GST Section 24: Compulsory Registration Rules, Categories and Latest Amendments Explained

Section 24 of the CGST Act, 2017 mandates compulsory GST registration for specific categories of persons, regardless of their turnover. These include inter-State suppliers, casual and non-resident taxable persons, agents, Input Service Distributors, e-commerce operators, and those liable under reverse charge or specific provisions like Section 9(5) and Section 51.

Recent amendments also cover online money gaming and OIDAR services from outside India. Notified persons may follow special compliance procedures, such as exemption from filing GSTR-9 and GSTR-9C. This detailed guide by AUBSP explains the scope, applicability, and key dates to help you stay GST-compliant.

GST Section 24: Compulsory Registration in Certain Cases

When it comes to compliance under the Goods and Services Tax (GST) regime, one critical aspect is knowing who is required to register compulsorily under GST. While Section 22 outlines the threshold limits for registration, Section 24 of the CGST Act, 2017 overrides those limits for certain categories of persons. AUBSP will walk you through the provisions of Section 24, explaining who must register under GST without considering the threshold exemption limits.

What is Section 24 of the CGST Act, 2017?

Section 24 of the Central Goods and Services Tax (CGST) Act, 2017 mandates compulsory registration for specific categories of taxpayers, irrespective of their aggregate turnover. In simpler terms, even if your turnover is below the threshold specified in Section 22, you may still be required to register under GST if you fall into one of the categories listed in Section 24.

Categories Requiring Compulsory GST Registration under Section 24

The following persons are mandatorily required to register under GST, irrespective of turnover:

1. Inter-State Taxable Suppliers

Anyone making inter-State taxable supply of goods or services must register under GST. The threshold limit does not apply in such cases.

2. Casual Taxable Persons

A person who occasionally supplies goods or services in a taxable territory where they do not have a fixed place of business.

3. Persons Under Reverse Charge Mechanism (RCM)

Those liable to pay GST under reverse charge, i.e., the recipient of goods/services pays tax instead of the supplier.

4. Specified Taxpayers under Section 9(5)

Persons liable to pay tax on specific notified services under Section 9(5) of the CGST Act.

5. Non-Resident Taxable Persons (NRTP)

Foreign suppliers making taxable supplies in India must obtain GST registration.

6. Tax Deductors under Section 51

Government departments and other entities liable to deduct tax at source (TDS) under Section 51 must register under GST.

7. Agents Supplying on Behalf of Others

Any person supplying goods or services on behalf of another taxable person, including agents, is required to register.

8. Input Service Distributors (ISD)

ISDs must register even if they do not cross the turnover limit.

9. Suppliers via E-Commerce Operators

Persons supplying goods or services through e-commerce operators who are required to collect TCS under Section 52.

10. E-Commerce Operators Required to Collect TCS

Every e-commerce operator required to collect Tax Collected at Source (TCS) under Section 52.

11. Suppliers of OIDAR Services from Outside India

Persons supplying Online Information and Database Access or Retrieval (OIDAR) services from outside India to non-registered persons in India.

12. Suppliers of Online Money Gaming Services [Inserted w.e.f. 01.10.2023]

Persons located outside India supplying online money gaming services to persons in India must compulsorily register.

13. Any Other Persons as Notified

The Government may notify additional categories of persons based on the GST Council’s recommendations.

Important Dates and Notifications

To ensure accurate compliance, here are key effective dates and notifications:

Special Procedures for Certain Registered Persons

As per Notification No. 30/2019-Central Tax (Rate), the Central Government has specified special procedures for certain registered persons supplying OIDAR services from outside India:

• No need to file Annual Return (GSTR-9)
• No need to furnish Reconciliation Statement (GSTR-9C)

This is a compliance relaxation specifically aimed at foreign OIDAR service providers registered under Section 24.

Conclusion by AUBSP

Understanding Section 24 of the CGST Act is crucial for anyone engaged in special or high-risk supply categories under GST. Whether you’re an inter-State supplier, e-commerce operator, or a foreign OIDAR service provider, registration under GST is mandatory irrespective of your turnover.

At AUBSP, our objective is to simplify complex tax provisions for professionals and businesses alike. By keeping you informed of both statutory provisions and recent amendments, AUBSP.com ensures that you remain compliant with GST laws.

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FAQs on Compulsorily register under GST

Who is required to compulsorily register under GST as per Section 24?
Persons making inter-State taxable supplies, casual taxable persons, those under reverse charge, non-resident taxable persons, tax deductors under Section 51, agents, Input Service Distributors, e-commerce operators, and suppliers of certain online services must register compulsorily.

Does the threshold turnover limit apply to persons covered under Section 24?
No, Section 24 mandates registration regardless of turnover thresholds specified under Section 22.

What are the recent additions to the compulsory registration categories?
From 1st October 2023, persons supplying online money gaming services from outside India to persons in India must also register under GST as per the CGST Amendment Act, 2023.

Are non-resident taxable persons required to register under GST?
Yes, any non-resident taxable person making taxable supplies in India must compulsorily register under GST.

Do Input Service Distributors need to register under GST?
Yes, Input Service Distributors are required to register irrespective of their turnover.

What special compliance relaxations apply to persons supplying OIDAR services from outside India?
Such persons are exempt from filing the annual return in FORM GSTR-9 and the reconciliation statement in FORM GSTR-9C.

Are e-commerce operators required to register under GST compulsorily?
Yes, every e-commerce operator required to collect Tax Collected at Source (TCS) under Section 52 must register under GST.

Is registration mandatory for agents supplying goods or services on behalf of others?
Yes, agents making taxable supplies on behalf of other taxable persons must register under GST.

When did Section 24 of the CGST Act come into effect?
Section 24 came into force on 22nd June 2017 as notified by Notification No. 1/2017-Central Tax.

Can the Government notify additional categories of persons for compulsory registration?
Yes, the Government can notify other persons or classes of persons for compulsory registration based on the GST Council’s recommendations.

What is the significance of persons required to pay tax under reverse charge?
These persons pay GST on behalf of the supplier and must register compulsorily, even if their turnover is below the threshold limit.

Are casual taxable persons required to register under GST?
Yes, casual taxable persons making taxable supplies must register regardless of turnover limits.

Does a person making taxable supplies through an e-commerce operator need to register?
Yes, persons making taxable supplies through an e-commerce operator who collects TCS must register.

What about persons required to deduct tax under Section 51?
Such persons must register under GST even if they are not separately registered for other purposes.

What happens if a person fails to register under Section 24 when required?
Non-registration despite compulsory requirements can lead to penalties and disallowance of input tax credit.

Are persons supplying online database access or retrieval services from outside India required to register?
Yes, such persons must register if supplying to unregistered persons in India.

Is the annual return mandatory for all persons registered under Section 24?
Not necessarily; for example, persons supplying OIDAR services from outside India are exempted from filing annual returns like GSTR-9 and reconciliation statements like GSTR-9C.

Where can I find the official notifications related to Section 24?
Key notifications include No. 1/2017-Central Tax dated 19.06.2017 and No. 30/2019-Central Tax (Rate) dated 28.06.2019, among others.

Does Section 24 registration requirement apply to intra-State suppliers?
Not unless they fall into one of the specified categories; typically, intra-State suppliers below threshold limits are exempt.

Is it mandatory for foreign suppliers providing online money gaming to register under GST?
Yes, following the 2023 amendment, such suppliers must compulsorily register.