## Section 25(3) — Voluntary Registration

A person not liable for registration u/s 22 or 24 may opt for voluntary registration. Once registered, all provisions of the Act apply — including payment of tax — irrespective of turnover being below the threshold.

## Section 25(4) & (5) — Distinct Persons / Establishments of Distinct Persons

Sec 25(4): A person with multiple registrations (in one or more States/UTs) is treated as distinct persons for each registration.
Sec 25(5): Where a person who has obtained / is required to obtain registration in one State/UT also has an establishment in another State/UT, the establishments are treated as establishments of distinct persons.

Consequence: Supplies between such establishments are taxable supplies even within the same legal entity.

## Section 25(6) & (7) — PAN Requirement

PAN issued under the Income-tax Act, 1961 is mandatory for obtaining GST registration.
Exception: A Non-Resident Taxable Person (NRTP) may be granted registration on the basis of other prescribed documents (e.g., passport).

Worked example

### Example 1

Example (Voluntary): Ms. R runs a boutique in Pune with turnover ₹15 lakh — below threshold. To claim ITC and supply to corporates wanting GST invoices, she registers voluntarily. She must now charge GST and comply with all provisions.

### Example 2

Example (Distinct persons): ABC Pvt Ltd has registrations in Delhi and Haryana. Stock transfer from Delhi office to Haryana office is a taxable supply between distinct persons — IGST applies.

### Example 3

Example (NRTP): A UK consultant coming to India for a 3-month assignment cannot obtain PAN immediately. He may register as NRTP using his passport.

⚠️ Common exam mistakes

Believing voluntary registrants can avoid paying tax until they cross the threshold — once registered, full compliance is required.
Treating intra-entity branch transfers as non-supplies — they are taxable between distinct persons.
Assuming NRTP also needs PAN — they don't; other prescribed documents suffice.

Bare-Act text Section 25(3) to 25(7) of CGST Act, 2017 · CGST Act, 2017 · click to expand

Section 25(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.

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Section 25(3), (4), (5), (6) & (7) — Voluntary Registration, Distinct Persons, PAN

Worked example

⚠️ Common exam mistakes