This article comprises of basic compliances which every assessee shall be liable to comply with and in case, it defaults in complying with the same, he shall be subject to penalty and interest. CA Ashish Garg

1. REGISTRATION AND
COMPLIANCE UNDER GST
GOODS AND SERVICE TAX (GST)
BY CA ASHISH GARG
B.COM (H), FCA, LL.B.
1TAXMUNEEM

2. REGISTRATION AND
COMPLIANCES UNDER GST
TAXMUNEEM 2
GST is the most discussed topic in India nowadays and is also a main cause of worry for every
businessman. Every businessman is worried about his fate after implementation of GST in India
as what would be the registration process, what will be the compliance process, what shall be the
payment structure etc.
This article comprises of basic compliances which every assessee shall be liable to comply with
and in case, it defaults in complying with the same, he shall be subject to penalty and interest.

3. Liability to take Registration
Particulars Exemption
Limit
Remarks
Supplier having
aggregate turnover
above specified limit
a)In case of North
Eastern States and
hill states
b)States other than
(a)
Rs. 10 lakhs
Rs. 20 lakhs
a) Aggregate turnover shall include total turnover from all
states;
b) If a person is engaged in supply of both exempted/ non
taxable/ export goods/ services and taxable goods/
services, then value of both shall be considered for
computing Aggregate turnover;
c) If a person is solely engaged in supply of goods/services
which are not liable to tax, then such shall not be liable to
take registration
d) Aggregate turnover shall include all supplies made by the
taxable person, whether on his own account or made on
behalf of all his principals.
e) However in case of supply of goods by registered job worker,
it shall be treated as supply of goods by principle and shall
not be included in aggregate turnover of job worker.
3TAXMUNEEM

4. Liability to take Registration
Particulars Exemption Limit Remarks
Input Service Distributor No Exemption
Person making interstate
taxable supply
No Exemption Every person making interstate supply of taxable
goods or services shall be liable to take registration
under GST irrespective of the turnover
Casual Taxable person No Exemption Every casual taxable who occasionally undertakes
supply of goods or services in the course of
furtherance of business in a taxable territory where
he has no fixed place of business shall be liable to take
registration under GST irrespective of the turnover.
Person registered under
existing Indirect Tax laws
Every person who is currently registered under
existing indirect taxes shall be liable to be registered
under GST. However, if an assessee is not covered
under GST, then he shall be able to surrender its
registration.
4TAXMUNEEM

5. Liability to take Registration
Particulars Exemption Limit Remarks
Person liable to pay
tax under Reverse
Charge Mechanism
No Exemption Every person who is in receipt of specified services on
which he is liable to pay GST under Reverse Charge shall
be liable to take registration under GST irrespective of
the turnover.
Non Resident taxable
person
No Exemption Every non resident taxable person who occasionally
undertakes supply of goods or services in India but who
has no fixed place of business shall be liable to take
registration under GST irrespective of the turnover.
Person liable to deduct
TDS
Value of supply
under contract
exceed Rs. 10 lakhs
Every person specified by the Legislature to deduct tax
at source at the rate of 1% from the payment made or
credited to the supplier where the total value of supply
exceeds Rs. 10 lakhs shall be liable to take registration
under GST as a deductor
5TAXMUNEEM

6. Liability to take Registration
Particulars Exemption Limit Remarks
Supplier of goods on
behalf of other taxable
person whether as agent
or otherwise.
No exemption. Every person who is making supply of goods/services
on behalf of other taxable person whether as agent or
otherwise shall be liable to take registration under
GST irrespective of the turnover.
Supplier of Goods/
services through E-
commerce operator
No Exemption Every person who is supplying goods/ services
through E-commerce operator shall be liable to take
registration under GST irrespective of the turnover as
the customer of the goods are scattered all over India.
Electronic commerce
operator
No Exemption Every E-commerce operator who owns, operates or
manages electronic platform that is engaged in supply
of goods or services for taxable persons shall be liable
to take registration under GST irrespective of the
turnover.
6TAXMUNEEM

7. Particulars Exemption Limit Remarks
Aggregator No Exemption Every aggregator who owns and manages an
electronic platform and by means of
application and communication device
connects a person with the supplier of service
under his own brand name or trade name
shall be liable to take registration under GST
irrespective of the turnover.
Any other category of person As may be prescribed Government may specify any other person or
class of person who shall be liable to take
registration under GST.
Liability to take Registration
7TAXMUNEEM

