Section 40 closes a gap: a person who becomes liable to register is taxable from that date, though no return can be filed until registration is granted. Supplies of the interim period go into the first return.
Key points
- Under section 40 of the CGST Act, 2017 outward supplies made between the date of liability to register and the date registration is granted must be declared in the first return after registration.
- Revised tax invoices for those supplies may be issued within one month of the grant of registration (section 31(3)(a)).
The provisions
40First return
Statutory text
Every registered person who has made outward supplies in the period between the date on which he became liable to registration till the date on which registration has been granted shall declare the same in the first return furnished by him after grant of registration.
*Enforced w.e.f. 1st July, 2017.
Statutory text as published on the CBIC tax information portal, as on 03.10.2026; the numbered notes record each amendment. Official source
Common questions
- How are supplies before GST registration reported?
- Supplies made after becoming liable to register but before registration is granted are declared in the first return (section 40 CGST), and revised tax invoices may be issued within a month of registration.
Commentary and case notes checked against the judgments and CBIC sources on 04.10.2026.
What it means
If the application is made within thirty days of becoming liable, registration takes effect from the date of liability; otherwise from the date of grant (section 25, Rule 10). Either way, supplies of the gap period are reported in the first return, and revised invoices under section 31(3)(a) let registered customers take credit on them. Supplies made before the effective date of a late registration remain taxable and are recoverable with interest; the section does not excuse them.