**Recent notifications — verify before relying** GST notification volume is high — late-fee waivers, return-date extensions, RCM scope changes, e-invoicing threshold revisions, and rate changes happen almost every quarter. Before relying on any number in this guide, check the latest notification on cbic-gst.gov.in/cgst-notification.html and the latest GSTN advisory at tutorial.gst.gov.in/downloads/news/. Specific items worth watching: annual GSTR-9 / 9C waiver thresholds (re-notified each year), e-invoicing reporting time limits, and HSN-reporting Table-12 validations on GSTR-1 (still being rolled out in phases).
When does registration become mandatory?
Source: Sections 22 and 24 of the CGST Act, 2017.
- **Goods (normal states)** — aggregate turnover crosses **Rs. 40 lakh** in a financial year.
- **Goods (special-category states with the Rs. 20 lakh threshold)** — Arunachal Pradesh, Manipur, Meghalaya, Mizoram, Nagaland, Puducherry, Sikkim, Telangana, Tripura, Uttarakhand.
- **Services (normal states)** — Rs. 20 lakh.
- **Services (special-category states with the Rs. 10 lakh threshold)** — Manipur, Mizoram, Nagaland, Tripura.
Section 24 overrides the threshold for: inter-State taxable supply of goods; casual taxable persons; persons liable to pay under reverse charge; non-resident taxable persons; persons required to deduct TDS / collect TCS; Input Service Distributors; e-commerce operators required to collect TCS; OIDAR service providers supplying from outside India to unregistered persons in India; and a few other notified categories. These need to register regardless of turnover.
Registration must be applied for within 30 days of becoming liable.
The monthly / quarterly return cycle
Source: GSTN portal user guides under tutorial.gst.gov.in.
- **GSTR-1** — Outward supplies. Monthly filers: due 11th of the next month. QRMP filers (PAN-based AATO up to Rs. 5 crore): due 13th of the month following the quarter, with optional IFF in months 1 and 2 of the quarter by 13th.
- **GSTR-3B** — Self-assessed summary with tax payment. Monthly filers: 20th. QRMP filers: 22nd (Category-X states) or 24th (Category-Y states) of the month following the quarter.
- **GSTR-2A** — Auto-drafted, dynamic, informational view of inward supplies based on suppliers' GSTR-1.
- **GSTR-2B** — Auto-drafted, static ITC statement generated on the 14th of each month and used to determine eligible ITC.
Reconcile GSTR-2B against the purchase register monthly — not annually. The single largest source of GST scrutiny we see is the unexplained gap between GSTR-2B and the ITC actually claimed in GSTR-3B.
E-invoicing — current threshold
Source: Rule 48(4) read with Notification 10/2023-CT dated 10 May 2023.
E-invoicing on the Invoice Registration Portal (IRP) is mandatory for taxpayers whose aggregate turnover crossed Rs. 5 crore in any FY from 2017-18 onwards (applicable to B2B invoices, credit notes, debit notes and exports). Excluded classes include SEZ units (developers are covered), banks / FIs / NBFCs, insurers, GTAs in road transport, passenger-transport providers, multiplex cinematograph admissions, and Government departments / local authorities.
A 30-day reporting time limit on the IRP applies to taxpayers with AATO of Rs. 10 crore or more (effective 1 April 2025, per GSTN advisory). Confirm the latest position on einvoice1.gst.gov.in.
E-way bills
Source: Rule 138 of CGST Rules, 2017 + Notification 94/2020-CT dated 22 December 2020.
Generation is mandatory whenever a registered person causes movement of goods of consignment value exceeding Rs. 50,000 (states may notify higher intra-state thresholds for specific cases).
Validity for normal cargo: 1 day for every 200 km (changed from 100 km by Notification 94/2020-CT — the older CBIC FAQ still says 100 km, which is incorrect; cite the notification). For Over-Dimensional Cargo / multimodal with a vessel leg: 1 day per 20 km.
