☐ Has registration liability event been identified? ☐ Has 30-day application window been observed? ☐ Has PAN compliance been verified? ☐ Has Aadhaar authentication been coordinated? ☐ Have documentary proofs been compiled? ☐ For multiple…
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☐ Has registration liability event been identified? ☐ Has 30-day application window been observed? ☐ Has PAN compliance been verified? ☐ Has Aadhaar authentication been coordinated? ☐ Have documentary proofs been compiled? ☐ For multiple…
Section 25 registration procedure — checklist (19 items)
Section 25 registration procedure — checklist (19 items)
☐ Has registration liability event been identified?
☐ Has 30-day application window been observed?
☐ Has PAN compliance been verified?
☐ Has Aadhaar authentication been coordinated?
☐ Have documentary proofs been compiled?
☐ For multiple places in same State, has Rule 11 framework been considered?
☐ For multi-State, have separate State-wise registrations been planned?
☐ Has sub-s. (4) distinct-persons framework been understood?
☐ Has 7-day / 3-day deemed-grant tracking been done?
☐ For SEZ, has separate registration been planned?
☐ For UN / Embassy, has UIN framework been applied?
☐ For voluntary registration, has strategic evaluation been done?
☐ Has registration certificate REG-06 been received?
☐ For rejection, has procedural-fairness been verified?
☐ For suo motu (sub-s. (8)), has defence framework been built?
☐ Has Mohit Minerals constitutional framework been applied?
☐ Has Mafatlal procedural-fairness framework been observed?
☐ Has Whirlpool writ-jurisdiction framework been considered?
☐ Has the file been reviewed for audit-defensibility?
Worked examples — five live scenarios
Example 1 — Threshold breach registration
Facts: Service provider's turnover crosses Rs. 20 lakh on 15-Aug-2025.
Analysis: 30-day window — apply by 14-Sep-2025. FORM REG-01 + documents + Aadhaar authentication. On Aadhaar-authentication, deemed grant within 3 working days.
Result: Standard registration flow.
Example 2 — Multi-State operation
Facts: Entity expanding to 3 States (Delhi, Maharashtra, Karnataka).
Analysis: Sub-s. (4) distinct persons. Three separate registrations. Inter-State transactions between branches are supplies (IGST). ISD framework for centralised services (post-FA 2024 mandatory).
Result: Three State registrations + ISD coordination.
Example 3 — Voluntary registration for B2B
Facts: Small B2B service provider, turnover Rs. 15 lakh. Customers want ITC.
Analysis: Sub-s. (3) — voluntary registration. Once registered, full compliance. Customer claims ITC on supplies. Strategic for B2B operations.
Result: Voluntary registration facilitates ITC chain.
Example 4 — UN agency UIN
Facts: UN agency in India procures various goods / services for office operations.
Analysis: Sub-s. (9) — UIN issued. Refund on inward supplies above Rs. 5,000 invoice value via RFD-10 framework. GSTR-11 quarterly filing.
Result: UIN framework operational.
Example 5 — Deemed grant on official delay
Facts: Aadhaar-authenticated applicant filed REG-01 on 1-Aug-2025. Officer takes no action.
Analysis: Sub-s. (10) + Rule 9 — 3 working days for Aadhaar-authenticated. Officer's non-action by 4-Aug-2025 + grace = deemed grant. Practitioner discipline — track deemed-grant date; on deemed grant, system issues GSTIN.
Result: Deemed grant effective.
Planning and litigation strategy
Litigation defence
Cross-references