Section 24 states that person who shall be compulsorily required to be registered under this Act without applying threshold limit.

Section 24 contains

Notwithstanding anything contained in section 22(1)

As per section 22(1), a supplier is liable to be registered only if his aggregate turnover in a FY exceeds the applicable threshold limit.

However, section 24 provides that a supplier is mandatorily required to obtain registration even though his aggregate turnover does not exceed the applicable threshold limit.

Following categories of persons shall be compulsorily required to be registered under this Act unless they are exempted u/s 23(2) by notification

Section 24(i) persons making any inter-State taxable supply

Section 24(i) requires compulsory registration of person who is making any inter-state taxable supply of goods or services even if his aggregate turnover does not exceed threshold limit.

However, following exemptions from registration were given u/s 23(2)

Question & Answer

Refer Notification No. 10/2017-Integrated Tax dt. 13-10-2017

Ex

Dhola & Co., located in Delhi, is engaged in supply of taxable goods in the neighbouring States of Punjab and Haryana.

Its aggregate turnover in current FY is Rs.10 lakh. Since it is engaged in making inter-State taxable supply of goods, it is required to register mandatorily under GST irrespective of its aggregate turnover.

However, if in the above case, Dhola & Co. is engaged in inter- State supply of taxable services instead of goods, it will be eligible for exemption from registration till its aggregate turnover does not exceed Rs.20 lakh.

Question & Answer

Refer Notification No. 07/2017-Integrated Tax dt. 14-09-2017

Question & Answer

Refer Notification No. 03/2018-Integrated Tax dt. 22-10-2018

Ex

Ariza Pvt. Ltd., located in Madhya Pradesh, is a supplier of taxable and notified handicraft goods. It supplies these goods in the neighbouring States of Uttar Pradesh and Orissa. Its aggregate turnover in the month of April is Rs.15 lakh.

Although Ariza Pvt. Ltd. is engaged in making inter-State supplies of taxable goods, it is not liable to obtain registration till its aggregate turnover does not exceed Rs.20 lakh as it has availed the exemption from registration under Notification No. 03/2018 IT

Section 24(ii) casual taxable persons making taxable supply

Section 24(ii) requires compulsory registration of CTP who is making taxable supplies, even if his aggregate turnover does not exceed threshold limit.

However, following exemptions from registration have been provided u/s 23(2)

Refer Section 2(20) for meaning of “Casual Taxable Person”

Question & Answer

Notification No. 56/2018-Central Tax dt. 23-10-2018

However, vide above notification, a threshold limit of Rs.20 lakh (Rs.10 lakh in case of specified Special Category States) is available for registration to a casual taxable person:

(i) who is making inter-State taxable supplies of notified handicraft goods and notified hand-made goods,

(ii) whose aggregate turnover should be less than threshold limit, and

(iii) who has obtained a PAN and

(iv) who has generated an e-way bill.

Question & Answer

Section 24(iii) persons who are required to pay tax under reverse charge

Section 24(iii) requires compulsory registration of person who is required to pay tax under RCM on inward supplies, even if his aggregate turnover does not exceed threshold limit.

No threshold limit of AT will apply to person who is required to pay Tax under RCM u/s 9(3).

Such Person must be registered even if there are no outward supplies.

Refer Notification  No. 05/2017-Central Tax dt. 19-06-2017

As per above notification, following person is exempt from registration on satisfying all conditions

a) Persons is making only supplies on which tax is to be paid by recipient under RCM u/s 9(3)

b) No other supplies can be made by him

c) He must 

Ex

Manikaran Transporters is a GTA engaged exclusively in supplying GTA services liable to tax under reverse charge [since tax is beng paid on GTA services @ 5% in the given case].

Thus, it is exempt from registration as it is engaged exclusively in making supplies, tax on which is liable to be paid on reverse charge basis.

Further, Manikaran Transporters supplies said service to Diwakar Manufacturing Pvt. Ltd. whose aggregate turnover does not exceed the applicable threshold limit.

