☐ Has CTP / NRTP applicability been identified? ☐ Has registration been planned 15-20 days before event? ☐ Has estimated tax liability been computed? ☐ Has REG-01 (CTP) or REG-09 (NRTP) been filed? ☐ Has advance tax deposit been made? ☐…
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☐ Has CTP / NRTP applicability been identified? ☐ Has registration been planned 15-20 days before event? ☐ Has estimated tax liability been computed? ☐ Has REG-01 (CTP) or REG-09 (NRTP) been filed? ☐ Has advance tax deposit been made? ☐…
Section 27 CTP / NRTP framework — checklist (19 items)
Section 27 CTP / NRTP framework — checklist (19 items)
☐ Has CTP / NRTP applicability been identified?
☐ Has registration been planned 15-20 days before event?
☐ Has estimated tax liability been computed?
☐ Has REG-01 (CTP) or REG-09 (NRTP) been filed?
☐ Has advance tax deposit been made?
☐ Has 90-day validity been tracked from effective date?
☐ For events beyond 90 days, has extension been planned?
☐ For extension, has additional deposit been made?
☐ Are supplies only after certificate issuance?
☐ Are tax invoices being issued under s. 31?
☐ Is tax being paid through electronic cash ledger?
☐ Have CTP / NRTP returns been filed?
☐ On completion, has refund framework been engaged?
☐ Has documentary trail been preserved?
☐ Has Mafatlal procedural-fairness framework been observed?
☐ Has Mohit Minerals constitutional framework been applied?
☐ Has Bharti Airtel substance-over-form discipline been applied?
☐ Has Vatika prospective-operation been applied?
☐ Has the file been reviewed for audit-defensibility?
Worked examples — five live scenarios
Example 1 — Trade fair CTP
Facts: Mumbai-based vendor participates in 10-day trade fair in Bangalore. Expected supplies Rs. 20 lakh (Karnataka GST 18%).
Analysis: CTP under s. 27. Estimated tax = Rs. 3.6 lakh. Advance deposit Rs. 3.6 lakh. REG-01 filed 15 days before fair. 90-day validity from effective date. Supplies during fair; tax paid through ledger.
Result: Standard CTP framework operative.
Example 2 — Foreign exhibitor NRTP
Facts: Foreign company exhibits at trade event in Delhi for 7 days. Expected sales Rs. 10 lakh (18% GST).
Analysis: NRTP under s. 27. REG-09 with passport + business documents. Estimated tax Rs. 1.8 lakh advance deposit. Indian representative for compliance. 90-day validity.
Result: NRTP framework operative.
Example 3 — Extension for extended event
Facts: CTP registered for 90-day fair. Event extended to 120 days due to demand.
Analysis: Extension under sub-s. (1) proviso — up to additional 90 days. Sufficient cause shown — operational extension. Additional advance deposit equivalent to estimated tax for 30-day extension.
Result: Extension granted; additional deposit framework.
Example 4 — Refund of excess deposit
Facts: NRTP completed event. Actual sales Rs. 7 lakh (tax Rs. 1.26 lakh). Advance deposit was Rs. 1.8 lakh. Excess Rs. 54,000.
Analysis: Excess deposit refundable under s. 54 framework. Refund application after event completion. Documentary trail of actual supplies + advance deposit.
Result: Refund of Rs. 54,000 framework operative.
Example 5 — Pre-certificate supply (non-compliant)
Facts: CTP made supplies before certificate issuance.
Analysis: Sub-s. (1) — supply only after certificate. Pre-certificate supplies non-compliant. Section 122 penalty framework + recovery under s. 73. Practitioner advice — strict timing discipline.
Result: Non-compliant; recovery + penalty framework engages.
Planning and litigation strategy
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Cross-references