☐ Has transaction type been identified? ☐ Has s. 24 category applicability been verified? ☐ For inter-State, has Notification 10/2017-IT relief been considered? ☐ For CTP / NRTP, has s. 27 framework been applied? ☐ For RCM, has compulsory…
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☐ Has transaction type been identified? ☐ Has s. 24 category applicability been verified? ☐ For inter-State, has Notification 10/2017-IT relief been considered? ☐ For CTP / NRTP, has s. 27 framework been applied? ☐ For RCM, has compulsory…
Section 24 compulsory registration — checklist (19 items)
Section 24 compulsory registration — checklist (19 items)
☐ Has transaction type been identified?
☐ Has s. 24 category applicability been verified?
☐ For inter-State, has Notification 10/2017-IT relief been considered?
☐ For CTP / NRTP, has s. 27 framework been applied?
☐ For RCM, has compulsory registration been ensured?
☐ For ECO (s. 9(5)), has category (iv) been applied?
☐ For ECO (s. 52 TCS), has categories (ix) + (x) been applied?
☐ For TDS deductors, has category (vi) been applied?
☐ For ISD (post-FA 2024), has category (viii) mandatory framework been applied?
☐ For agents, has category (vii) been applied?
☐ For OIDAR from outside India, has category (xi) been applied?
☐ Has Notification under category (xii) been tracked?
☐ Has coordination with s. 22 / 23 been done?
☐ Has Mohit Minerals constitutional framework been applied?
☐ Has Mafatlal procedural-fairness framework been observed?
☐ Has Vatika prospective-operation been applied?
☐ Has Bharti Airtel substance-over-form discipline been applied?
☐ Has Dilip Kumar strict-construction been considered?
☐ Has the file been reviewed for audit-defensibility?
Worked examples — five live scenarios
Example 1 — Inter-State goods supplier
Facts: Trader in Maharashtra supplies goods inter-State (to Karnataka). Turnover Rs. 5 lakh.
Analysis: Section 24(i) compulsory. Notification 10/2017-IT relief is service-specific. Goods inter-State supplier always registered.
Result: Registration required regardless of turnover.
Example 2 — Inter-State service supplier under Rs. 20 lakh
Facts: Consultant in Delhi provides services to clients in Mumbai (inter-State). Aggregate turnover Rs. 18 lakh.
Analysis: Notification 10/2017-IT — service suppliers up to Rs. 20 lakh exempted from s. 24(i). Practitioner discipline — verify Notification operative. Aggregate turnover monitored.
Result: Exempted under Notification 10/2017-IT.
Example 3 — Casual taxable person at trade fair
Facts: Vendor from UP participates in trade fair in Delhi for 7 days. Plans to sell Rs. 2 lakh worth.
Analysis: Section 24(ii) — CTP. Compulsory registration prior to commencement. Section 27 — 90-day validity + advance tax deposit.
Result: CTP registration required.
Example 4 — ISD post-FA 2024
Facts: Multi-State entity. Central office (Delhi) receives audit services for distribution to operational GSTINs.
Analysis: Section 24(viii) + FA 2024 s. 20 mandatory ISD framework. Post-1-Apr-2025, ISD registration mandatory at Delhi.
Result: Mandatory ISD registration.
Example 5 — Foreign OIDAR supplier
Facts: Foreign software company supplies online services to Indian individual users.
Analysis: Section 24(xi) — OIDAR from outside India to unregistered Indian. Compulsory registration. Framework — Indian representative; OIDAR compliance.
Result: Compulsory registration via Indian representative.
Planning and litigation strategy
Litigation defence
Cross-references