☐ Has single REG-01 application been filed? ☐ Has State / UT-level processing been monitored? ☐ Has 7-day / 3-day CGST timeline been tracked? ☐ Has documentary trail of application + decision timing been preserved? ☐ Has State / UT grant…
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☐ Has single REG-01 application been filed? ☐ Has State / UT-level processing been monitored? ☐ Has 7-day / 3-day CGST timeline been tracked? ☐ Has documentary trail of application + decision timing been preserved? ☐ Has State / UT grant…
Section 26 single-application framework — checklist (19 items)
Section 26 single — application framework — checklist (19 items)
☐ Has single REG-01 application been filed?
☐ Has State / UT-level processing been monitored?
☐ Has 7-day / 3-day CGST timeline been tracked?
☐ Has documentary trail of application + decision timing been preserved?
☐ Has State / UT grant triggered CGST deemed grant?
☐ If rejection, has Article 226 writ framework been considered?
☐ Has Whirlpool framework been applied?
☐ Has Mohit Minerals cooperative-federalism framework been applied?
☐ Has Mafatlal procedural-fairness framework been observed?
☐ Has Bharat Hi-Tech Builders natural-justice framework been applied?
☐ Has Vatika prospective-operation been applied?
☐ Has Bharti Airtel substance-over-form discipline been applied?
☐ For UIN, has parallel framework been applied?
☐ Has Centre-State operational coordination been observed?
☐ For rejection challenge, has coordinated framework been built?
☐ Has audit-trail of decision been preserved?
☐ Has Calcutta Discount Co. jurisdictional framework been considered?
☐ Has Modern Dental proportionality been applied?
☐ Has the file been reviewed for audit-defensibility?
Worked examples — five live scenarios
Example 1 — Standard registration flow
Facts: Taxpayer files REG-01 on 1-Aug-2025 with Aadhaar authentication. State officer grants on 4-Aug-2025.
Analysis: State grant operative. CGST grant deemed under sub-s. (1) — CGST officer non-rejection within 3 working days completes deeming.
Result: CGST registration deemed granted.
Example 2 — State rejection coordinated CGST rejection
Facts: State officer rejects application on 10-Aug-2025 citing inadequate documents.
Analysis: Sub-s. (2) non-obstante override — CGST rejection deemed. Practitioner files writ under Article 226 challenging State rejection. Successful challenge → State grant → CGST deemed grant.
Result: Coordinated rejection. Coordinated challenge required.
Example 3 — UN agency UIN
Facts: UN agency applies for UIN. Delhi State authority grants.
Analysis: Sub-s. (1) applies to UIN. State UIN grant deemed CGST UIN grant. RFD-10 refund framework operates.
Result: UIN coordinated framework.
Example 4 — Centre-side deemed grant under s. 25(10)
Facts: Aadhaar-authenticated REG-01 on 1-Aug. State officer takes no action by 8-Aug.
Analysis: Two-track — s. 25(10) CGST deemed grant after 3 working days; s. 26(1) CGST deemed grant on State grant. In this case, State has not granted. s. 25(10) operates for CGST. But registration cannot be only-CGST; system operationally treats as joint deemed grant under cooperative framework.
Result: Operational coordination ensures joint deemed grant.
Example 5 — Rejection with natural-justice breach
Facts: State officer rejects without reasons or opportunity. Sub-s. (2) triggers CGST rejection.
Analysis: Practitioner files writ — Bharat Hi-Tech Builders framework + Mafatlal procedural-fairness. Successful challenge → fresh decision required.
Result: Procedural-fairness defence framework. Coordinated rejection challenged through writ.
Planning and litigation strategy
Litigation defence
Cross-references