8. Steps for Registration
8TAXMUNEEM

9. TAXMUNEEM 9
Other Important Points
Condition for Registration of Casual Taxable person and Non resident taxable person
Casual Taxable person and Non resident taxable person shall deposit advance tax equivalent to
the estimated tax liability and such registration shall be valid for the period of 90 days. The
period of 90 days can be extended for the further period not exceeding 90 days on the request of
such taxable person
Penalty for Non registration
Every person shall be liable to penalty of Rs. 10,000/- if:
 He is liable to take registration but fails to obtain registration
 He furnishes any false information with regard to particulars specified as mandatory at the
time of applying for registration.
Display of Registration Certificate in principal place of business
Every registered taxable person shall display his certificate of registration in a prominent
location at his principal place of business and at every additional place of business. It shall also
mention its GSTIN in the name board exhibited at the entry of principal place of business and of
every additional place of business

10. TAXMUNEEM 10
Other Important Points
Registration for Existing Dealers under existing Indirect Tax Laws
Assessee who is currently registered with various State or Central Indirect Statutes shall not be
required to apply for fresh registration and he shall get himself registered by following the
procedure prescribed in this regard.
Deemed Registration
If the proper officer does not grant registration to the applicant within the specified time limit
nor communicated any deficiency in the application to the applicant, then the registration shall
be deemed to have been granted after the expiry of stipulated time limit.
Rejection of application of registration under one act shall lead to automatic rejection
under other Act
Any application of registration under CGST Act/SGST Act by the department shall automatically
lead to rejection of application of registration under SGST Act/CGST Act.

11. Discharge of Tax liability under GST
Particulars Due date of payment of tax
Regular Assessee liable to be registered under
Schedule III of MGL
20th
of the succeeding month to which liability
pertains
Assessee opted to discharge GST liability under
Composition Scheme
18th
of the succeeding quarter to which the
liability pertains
Deductor/collector of tax at source 10th
of the succeeding month in which the
deduction or collection is made
11TAXMUNEEM

12. TAXMUNEEM 12
Other Important Points
Date of payment of tax shall be the date of actual credit of amount in the government account.
Thus, if an assessee has deposited GST within due time limit but it has not been credited in the
government accounts till the last day of filing of return, then it shall be considered as late
payment of tax.
The amount deposited by an assessee shall be credited to the electronic cash ledger and such
amount can be adjusted against GST, interest, penalty, fees etc. payable under GST Act. An
assessee can make payment in its electrnoic cash ledger through debit card/credit card or NEFT
or RTGS or any other prescribed mode.
Any assessee who makes default in payment of GST either on its supply of goods/services or on
tax deducted /collected at source or under Reverse Charge mechanism shall be liable to pay
interest at the rate to be notified

13. Periodical Returns
Particulars Prescribed
Form
Due date of return
Details of outward supplies by every registered taxable
person other than ISD, or a person paying tax under
Composition Scheme or Deductor of tax at source.
GSTR-1 10th
of the succeeding month
to which outward supplies
pertains.
Details of inward supplies by every registered taxable
person including person covered under reverse charge
mechanism but excluding ISD, or a person paying tax
under Composition Scheme or Deductor of tax at
source.
GSTR-2 15th of the succeeding month
to which inward supplies
pertains.
Monthly return of GST by Regular Assessee liable to be
registered under Schedule III of MGL.
GSTR-3 20th of the succeeding month
to which liability pertains.
Assessee opted to discharge GST liability under
Composition Scheme.
GSTR-4 18th
of the succeeding quarter
to which the liability pertains.
13TAXMUNEEM

14. Periodical Returns
Particulars Prescribed
Form
Due date of return
Non Resident taxable person GSTR-5 20th
after the end of a tax period or within 7
days after the last day of the validity period of
registration, whichever is earlier.
Input Service Distributor GSTR-6 13th
of the succeeding month
Deductor/collector of tax at source GSTR-7/
GSTR-8
10th
of the succeeding month in which the
deduction or collection is made
Annual Return by registered taxable
person other than ISD or Deductor of
tax at source or a casual taxable person
and a non-resident taxable person
GSTR-9 31st
December following the end of each
financial year
Final Return to be submitted by the
registered taxable person who applied
for cancellation of registration
GSTR-10 Every registered taxable person shall file a final
return within three months from the date of
cancellation or date of cancellation order
whichever is later.
14TAXMUNEEM

