REGISTRATION

[SUDHIRKUMAR SHAH]

COMPANY IS REGISTERED IN GUJARAT HAVING GST REGISTRATION PROVIDING SERVICES EXEMPTED AS WELL AS TAXABLE

NOW IT WANT TO START ONE NEW OFFICE PROVIDING ONLY EXEMPTED SERVICE IN RAJASTHAN.

WHETHER NEW OFFICE WILL BE EXEMPTED FROM GETTING REGISTRATION UNDER SECTION 23.

[Ganeshan Kalyani]

If there is only supply of exempted service no registration under GST is required. However, if you are availing any service which are covered under reverse charge then registration is required.

[KASTURI SETHI]

New registration is not required in terms of Section 23(1)(a) of CGST Act. I also agree with Sh.Ganeshan Kalyani Ji.

[YAGAY andSUN]

We are amenable with the replies of our experts. From Rajasthan Office you would have to issue Bill of Supply for providing exempted services to your service recipients.

[Alkesh Jani]

Dear Experts,

In the instant the company is already supplying taxable as well as Exempted Service. If we pursue the definition of "Aggregate Turnover" given at Section 2(6) of the Act, it says includes all supplies except RCM and also includes "Exempt supply" and on same PAN all India basis.

Section 23 says "Every Supplier.... if his aggregate turnover in a financial year exceeds twenty lakh rupees."

If same PAN is to be considered than it means taxable and exempted both, Section 23(a) is for Exempted supply only.

Therefore, I am of the view that separate registration may be obtained for Rajasthan and can show exempted supply in their returns.

[HariKishan Bhonagiri]

I subscribe the views of Mr. jain

AI Summary

GST registration for exempt supplies may not be required, but PAN-level aggregate turnover and reverse charge can trigger registration. No separate GST registration is normally required for a new office that makes only exempt supplies and should issue a bill of supply; registration becomes necessary if the office receives services subject to reverse charge. Registration obligations may nonetheless be triggered by PAN-level aggregate turnover, because aggregate turnover includes exempt supplies, so where PAN-wide turnover exceeds the statutory threshold registration under Section 23 can apply. Practitioners were divided, with most advising no registration for exempt-only operations and one recommending separate registration and return reporting for the Rajasthan office.