Need for registration under CGST Act

[Lalitha Krishnamurthy]

A client (Individual) has income from Bank Fixed Deposits (which is exempt) and renting of commercial property to a registered entity (which is taxable on reverse charge basis). Though the aggregate income is more than Rs. 20 lakhs, he is not liable to pay tax under GST laws. Under the circumstances, is he required to register himself and file nil returns? Section 23(1)(a) of the CGST Act provides for exemption from registration to persons who are only engaged in making exempt supplies while Notification no. 5/2017 - Central Tax dated 19/06/2017, as amended by Notification no.24/2024 - Central Tax dated 09/10/2024 provides for exemption from registration to persons who are only engaged in supplies subject to tax on reverse charge basis. In our opinion, registration is not required when the provisions are read together; would be grateful if the experts could confirm this. Thank you.

AI Summary

GST registration exemption may apply where supplies are exclusively exempt or taxable to recipients under reverse charge.
Section 23(1)(a) exempts persons exclusively making exempt supplies from GST registration. A separate registration exemption applies to persons exclusively making supplies taxable under reverse charge. Where an individual receives exempt bank fixed-deposit income and makes commercial-property rental supplies on which the registered recipient pays GST under reverse charge, registration is considered unnecessary on a combined reading, despite aggregate income exceeding the registration threshold.