Microlesson · 5-min read

Procedure of Registration [Section 25] — GSTIN, Where, When & How to Apply

# Section 25 — Procedure of Registration

## 1. GSTIN — GST Identification Number

GSTIN is a 15-character unique number assigned to every registered person, parallel to PAN in income tax.

### Structure

Position	Length	Content
1-2	2 digits	State Code (e.g., 27 for Maharashtra)
3-12	10 chars	PAN of the taxpayer
13	1 char	Entity code (number of registration per PAN in that state)
14	1 char	Fixed letter (default Z)
15	1 char	Check digit

> PAN is mandatory for registration. Exception: A Non-Resident Taxable Person (NRTP) can register based on passport.

## 2. Where to Apply

Registration is state-wise — only in States/UTs from where taxable supplies are made.
No centralised registration under GST.
One State, one registration by default; cannot cover multiple states with a single registration.
If a person has multiple places of business in the same State/UT, he may opt for either:
Single Registration: Declare one as PPoB and others as APoB, OR
Separate Registration: Get a separate GSTIN for each place of business.
SEZ vs Non-SEZ in same state: Separate registration is mandatory for the SEZ unit (even if in the same state).

## 3. When to Apply

Type of Person	When to Apply
Person liable under Section 22 or 24	Within 30 days from the date of becoming liable to register
Casual Taxable Person (CTP) / Non-Resident Taxable Person (NRTP)	At least 5 days prior to commencement of business

## 4. Effective Date of Registration

### Case A — Liable to register & applied within 30 days:

Effective date = Date on which he became liable to register.

### Case B — Liable to register but applied after 30 days:

Effective date = Date of grant of registration certificate.

### Case C — Voluntary Registration:

Effective date = Date of grant of registration certificate.

## 5. Step-by-Step Procedure (GST REG-01)

All persons apply in Form GST REG-01, except the following (separate forms apply):

Non-Resident Taxable Person
TDS Deductor / TCS Collector
Person supplying OIDAR services / Online Money Gaming from outside India

### Part-A

1. Declare PAN, State/UT.

2. PAN-linked mobile number and email captured from CBDT database.

3. PAN validation done from CBDT database via OTP.

4. Mobile and email validated by OTP.

5. A Temporary Reference Number (TRN) is generated and sent to applicant.

### Part-B

Using the TRN, applicant fills Part-B + uploads documents + does Aadhaar Authentication (AA) (optional).

CTPs additionally deposit advance tax at this stage.

### Acknowledgement & Routing to Proper Officer

Two paths depending on whether AA was opted for and successful:

#### Path 1: AA Successfully done within 15 days (or AA not opted but treated similarly)

No deficiency → Registration granted within 7 working days. If no action by officer, deemed registered from 7th day.
Deficiency → Notice issued within 7 working days → Applicant clarifies within 7 working days of notice → Officer either grants registration within 7 working days, or rejects. If no action, deemed registered from 7th working day after clarification.

#### Path 2: AA Not opted / AA Failed

Date of application = 15th day from submission (if AA failed within 15 days).
Physical examination of place of business / document verification required.
Registration granted within 30 days of application.
No deficiency → No action by 30th day → Deemed registered.
Deficiency → Notice within 30 days → Applicant clarifies within 7 working days → Officer grants within 7 working days or rejects.

## 6. Key Time Limits Snapshot

Event	Limit
Apply (normal)	Within 30 days of becoming liable
Apply (CTP/NRTP)	5 days before commencement
Officer's decision (with AA, no deficiency)	7 working days
Officer's decision (without AA / physical verification)	30 days
Notice for deficiency	Within 7 working days (AA path) / 30 days (non-AA path)
Applicant's clarification	7 working days from notice
ECO requiring TCS (special)	Registration within 3 working days

Worked example

### Example 1

Example 1 — Effective date when applied in time

Ron Ltd. became liable to register on 1st June and applied on 10th June (within 30 days). Registration certificate granted on 5th July.

Applied within 30 days → Effective date of registration = 1st June (date of becoming liable).

### Example 2

Example 2 — Effective date when application delayed

Ron Ltd. became liable to register on 1st June but applied only on 5th July (after 30 days). Certificate granted on 15th July.

Applied after 30 days → Effective date = 15th July (date of grant of certificate).

Consequence: For the gap from 1st June to 14th July, the company was a 'taxable person' but unregistered — liable for late fees/interest and ITC complications on missed input invoices.

### Example 3

Example 3 — Multiple places, same state

XYZ Ltd. has its head office in Mumbai (Maharashtra) and warehouses in Pune and Nashik (also Maharashtra). Options:

One GSTIN: Declare Mumbai as PPoB; Pune and Nashik as APoB, OR
Three GSTINs: One for each place of business.

If XYZ Ltd. also has a unit in SEZ at Navi Mumbai → Separate GSTIN mandatory for the SEZ unit.

### Example 4

Example 4 — Deemed registration

A Ltd. applied with Aadhaar Authentication. AA was successful on day 3. No deficiency was raised by the officer for 8 working days. On the 8th working day, A Ltd. is deemed registered automatically — the officer's silence past 7 working days creates deemed approval.

⚠️ Common exam mistakes

Believing that registration can cover multiple states — it's strictly state-wise.
Failing to take a separate registration for an SEZ unit even when it's in the same state as the main unit.
Missing the 30-day window — applying late changes the effective date to the grant date, causing tax/ITC issues for the gap period.
Confusing 'working days' (officer's response window) with 'calendar days' (application deadline).
Forgetting that a CTP must apply 5 days BEFORE commencement and deposit advance tax in Part-B.
Not realising that voluntary registration has effective date = grant date, never retrospective.
Trying to register a Non-Resident on PAN — passport-based registration is the correct route.
Overlooking the 'deemed registration' rule — officer's inaction after the prescribed period gives the applicant a deemed registration.

Bare-Act text Section 25 · CGST Act, 2017 · click to expand

Section 25 of the CGST Act, 2017 — Procedure for registration. (1) Every person who is liable to be registered under section 22 or section 24 shall apply for registration in every such State or Union territory in which he is so liable within thirty days from the date on which he becomes liable to registration, in such manner and subject to such conditions as may be prescribed. Provided that a casual taxable person or a non-resident taxable person shall apply for registration at least five days prior to the commencement of business. (4) A person who has obtained or is required to obtain more than one registration, whether in one State or Union territory or more than one State or Union territory shall, in respect of each such registration, be treated as distinct persons for the purposes of this Act. (6) Every person shall have a Permanent Account Number issued under the Income-tax Act, 1961 in order to be eligible for grant of registration: Provided that a person required to deduct tax under section 51 may have, in lieu of a Permanent Account Number, a Tax Deduction and Collection Account Number. (7) Notwithstanding anything contained in sub-section (6), a non-resident taxable person may be granted registration under sub-section (1) on the basis of such other documents as may be prescribed.

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