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28

CGST Act · Section 28

Amendment of registration

☐ Has the change event been identified? ☐ Has core / non-core categorisation been done? ☐ For non-core, has REG-14 been filed (automatic)? ☐ For core, has documentary support been prepared? ☐ Has REG-14 been filed within 15 days? ☐ Has…

Section 28 amendment compliance — checklist (19 items)

Section 28 amendment compliance — checklist (19 items)

☐ Has the change event been identified?

☐ Has core / non-core categorisation been done?

☐ For non-core, has REG-14 been filed (automatic)?

☐ For core, has documentary support been prepared?

☐ Has REG-14 been filed within 15 days?

☐ Has State / UT processing been monitored?

☐ Has Centre-State coordination through sub-s. (3) been considered?

☐ For rejection, has hearing opportunity been demanded?

☐ Has Mafatlal procedural-fairness framework been applied?

☐ For PAN-change, has fresh registration framework been initiated?

☐ Have internal records been updated post-amendment?

☐ Has documentary trail of amendment been preserved?

☐ Has Bharat Hi-Tech Builders natural-justice framework been applied?

☐ Has Mohit Minerals constitutional framework been applied?

☐ Has Vatika prospective-operation been applied?

☐ Has Bharti Airtel substance-over-form discipline been applied?

☐ Has annual compliance review been done?

☐ Has the file been reviewed for audit-defensibility?

☐ Has coordination with broader compliance framework been done?

Worked examples — five live scenarios

Example 1 — Non-core amendment

Facts: Authorised signatory's phone number changed. Filed REG-14 with new phone.

Analysis: Non-core amendment — phone is minor detail. Automatic update through Common Portal. No officer approval required.

Result: Automatic non-core amendment.

Example 2 — Core amendment with hearing

Facts: Principal place of business shifted from old address to new address. Filed REG-14 with documentary support (lease agreement, electricity bill).

Analysis: Core amendment — requires officer approval. Officer reviews documentary support. If rejection contemplated, hearing opportunity (second proviso). Approval issued via REG-15.

Result: Core amendment with procedural-fairness compliance.

Example 3 — PAN change (constitution change)

Facts: Proprietorship converted to private limited company. New PAN obtained.

Analysis: PAN-change cannot be amended under s. 28. Fresh registration under s. 25 required for private limited company. Existing proprietorship registration cancelled under s. 29. ITC transfer through ITC-02 (s. 18(3)) for going-concern transfer.

Result: New registration + ITC transfer framework.

Example 4 — Centre-State coordinated amendment

Facts: Principal place change approved at State / UT level on 1-Sep-2025.

Analysis: Sub-s. (3) — SGST/UTGST approval deemed CGST approval. Single decision binds both. Practitioner discipline — monitor State / UT decision; CGST coordination automatic.

Result: Coordinated amendment framework.

Example 5 — Rejection without hearing (procedural defect)

Facts: Amendment application rejected without hearing. Practitioner challenges.

Analysis: Second proviso — opportunity of hearing required for rejection. Procedural defect. Practitioner files writ — Mafatlal + Bharat Hi-Tech Builders procedural-fairness framework. Successful challenge → fresh hearing required.

Result: Procedural-fairness defence framework operative.

Planning and litigation strategy

  • • Build annual registration-particulars review SOP.
  • • For material changes, immediate REG-14 filing within 15 days.
  • • For core amendments, prepare documentary support proactively.
  • • Coordinate State-Centre processing.
  • • For PAN-change events, plan new-registration + cancellation framework.
  • • Apply Mafatlal procedural-fairness framework defensively.
  • • Build precedent file on s. 28 jurisprudence.
  • • Train compliance teams on amendment framework.
  • • Coordinate with broader compliance framework.
  • • For repeated changes, organisational SOP.
  • • Apply Vatika prospective-operation for amendments.
  • • Coordinate with State / UTGST parallel framework.
  • • Maintain readiness for amendment disputes.
  • • Apply Bharti Airtel substantive-accuracy discipline.
  • • Coordinate with broader compliance calendar.

Litigation defence

  • • For amendment-rejection challenges, plead Mafatlal procedural-fairness + Bharat Hi-Tech Builders natural justice.
  • • Use Whirlpool framework for writ jurisdiction.
  • • Plead Mohit Minerals constitutional framework.
  • • Apply Vatika prospective-operation.
  • • Use Bharti Airtel substance-over-form discipline.
  • • Apply Calcutta Discount Co. for jurisdictional discipline.
  • • Plead Modern Dental proportionality.
  • • Use Maneka Gandhi procedural-fairness framework.
  • • For Centre-State coordinated rejection, coordinated challenge framework.
  • • For PAN-change disputes, plead fresh-registration framework.
  • • Build precedent file on s. 28 jurisprudence.
  • • Coordinate with State / UTGST parallel framework.
  • • Maintain readiness for amendment litigation.
  • • Apply Dilip Kumar discipline where applicable.
  • • For non-core amendments, plead first-proviso automatic framework.
  • • For core amendments, plead documentary discipline.

Cross-references

  • • Section 18(3) (ITC transfer on M&A / constitution change)
  • • Section 22, 24 (Registration liability)
  • • Section 25 (Procedure)
  • • Section 26 (Deemed registration)
  • • Section 29 (Cancellation)
  • • Rule 19 (Amendment framework)
  • • FORM GST REG-14 (Amendment application)
  • • FORM GST REG-15 (Order of amendment)
  • • Section 9 (Levy framework)
  • • Section 16 (ITC eligibility)
  • • Section 22 (Persons liable for registration)
  • • Section 23 (Persons not liable)
  • • Section 24 (Compulsory registration)
  • • Section 25 (Procedure)
  • • Section 26 (Deemed registration)
  • • Section 27 (CTP / NRTP)
  • • Section 28 (Amendment)
  • • Section 29 (Cancellation / suspension)
  • • Section 30 (Revocation)
  • • Section 39 (Returns)
  • • Section 49 (Payment)
  • • Section 122 (Penalty)
  • • Section 161 (Rectification)
  • • Section 168 (Instructions)
  • • Article 246A, Constitution of India (concurrent legislative power)
  • • Article 14, Constitution of India (reasonableness)
  • • Article 19(1)(g), Constitution of India (right to carry on business)
  • • Article 21, Constitution of India (procedural due process)
  • • Article 226, Constitution of India (writ jurisdiction)
  • • Rules 8-26 (Registration framework)
  • • FORM GST REG-01 to REG-31 (Registration forms)
  • • Notification 10/2019-CT (Rs. 40 lakh threshold for goods-only suppliers)
  • • Notification 4/2017-CT (Common Portal)
  • • Mohit Minerals (2022) 10 SCC 700 (constitutional architecture)
  • • Vatika Township (2014) 367 ITR 466 (prospective operation)
  • • Mafatlal Industries (1997) 5 SCC 536 (procedural framework)
  • • Bharti Airtel v UoI (2021) 11 SCC 374 (substance over form)
  • • Whirlpool Corporation (1998) 8 SCC 1 (writ jurisdiction)
  • • Calcutta Discount Co. AIR 1961 SC 372 (jurisdictional limits)
  • • Modern Dental College (2016) 7 SCC 353 (proportionality)
  • • Maneka Gandhi (1978) 1 SCC 248 (procedural fairness)
  • • Dilip Kumar (2018) 9 SCC 1 (strict construction)
  • • Suguna Cutpiece (Madras HC 2022) 59 GSTL 73 (retrospective cancellation framework)