CA K Sanjay BhargavChartered Accountant
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GST registration: the process, and the 30-day trap

CA K Sanjay Bhargav, Chartered Accountant, Bengaluru

Membership No. 250054 · DISA (ICAI)

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Short answer: you have 30 days from becoming liable to apply. With Aadhaar authentication the application is normally deemed approved in seven working days; without it, expect physical verification and around twenty-one.

The part almost nobody is told: applying within those 30 days is what preserves input tax credit on the stock you are holding when you register. Miss the window and the registration still happens — the credit does not.

When the clock actually starts

The obligation arises when you cross the threshold or fall into a compulsory category under Section 24, not when you get round to dealing with it. From that date you have 30 days to apply.

Whether you are liable at all — the ₹40 lakh and ₹20 lakh thresholds, and the Section 24 cases that override them entirely — is set out on the GST registration and return filing page. A trader selling through a marketplace, or a consultant with one client in another state, is frequently liable well below the threshold.

The process

1. Form REG-01, Part A. PAN, mobile number and email. These are validated and you receive a Temporary Reference Number.

2. Part B. The substance: constitution of business, principal and additional places of business, bank details, goods and services with HSN or SAC codes, and details of promoters or partners.

3. Aadhaar authentication. Under Section 25(6A) to (6D), you elect whether to authenticate via Aadhaar. This choice drives everything that follows.

4. Biometric verification, where flagged. Where the application is selected for it, the applicant must attend a GST Suvidha Kendra in person for biometric Aadhaar authentication and document verification. This has been rolled out state by state.

5. Approval, or a query.

RouteWhat happensTimeline
Aadhaar authenticatedDeemed approved unless a notice issues7 working days
No Aadhaar / authentication failsReferred for physical verification of the place of businessup to ~21 working days
Query raisedNotice in REG-03, reply in REG-04generally 7 working days to reply
ApprovedCertificate in REG-06 with your GSTIN
RejectedREG-05 — you must apply afresh

One operational trap worth knowing: the verification steps have to be completed within 15 days of submitting Part B, failing which the application does not proceed to an ARN. An application started and left half-finished does not sit patiently waiting.

The 30-day trap — where the money is

This is the part that turns a scheduling question into a financial one.

Section 18(1)(a) entitles a newly registered person to input tax credit on inputs held in stock, and inputs contained in semi-finished and finished goods, as on the day immediately preceding the date from which liability arose.

But it is conditional:

  • It is available only where the application was made within 30 days of becoming liable.
  • It must be declared in Form ITC-01, filed within 30 days of registration being granted.
  • The declaration can be made only once.
  • Invoices can be up to one year old for inputs, and up to five years for capital goods in the situations where those qualify.

So a business that crosses the threshold in April, carries on trading, and gets round to registering in August faces three separate losses: the stock credit is gone, the tax on supplies made in the meantime is still payable, and interest runs on it.

The delay is usually thought of as a paperwork lapse with a late fee attached. On a business holding meaningful stock, the forfeited credit is frequently the largest number in the whole exercise — and it is unrecoverable, because ITC-01 can only be filed once and only within its window.

What you will need

  • PAN of the business and of promoters or partners
  • Aadhaar of the authorised signatory and promoters
  • Constitution proof — partnership deed, certificate of incorporation, or equivalent
  • Proof of principal place of business — ownership document, or rent agreement together with the owner's ownership proof and a no-objection letter
  • Bank account proof — cancelled cheque, statement or passbook page
  • Photographs of promoters and the authorised signatory
  • Authorisation letter or board resolution for the authorised signatory
  • Digital signature, where the entity is a company or LLP

The place-of-business documentation is where applications most often stall. A rent agreement without the landlord's ownership proof, an address that does not match the electricity bill, or a shared or virtual office without adequate supporting documents are the recurring causes of a REG-03 query.

Voluntary registration — when it is worth it

Section 25(3) allows registration below the threshold. It is worth considering where:

  • your customers are registered businesses who need the credit on what you supply them;
  • you are paying GST on your own inputs and would rather claim it than absorb it;
  • a marketplace or client requires a GSTIN as a condition of onboarding;
  • you expect to cross the threshold soon and would rather not deal with the stock-credit timing question later.

The cost is that compliance starts immediately and in full. Returns fall due every period whether or not you traded, late fees accrue on nil returns, and — since the three-year bar — unfiled returns can become permanently unfilable. Voluntary registration taken lightly is how a dormant registration turns into a demand years later.

What starts the day you are registered

Registration is the beginning of an obligation, not the end of a task:

  • Tax invoices must be issued in the prescribed form, with your GSTIN.
  • GSTR-1 and GSTR-3B fall due from the first period — monthly, or quarterly under QRMP where eligible.
  • ITC-01 should be filed within 30 days if you are claiming the stock credit.
  • Monthly reconciliation against GSTR-2B begins, because credit turns on what your suppliers report rather than on your invoices — see input tax credit and GSTR-2B.
  • Display of the registration certificate at the place of business, and the GSTIN on the signboard.

Where books also need to be set up rather than merely filed from, that sits alongside as accounting and bookkeeping.

Casual and non-resident taxable persons

A separate track under Section 27. Someone supplying occasionally in a state where they have no fixed place of business — an exhibition, a seasonal stall, a one-off contract — registers as a casual taxable person, for a limited validity, and must make an advance deposit of estimated tax at the time of applying. It is not the ordinary route and should not be treated as one.


Registration procedure and the biometric authentication rollout have been changing state by state, and thresholds turn on the nature and place of supply. This note sets out the general position; whether registration is required in a particular case, and from what date, should be confirmed against the facts before applying.

Frequently asked questions

How long do I have to apply once I become liable?

Thirty days from the date you become liable to register. That window matters for more than punctuality — applying within it is what preserves your entitlement to input tax credit on stock held at the time of registration under Section 18(1)(a). Apply later and the registration is still granted, but that credit is lost.

How long does registration take?

Where Aadhaar authentication is opted for and succeeds, the application is deemed approved within seven working days unless a notice is issued in that period. Where Aadhaar authentication is not opted for or fails, the case goes for physical verification of the place of business and approval can take up to around twenty-one working days.

What is biometric authentication and do I need to attend in person?

Where the application is flagged for it, the applicant is required to attend a GST Suvidha Kendra for biometric Aadhaar authentication and document verification. It has been rolled out state by state. Where it applies, the registration cannot progress until the visit is completed.

What happens if the officer raises a query?

A notice seeking clarification issues in Form REG-03 and is answered in Form REG-04, generally within seven working days. Queries commonly concern proof of the place of business, a mismatch in the constitution of business, or unclear ownership documents. An unanswered query results in rejection in REG-05, after which you must apply afresh.

Can I register voluntarily below the threshold?

Yes, under Section 25(3). It is worth doing where your customers are registered businesses who need the credit, where you need credit on your own inputs, or where a marketplace or client requires a GSTIN. The trade-off is that once registered, the full compliance cycle applies regardless of turnover — returns fall due whether or not you have any sales.

Do I need separate registration for each state?

Registration is state-wise. If you have a place of business in more than one state, each requires its own registration on the same PAN. Within a state, a single registration ordinarily covers the business, with the option of separate registrations for distinct places of business.

Registering for GST?

Send your turnover, what you supply and where you sell, along with your stock position. Whether registration is required, the correct date to apply from, and what credit can be preserved are worked out before the application goes in.

Related service: GST Registration & Returns