For most small businesses, GST registration depends on four things: your all-India aggregate turnover under one PAN, whether you sell goods or services, the State in which you operate, and whether a compulsory-registration rule applies. The CBIC’s 2019 threshold update records a ₹40 lakh limit for suppliers of goods in most States, ₹20 lakh for goods suppliers in specified States, ₹20 lakh for service suppliers in most States, and ₹10 lakh for services in specified special-category States.
Those limits are not a universal safe harbour. Inter-State taxable sales, certain e-commerce activities, reverse-charge liabilities, agency work and other Section 24 categories can require registration below the normal threshold. A business making only wholly exempt or non-taxable supplies is generally outside registration under Section 23.
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GST thresholds at a glance
The threshold is measured against aggregate turnover for the entire business linked to a PAN, not against one shop, one GSTIN or one State. The figures below are the statutory levels described in CBIC’s 2019 update. Because GST notifications can alter eligibility and exceptions, confirm the rule applicable to your State and supply before relying on a threshold.
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|---|---|---|---|
| Suppliers of goods | ₹40 lakh | ₹20 lakh | Registration is generally required when aggregate turnover crosses the applicable limit, unless an earlier compulsory-registration rule applies. |
| Suppliers of services | ₹20 lakh | ₹10 lakh | The lower service threshold applies in specified special-category States identified by the governing notification. |
| Mixed goods and services | Use the rule that fits the supplies and the applicable notification | Use the State-specific rule | Do not assume the goods limit merely because goods are part of the business; review the character of the taxable supplies. |
“Most States” and “specified States” are legal categories, not informal descriptions. The list and treatment of special-category States should be checked in the current notification when you register, especially if your business operates in more than one State.
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What counts toward the ₹20 lakh or ₹40 lakh limit?
Aggregate turnover is calculated on an all-India basis for the same PAN. It combines the value of supplies made by the business and its branches, registrations and establishments across India. Looking only at the State where the largest branch operates can understate liability.
- Include taxable supplies: sales on which GST is chargeable, whether goods, services or both.
- Include exempt supplies: exempt turnover still enters the aggregate-turnover calculation unless the business is exclusively engaged in exempt or non-taxable supplies and qualifies for the Section 23 exclusion.
- Include exports: exports are included even though they are treated as zero-rated supplies under the GST framework.
- Exclude GST itself: central, State, integrated and compensation cess amounts collected as GST are not part of turnover.
- Aggregate related registrations under one PAN: separate GST registrations in different States do not create separate threshold calculations.
For example, suppose a PAN has ₹16 lakh of taxable sales in one State, ₹8 lakh of exempt sales in another and ₹5 lakh of exports from a third location. The aggregate is ₹29 lakh before GST, not ₹16 lakh. Whether registration is required then depends on the supply mix, the State rules and any Section 24 trigger.
Who can remain unregistered under Section 23?
Businesses supplying only non-taxable or wholly exempt items
Section 23 excludes a person engaged exclusively in supplying goods or services that are not liable to tax or are wholly exempt under the CGST or IGST framework. CBIC’s FAQ explains the practical consequence: a business dealing only in 100% exempt supplies is not liable to register solely because its turnover exceeds ₹20 lakh.
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The word “exclusively” is decisive. A business selling exempt products alongside even a small amount of taxable goods or services no longer fits the exclusive-supply exclusion. It must then test the ordinary threshold and the compulsory-registration rules. Keep invoices, product classifications and exemption notifications that demonstrate why each supply is exempt.
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Agriculturists supplying their own produce
An agriculturist is excluded to the extent of supplying produce arising from cultivation of land. The exclusion concerns the person’s own agricultural produce; it does not automatically cover trading in produce bought from other farmers, processing activities or unrelated taxable services. Those additional activities need a separate threshold and compulsory-registration analysis.
Non-taxable is not the same as low-value
Section 23 is an activity-based exclusion, not a turnover concession. A business cannot convert a taxable activity into an exempt one by describing its receipts as agricultural, reimbursement or commission income. Classify each supply under the applicable GST rate and exemption entry, and preserve contracts and supporting records.
When registration is compulsory below the normal threshold
Section 24 overrides the basic threshold for specified categories. The exact application can depend on the type of supply and on notifications, so a low turnover does not by itself settle the question.
Inter-State taxable supplies
A person making taxable supplies from one State to another can fall within compulsory registration even when aggregate turnover is below the ordinary State threshold. This rule concerns taxable inter-State supplies; it should not be generalized to every movement of goods, exempt supply or stock transfer. Identify the place of supply and whether the transaction is taxable before deciding.