Reverse Charge Mechanism (RCM) — major categories
Source: Notification 4/2017-CT(Rate) for goods and Notification 13/2017-CT(Rate) for services.
Goods under Section 9(3): cashew nuts (un-shelled), bidi wrapper leaves, tobacco leaves, silk yarn from raw silk/cocoons, raw cotton, supply of lottery by State authorities, used / seized / waste goods from Govt to registered person, priority sector lending certificates.
Services under Section 9(3) — frequently triggered:
- Goods Transport Agency (other than the 6% forward-charge variant) supplying to factory / society / registered person / body corporate / partnership firm
- Legal services from advocate / law firm to a business entity above the registration threshold
- Director's services to the company / body corporate
- Renting of immovable property by Government to a registered person
- Renting of a residential dwelling to a registered person (added by Notification 5/2022-CT(R) w.e.f. 18 July 2022 — not in the CBIC consolidated PDF; cite the notification)
- Sponsorship services to a body corporate or partnership firm
- Insurance agent commission, recovery agent services to banks / FIs / NBFCs
- Author / music composer / artist transferring copyright to publisher / music company / producer
Section 9(4) (purchases from unregistered persons) is currently restricted to notified classes (most operationally relevant: real-estate promoters' shortfall against the 80% registered-procurement requirement, and any procurement of cement by a project promoter from an unregistered supplier).
Annual return — GSTR-9 and 9C
Source: GSTN advisories at tutorial.gst.gov.in and CBIC circulars.
- **GSTR-9 (annual return)** — Mandatory for all normal registered persons including SEZ units / developers. **Optional** for those with AATO up to Rs. 2 crore for the year (the Department has consistently re-notified this waiver — verify the FY-specific notification).
- **GSTR-9C (reconciliation statement)** — Mandatory if AATO crosses Rs. 5 crore for the year. Self-certified (CA / CMA certification was dropped from FY 2020-21 onwards by Finance Act, 2021).
- **Due date for FY 2024-25:** 31 December 2025, subject to extension.
Circular 246/03/2025-GST clarified that late fee under Section 47(2) accrues on the entire annual return, so the clock keeps running until both 9 and 9C (where required) are filed.
Late fees and interest
- **GSTR-1 / 3B late fee** under Section 47, capped by turnover slab: Rs. 2,000 for AATO ≤ Rs. 1.5 cr, Rs. 5,000 for Rs. 1.5–5 cr, Rs. 10,000 for above Rs. 5 cr (statutory cap).
- **GSTR-9 / 9C late fee** under Section 47(2), rationalised by Notification 7/2023-CT: Rs. 50 / 100 / 200 per day depending on turnover, capped at 0.04% / 0.04% / 0.5% of turnover in State / UT.
- **Interest on delayed tax** under Section 50: 18% p.a. on the net cash component of the self-assessed tax declared in delayed GSTR-3B (per the proviso to Section 50(1) inserted by Finance Act, 2021 with retrospective effect from 1 July 2017).
- **Interest on wrongly availed and utilised ITC** under Section 50(3) read with Rule 88B: 18% p.a. (reduced from 24% by Notification 14/2022-CT). Interest only when wrongly availed ITC is actually **utilised**.
HSN / SAC reporting on invoices
Source: Notification 78/2020-CT dated 15 October 2020.
- AATO up to Rs. 5 crore: minimum **4-digit HSN** on B2B invoices; optional on B2C.
- AATO above Rs. 5 crore: minimum **6-digit HSN** on all invoices (B2B and B2C).
- 8-digit HSN is mandatory for specified notified chemicals and certain other categories.
Engaging us for GST work
Our practice handles registrations, monthly / quarterly return filing on a documented compliance calendar, GSTR-9 / 9C with full reconciliation working papers, refund claims (export-LUT, inverted-duty), and representation before authorities up to GST Tribunal. If you would like a one-time GST health check or to move your compliance to our team, please reach out via the contact page.