# Accounts and Records — Section 35

## Where Must Records Be Kept?

Every registered person must maintain books of accounts and records at every place of business — both the Principal Place of Business (PPoB) and every Additional Place of Business (APoB).

For records relating to a particular APoB, those records must physically be kept at that APoB.

## Common Records (Every Registered Person)

Every registered person must keep a true and correct account of:

Production / manufacture of goods
Inward and outward supplies of goods or services
Stock of goods
Input tax credit availed
Output tax payable and paid

> Exception: A composition taxpayer is NOT required to maintain these specific records.

## Additional Records by Specific Persons

Person	Extra Records Required
Manufacturer	Monthly production accounts — quantitative details of raw materials, input services used, goods produced (incl. waste & by-products).
Service Provider	Quantitative details of goods used in providing service, input services utilised, services supplied.
Agent	Authorisation received from each principal; particulars (description, value, quantity) of goods/services received & supplied on behalf of each principal; account statements issued to each principal; tax paid.
Works Contractor	Names & addresses of persons for whom work is executed; details of goods/services received & utilised; payment details; names & addresses of suppliers.
Warehouse owner / Operator / Transporter	Period-wise book of accounts (item-wise & owner-wise) to facilitate physical verification; for transporters, GSTIN of consignor and consignee. If not registered, must obtain a unique enrolment number.
Custodian / Clearing & Forwarding Agent	Details of goods handled on behalf of each registered person; furnish on demand to proper officer.

## Consequence of Failing to Account

If a registered person fails to account for any goods or services, the proper officer shall determine the tax payable as if such goods/services have been supplied. This is a deeming provision — silence is treated as suppressed supply.

Worked example

### Example 1

Example — Unregistered Transporter

Mr. X runs a small transport business and is not liable for GST registration. He still moves goods of registered consignors. Under Section 35, he must:

Maintain records of all goods transported, delivered, and stored, with GSTIN of consignor and consignee.
Obtain a unique enrolment number on the GST portal to fulfil this obligation, even without registration.

⚠️ Common exam mistakes

Maintaining all records only at PPoB — records of each APoB must be kept at that APoB.
Assuming composition taxpayers must keep the same detailed records — they are exempt from the common-record list under Section 35.
Treating unregistered transporters and warehouse-keepers as outside Section 35 — they must register for a unique enrolment number.
Overlooking that an agent must keep principal-wise records, not just consolidated ones.
Forgetting the deeming consequence — unaccounted goods are treated as supplied and demand is raised.

Bare-Act text Section 35(1) · CGST Act, 2017 · click to expand

Every registered person shall keep and maintain, at his principal place of business, as mentioned in the certificate of registration, a true and correct account of — (a) production or manufacture of goods; (b) inward and outward supply of goods or services or both; (c) stock of goods; (d) input tax credit availed; (e) output tax payable and paid; and (f) such other particulars as may be prescribed.

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Accounts and Records to be Maintained — Section 35

Worked example

⚠️ Common exam mistakes