☐ Has aggregate turnover been computed PAN-wide? ☐ Has applicable threshold been determined (Rs. 20 / 10 / 40 lakh)? ☐ Has State-specific framework been verified? ☐ For exclusive goods suppliers, has Rs. 40 lakh applicability been…
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☐ Has aggregate turnover been computed PAN-wide? ☐ Has applicable threshold been determined (Rs. 20 / 10 / 40 lakh)? ☐ Has State-specific framework been verified? ☐ For exclusive goods suppliers, has Rs. 40 lakh applicability been…
Section 22 registration threshold — checklist (19 items)
Section 22 registration threshold — checklist (19 items)
☐ Has aggregate turnover been computed PAN-wide?
☐ Has applicable threshold been determined (Rs. 20 / 10 / 40 lakh)?
☐ Has State-specific framework been verified?
☐ For exclusive goods suppliers, has Rs. 40 lakh applicability been verified?
☐ Has Notification 10/2019-CT applicability been verified?
☐ For special-category State, has Notification 31/2018-CT been considered?
☐ Has aggregate turnover s. 2(6) definition been applied?
☐ Has FY-wise turnover monitoring been done?
☐ On breach, has registration within 30 days been planned?
☐ For going-concern transfer, has sub-s. (3) been applied?
☐ For M&A under HC/Tribunal, has sub-s. (4) been applied?
☐ Has coordination with composition scheme been done?
☐ Has voluntary registration consideration been made for B2B?
☐ For multi-State, has comprehensive registration been done?
☐ Has Mohit Minerals constitutional framework been applied?
☐ Has Mafatlal procedural-fairness framework been observed?
☐ Has Vatika prospective-operation been applied?
☐ Has audit-defensibility through threshold file been ensured?
☐ Has the file been reviewed for audit-defensibility?
Worked examples — five live scenarios
Example 1 — Rs. 40 lakh threshold (goods only)
Facts: Trader in Delhi, exclusive goods (textiles), FY 2024-25 turnover Rs. 30 lakh.
Analysis: Notification 10/2019-CT — Rs. 40 lakh for exclusive goods suppliers (Delhi covered). Turnover Rs. 30 lakh below threshold. No registration liability.
Result: Below Rs. 40 lakh threshold. Not liable.
Example 2 — Rs. 20 lakh general threshold (services)
Facts: Service provider in Mumbai, FY 2024-25 turnover Rs. 22 lakh.
Analysis: Services — Rs. 20 lakh threshold. Breached. Registration liable within 30 days of breach.
Result: Registration required.
Example 3 — Special-category Rs. 10 lakh
Facts: Service provider in Manipur, FY 2024-25 turnover Rs. 12 lakh.
Analysis: Manipur is special-category. Rs. 10 lakh threshold applies. Notification 31/2018-CT did not enhance Manipur. Threshold breached.
Result: Registration required.
Example 4 — Going-concern transfer
Facts: A acquires B's business as going concern on 1-Jul-2025. B's registration was operative.
Analysis: Sub-s. (3) — A liable from 1-Jul-2025. Within 30 days, A registers (if not already). B's ITC transferred via ITC-02 framework.
Result: Successor registration discipline.
Example 5 — Multi-State operations
Facts: Entity with PAN-wide turnover Rs. 50 lakh, distributed across Delhi (Rs. 15 lakh), Maharashtra (Rs. 20 lakh), Karnataka (Rs. 15 lakh).
Analysis: Aggregate Rs. 50 lakh exceeds Rs. 20 lakh threshold. Registration required in each State of supply (s. 25(4) distinct persons).
Result: Three State registrations (Delhi, Maharashtra, Karnataka).
Planning and litigation strategy
Litigation defence
Cross-references