15. TAXMUNEEM 15
1.1. Details of outward supplies shall include details relating to zero-rated supplies, inter-
state supplies, return of goods received in relation to/ in pursuance of an inward
supply, exports, debit notes, credit notes and supplementary invoices issued during the
said tax period. However it shall not include details of exempted supplies.
Details of outward supplies shall include details relating to zero-rated supplies, inter-
state supplies, return of goods received in relation to/ in pursuance of an inward
supply, exports, debit notes, credit notes and supplementary invoices issued during the
said tax period. However it shall not include details of exempted supplies.
Important points with respect to
periodical returns
2.2. An assessee shall not be allowed to furnish return for any tax period if valid return for
any previous tax period has not been furnished by him.
An assessee shall not be allowed to furnish return for any tax period if valid return for
any previous tax period has not been furnished by him.
3.3. Valid return means return furnished after making payment of full tax dues as per such
return.
Valid return means return furnished after making payment of full tax dues as per such
return.
4.4. Every registered person shall be liable to furnish return with the GST department even
if no supplies of goods/services have been effected during the tax period i.e. he shall
be liable to file NIL returns.
Every registered person shall be liable to furnish return with the GST department even
if no supplies of goods/services have been effected during the tax period i.e. he shall
be liable to file NIL returns.
5.5. Any omission or deficiency in the return either out of its own motion or on being
pointed out by the department or due to the mismatch in outward supply or inward
supply shall rectify such omission or deficiency in the return for the period in which
such omission or deficiency is noticed or communicated.
Any omission or deficiency in the return either out of its own motion or on being
pointed out by the department or due to the mismatch in outward supply or inward
supply shall rectify such omission or deficiency in the return for the period in which
such omission or deficiency is noticed or communicated.

16. TAXMUNEEM 16
6.6. Where there is a increase of output tax liability or reduction in input tax credit due to
mismatch or reversal, an assessee shall be liable to pay the such output tax or input
credit along with interest at the prescribed rate.
Where there is a increase of output tax liability or reduction in input tax credit due to
mismatch or reversal, an assessee shall be liable to pay the such output tax or input
credit along with interest at the prescribed rate.
Important points with respect to
periodical returns
7.7. Where an assessee has paid output tax or input credit due to mismatch of records
which are subsequently been rectified, then the assessee shall be refunded the interest
and tax paid by crediting the same in its electronic cash ledger.
Where an assessee has paid output tax or input credit due to mismatch of records
which are subsequently been rectified, then the assessee shall be refunded the interest
and tax paid by crediting the same in its electronic cash ledger.
8.8. Every assessee who is liable to get his accounts audited under Section 42 of the MGL
shall along with its annual return, furnish the audited financial statements and
reconciliation between the value of supplies declared in the return furnished for the
year and audited annual financial statements.
Every assessee who is liable to get his accounts audited under Section 42 of the MGL
shall along with its annual return, furnish the audited financial statements and
reconciliation between the value of supplies declared in the return furnished for the
year and audited annual financial statements.
9.9. Every person liable to furnish details of outward supply, and inward supply under
section 25 and 26 of the MGL or return under Section 27 or section 31of MGL shall be
liable to pay a late fee of Rs. 100 per day of delay or Rs. 5000 whichever is lower for
delay in furnishing of return.
Every person liable to furnish details of outward supply, and inward supply under
section 25 and 26 of the MGL or return under Section 27 or section 31of MGL shall be
liable to pay a late fee of Rs. 100 per day of delay or Rs. 5000 whichever is lower for
delay in furnishing of return.
1010 Every person liable to furnish annual return under Section 30 shall be liable to pay a
late fee of Rs. 100 per day of delay subject to maximum of an amount equivalent to
0.25% of his aggregate turnover.
Every person liable to furnish annual return under Section 30 shall be liable to pay a
late fee of Rs. 100 per day of delay subject to maximum of an amount equivalent to
0.25% of his aggregate turnover.

17. TAXMUNEEM 17
Other Compliances
Maintenance of Accounts
Every registered taxable person shall keep and maintain, at his principal place of business a
true and correct account of production or manufacture of goods, of inward or outward supply of
goods and/or services, stock, input tax credit availed, output tax payable and paid.
Where more than one place of business is specified in the certificate of registration, then he
shall be liable to maintain accounts pertaining to such place at such place of business
Deemed Registration
Every registered taxable person having turnover exceeding the prescribed limit shall be liable to
get its accounts audited from a Chartered Accountant or a Cost Accountant and shall submit the
same to the proper officer along with the reconciliation statement reconciling difference
between audited financial statements and return filed during the year.

18. TAXMUNEEM 18
Other Compliances
Maintenance of Accounts
Every registered taxable person shall retain books of accounts and other records until the expiry of
60 months from the last date of filing of Annual return for the year pertaining to such accounts and
records.
However, where the taxable person who is party to an appeal or revision or any other proceeding
before any appellate authority, tribunal or court whether filed by the taxable person or by the
department, he shall be liable to retain the accounts and records pertaining to subject matter of such
appeal, revision or proceeding for a period of one year after the final disposal of such appeal or
revision or proceeding.
For any clarification or discussion on this article, the author may be contacted at A2B/16A, Ekta
Apartments, Paschim Vihar, Delhi-110063, Phone: 011-45564490, 011-43464490, E-mail:
mail@arajassociates.com.
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