, subject to applicable rules
Possible noticeFORM GST REG-03Depends on the applicable provisions

CBIC’s own FAQ similarly explains that certain core fields require approval, while other fields can be amended online without intervention by an officer.


Important Points About Section 28

The following points summarize the main provisions of Section 28 and Rule 19:

  1. Section 28 deals with amendment of GST registration.
  2. Registered persons must report changes in registration particulars.
  3. Persons assigned a UIN are also covered.
  4. The detailed procedure is prescribed under Rule 19 of the CGST Rules.
  5. The current Rule 19 generally requires amendment applications within 15 days of the change.
  6. The amendment application is filed electronically in FORM GST REG-14.
  7. Legal name changes are treated as core amendments.
  8. Changes in principal and additional places of business are core amendments.
  9. Addition, deletion or retirement of specified partners, directors and other responsible persons are core amendments.
  10. Core amendments require verification and approval by the proper officer.
  11. The approval order for core amendments is issued in FORM GST REG-15.
  12. Other prescribed particulars can be amended without prior approval.
  13. Authorised-signatory mobile number and email changes require online verification.
  14. A change in constitution resulting in a change of PAN requires fresh registration.
  15. The proper officer may issue FORM GST REG-03 where clarification or additional information is required.
  16. The taxpayer can reply in FORM GST REG-04.
  17. An unsatisfactory or missing reply can result in rejection through FORM GST REG-05.
  18. The taxpayer must be given an opportunity of being heard before rejection under Section 28.
  19. If the officer does not act within the prescribed period, the certificate can stand amended to the extent applied for.
  20. Amendment should not be confused with cancellation or fresh registration.

Why Timely Amendment of GST Registration Is Important

Keeping GST registration details updated is important because the registration certificate is used for identifying the registered taxpayer and its business.

An outdated address, incorrect legal name or inaccurate information about persons responsible for the business can create practical and compliance-related issues.

For this reason, taxpayers should not wait until a return, invoice or departmental communication reveals that registration details are outdated.

When a relevant change occurs, the taxpayer should identify the nature of the change and complete the prescribed amendment process within the applicable time.

The GST framework specifically requires the registered person to report changes within the period prescribed under Rule 19.

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Conclusion

Section 28 of the CGST Act, 2017 provides the legal framework for amending GST registration particulars when information furnished at the time of registration or subsequently changes.

The detailed procedure under Rule 19 divides registration changes into categories. Important core particulars such as the legal name of the business, principal or additional place of business, and specified partners, directors or other persons responsible for day-to-day affairs generally require verification and approval by the proper officer. Other prescribed particulars can be amended through the common portal without prior approval.

The current amendment process generally requires the taxpayer to submit FORM GST REG-14 within 15 days of the change. Where approval is required, the proper officer has 15 working days to act, and the approval is issued in FORM GST REG-15. If clarification is required, FORM GST REG-03 and FORM GST REG-04 are used, while rejection is communicated through FORM GST REG-05.

A particularly important point is that a change in the constitution of a business resulting in a change of PAN cannot be handled merely by amending the existing registration. In such a case, fresh GST registration in FORM GST REG-01 is required.

Understanding Section 28 along with Rule 19 helps taxpayers keep their GST registration records accurate and avoid confusion when business details change.

Frequently Asked Questions About Section 28 of the CGST Act

What is Section 28 of the CGST Act?

Section 28 of the CGST Act, 2017 deals with amendment of GST registration. It requires registered persons and persons assigned a Unique Identity Number to inform the proper officer about changes in the information furnished at the time of registration or subsequently.

What is the time limit for amending GST registration?

Under Rule 19 of the CGST Rules, a registered person generally has to submit the amendment application within 15 days of the change in the registration particulars.

Which form is used for amendment of GST registration?

The current Rule 19 prescribes FORM GST REG-14 for submitting an application for amendment of GST registration particulars.

Which GST registration details require approval from the proper officer?

Core particulars such as the legal name of the business, the principal or additional place of business, and addition, deletion or retirement of specified partners, directors and other persons responsible for the day-to-day affairs of the business require verification and approval under Rule 19, provided the change does not warrant cancellation of registration.

What is FORM GST REG-15?

FORM GST REG-15 is the order issued electronically by the proper officer for approval of an amendment in the registration particulars covered by the approval process under Rule 19.

What happens if the GST officer asks for clarification on an amendment application?

The proper officer may issue FORM GST REG-03 when the amendment is considered not warranted or the supporting documents are incomplete or incorrect. The registered person can submit a reply in FORM GST REG-04 within seven working days from service of the notice.

Can an amendment application be rejected without giving the taxpayer an opportunity to be heard?

No. Section 28 specifically provides that the proper officer shall not reject an application for amendment in registration particulars without giving the person an opportunity of being heard.

What happens if the GST officer does not take action on the amendment application within the prescribed time?

If the proper officer does not take action within 15 working days from submission of the application, or within seven working days from receipt of the taxpayer’s reply to the notice, Rule 19 provides that the registration certificate shall stand amended to the extent applied for and the amended certificate shall be made available on the common portal.

Can a change in constitution of business be made through GST amendment?

It depends on whether the change results in a change of PAN. If the change in constitution results in a change of PAN, Rule 19 requires the taxpayer to apply for fresh GST registration in FORM GST REG-01 rather than merely amending the existing registration.

Can GST registration details be amended online?

Yes. The amendment application is submitted electronically through the GST common portal. Core amendments are subject to the prescribed verification and approval process, while other prescribed particulars can be amended upon submission of the application.

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