Section 139 moved existing taxpayers into GST without fresh applications: anyone registered under the old laws with a valid PAN received a provisional registration on 1 July 2017.
Key points
- Under section 139(1) of the CGST Act, 2017 every person registered under an existing law with a valid PAN was issued a provisional registration certificate from the appointed day (01.07.2017).
- The final certificate followed on furnishing prescribed information (section 139(2), Rule 24); a provisional registration cancelled on the person's application is deemed never issued (section 139(3)).
The provisions
139(1)–(3)Migration of existing taxpayers
Statutory text
(1) On and from the appointed day, every person registered under any of the existing laws and having a valid Permanent Account Number shall be issued a certificate of registration on provisional basis, subject to such conditions and in such form and manner as may be prescribed, which unless replaced by a final certificate of registration under sub-section (2), shall be liable to be cancelled if the conditions so prescribed are not complied with.
(2) The final certificate of registration shall be granted in such form and manner and subject to such conditions as may be prescribed.
(3) The certificate of registration issued to a person under sub-section (1) shall be deemed to have not been issued if the said registration is cancelled in pursuance of an application filed by such person that he was not liable to registration under section 22 or section 24.
*Enforced w.e.f. 22nd June, 2017.
- Rule 24, CGST Rules
Statutory text as published on the CBIC tax information portal, as on 03.10.2026; the numbered notes record each amendment. Official source
Common questions
- How did existing taxpayers move to GST?
- Under section 139 of the CGST Act they received provisional GST registration from 01.07.2017 and final registration on furnishing the prescribed information.
Commentary and case notes checked against the judgments and CBIC sources on 04.10.2026.
What it means
Migration closed long ago, but problems with incomplete migration were later addressed through portal reopening and the transitional credit relief in section 140; see Filco Trade Centre there.