However, since Diwakar Manufacturing Pvt. Ltd. has to pay tax on GTA services [@ 5%] under reverse charge, it is required to obtain registration mandatorily irrespective of its aggregate turnover.

Question & Answer

Section 24(iv) person who are required to pay tax u/s 9(5)

ECO who is required to pay tax u/s 9(5) for notified supply of services, then they must be registered without applying threshold limit.

Refer Section 2(45) for meaning of “electronic commerce operator”

Section 24(v) non-resident taxable persons making taxable supply;

If NRTP is making any taxable supply, then it must be registered without applying threshold limit.

Refer Section 2(77) for meaning of non-resident taxable persons

Section 24(vi) persons who are required to deduct tax u/s 51,

whether or not separately registered under this Act

Persons who are required to deduct tax u/s 51, must be registered without applying Threshold Limit.

Section 24(vii) persons who make taxable supply of goods or services or both

on behalf of other taxable persons

whether as an agent or otherwise

Agent of taxable person must be registered without applying threshold limit.

Refer Section 2(5) for meaning of “agent”

Clearing and forwarding (C&F) Agent receives the goods on behalf of the principal. Subsequently he supplies goods to the customer as an agent of the principal. He maintains the stock and report to the principal. If so such an agent shall be liable to obtain the registration compulsorily irrespective of the aggregate turnover of such agent.

Question & Answer

Section 24(viii) Input Service Distributor, whether or not separately registered under this Act

ISD must be registered without applying threshold limit.

ISD does not make any outward supplies.

Refer Section 2(61) for meaning of “input service distributor”

Section 24(ix)

Without applying threshold limit, there is compulsory requirement of registration of

persons who supply goods or services or both, other than supplies specified u/s 9(5)

through such ECO who is required to collect TCS u/s 52.

However, following exemptions have been provided u/s 23(2) from compulsory registration

Refer Notification No. 65/2017-Central Tax dt. 15-11-2017

As per above notification, following person is exempt from registration on satisfying all conditions

a) Persons making supplies of services, other than supplies specified u/s 9(5)

b) Supply of services must be made through ECO who is required to collect Tax u/s 52

c) His AT < Rs.20/10 lacs 

Question & Answer

Refer Notification No. 34/2023-Central Tax dt. 04-08-2023

Persons having an aggregate turnover in the preceding and current FY not exceeding threshold limit as specified in section 22(1) and

he is making supplies of goods through an ECO who is required to collect TCS u/s 52

then he is exempted from obtaining registration, subject to the following conditions, namely:

(i) he shall not make any inter-State supply of goods;

(ii) he shall not make supply of goods through ECO in more than one State/UT;

(iii) he shall be required to have a PAN issued under the Income Tax Act,;

(iv) he shall, before making any supply of goods through ECO, declare on the common portal their PAN, address of their place of business and the State/UT in which such persons seek to make such supply, which shall be subjected to validation on the common portal;

(v) He has been granted an enrolment number on the common portal on successful validation of the PAN;

(vi) he shall not be granted more than one enrolment number in a State/UT;

(vii) no supply of goods shall be made by such persons through ECO unless such persons have been granted an enrolment number on the common portal; and

(viii) where such persons are subsequently granted registration u/s 25, the enrolment number shall cease to be valid from the effective date of registration.

Question & Answer

Section 24(x)

Every ECO [1][who is required to collect tax at source u/s 52]

Every ECO who is required to collect tax at source u/s 52 must be registered without applying any threshold limit.

Section 24(xi)

every person supplying online information and database access or retrieval services from a place outside India to a person in India, other than a registered person

Person supplying OIDAR from a place outside India must be registered if he is supplying said services to an Un registered person in India.

Refer Section 2(17) of IGST Act for meaning of “OIDAR” services

Section 24(xii)

such other person or class of persons as may be notified by the Government

Yet no such other person has been notified by the government.

Question & Answer