Multiple GST Registrations under a PAN within the State / UT

[Law stated in this post pertains to the period effective February 01, 2019. For the period July 01, 2017 till January 31, 2019, the concept of 'business vertical' was in vogue.]

Certain registered taxpayers may have multiple places of business within the same State / Union Territory (UT). Such taxpayers may apply for a separate GST registration for each such place of business under the same Permanent Account Number (PAN), if required. Among others, such requirement may be triggered where assessee deals with exempt goods / services in one place of business and taxable goods / services in another place of business, to minimise the reversal of ineligible common credit.

PLACE OF BUSINESS - MEANING

At the outset, it is important to understand the term ‘place of business’. This is defined in an inclusive manner under Section 2(85) of the CGST Act. It includes any of the following:

  • a place from where business is ordinarily carried on;
  • a warehouse, godown or any other place where a taxable person stores his goods;
  • any place where a taxable person supplies goods / services;
  • any place where a taxable person receives goods / services;
  • a place where a taxable person maintains his books of account;
  • a place where a taxable person is engaged in business through an agent (by whatever name called).

PROCEDURE

Application should be filed vide Form GST REG-01 in the GST Common Portal (www.gst.gov.in) to obtain separate registration for a place of business. In the author’s view, such application should state the reason to obtain registration under Table 14(xiv) and specify the existing GST registration number under Table 15 thereof.

CONDITIONS

Vide Rule 11(1) of CGST Rules, if all the following conditions are satisfied, the registered person shall be granted a separate registration for each place of business:

  • Such person should have more than one ‘place of business’, i.e., in the State / UT in which he has applied for registration;
  • Such person should pay GST either under the composition scheme for all his places of business (or) under the regular scheme for all his places of business;
  • Tax invoice / bill of supply should be issued for supply of goods / services between the registered places of business of such person;
  • GST should be paid on taxable supply of goods / services between the registered places of business of such person.

From the first condition, it can be inferred that a registered person (having only one place of business) cannot obtain more than one registration.

Also, if any registered place of business becomes ineligible to pay GST under the composition scheme, all other registered places of business of such person will become ineligible to pay GST under the composition scheme.