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Casual taxable persons
A casual taxable person makes taxable supplies in a State or Union territory where the person has no fixed place of business. Temporary stalls, exhibitions and short-term commercial events can create this status. Registration planning must occur before the event because the ordinary small-business threshold does not remove the Section 24 category.
Reverse-charge taxpayers
Where the recipient is liable to pay GST under reverse charge, the recipient may have a registration obligation under the relevant rules. Review the nature of the inward supply, the supplier’s location and the notification creating the reverse-charge liability. Do not assume that a small recipient is exempt simply because it makes few outward sales.
Agents and input-service distributors
An agent supplying goods or services on behalf of another taxable person is listed among the compulsory-registration categories. An input-service distributor, which distributes eligible input-service credit among registrations, is also treated separately from an ordinary operating unit. These roles can trigger registration even where the entity’s own outward turnover is modest.
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Non-resident and overseas digital suppliers
Non-resident taxable persons have a specific registration framework. Overseas suppliers of online information and database access services to Indian non-taxable recipients (often called OIDAR supplies) are also covered by a compulsory category. A foreign supplier should not apply domestic small-business thresholds without checking the non-resident and digital-service rules.
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E-commerce: why the platform and the supply both matter
Online selling is not one GST category. The result differs for goods, ordinary services, and services on which Section 9(5) shifts tax payment to the e-commerce operator.
| Situation | Typical GST effect | What to verify |
|---|---|---|
| Goods supplied through an operator required to collect TCS | The supplier generally cannot claim the normal threshold exemption merely because turnover is small. | Whether the operator is required to collect tax at source and whether a notification provides an exception. |
| Services supplied through an e-commerce platform | Certain service suppliers have a notified exemption up to the applicable turnover limit. | The service category, the notification’s conditions and the supplier’s State threshold. |
| Services covered by Section 9(5) | The operator can become liable to pay GST on the notified service. | Whether the exact service appears in a current Section 9(5) notification; this does not automatically exempt every other service sold online. |
| Direct online sales outside a notified exception | Ordinary threshold and Section 24 rules apply. | Place of supply, customer location, taxable status and the operator’s TCS role. |
Do not transfer a goods-marketplace rule to a service platform. Keep the operator’s contractual terms, TCS statements and the classification of every service so you can show why a threshold exemption was or was not used.
A practical decision process
- List every activity. Separate goods, services, exports, exempt supplies, non-taxable supplies, agency work, reverse-charge purchases and online-platform sales.
- Map the PAN. Gather turnover for all Indian branches, trade names and existing GST registrations linked to the same PAN.
- Compute aggregate turnover. Add taxable supplies, exempt supplies and exports; remove GST and cess amounts. Use the value for the relevant financial-year calculation under the GST framework.
- Identify the State rule. Determine where each supplier is located and whether the ₹40 lakh, ₹20 lakh or ₹10 lakh category applies. For multi-State operations, assess each registration obligation rather than averaging States.
- Test Section 23. Confirm whether the business is exclusively in non-taxable or wholly exempt supplies, or whether an agriculturist exclusion covers the particular produce.
- Test Section 24. Check inter-State taxable supplies, casual status, reverse charge, agency, input-service distribution, e-commerce/TCS, non-resident status and OIDAR supplies.
- Set a monitoring trigger. Review turnover monthly, including exempt and export invoices, and keep a separate flag for transactions that can create liability before the threshold is crossed.
- Apply when liability begins. If a threshold is crossed or a compulsory category applies, prepare the electronic registration application within the statutory 30-day period.
When to apply and how the GST registration starts
CBIC’s Sectoral FAQs state that the application must be made within 30 days of turnover crossing the threshold or of attracting a Section 24 condition. Waiting for the end of the financial year can create an avoidable gap in compliance.
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- On the GST Portal, start the normal-taxpayer application in FORM GST REG-01.
- Complete the initial details and verify the contact information through the portal’s authentication process.
- Provide the legal name, constitution, principal place of business, additional places, bank details and authorised signatory information requested by the form.
- Upload the supporting documents shown for your constitution and premises, then submit the application electronically.
- Record the application reference number and respond promptly if the tax officer asks for clarification or additional evidence.
The 30-day period is tied to the event that creates liability. If an inter-State taxable supply or another Section 24 condition applies before the turnover threshold is reached, that earlier event is the relevant date.
What changes after registration?
Registration turns the business into a normal taxable person for the supplies covered by GST. It is not only an identification number.
- Charge and report GST correctly: issue tax invoices where required, apply the correct rate and distinguish intra-State from inter-State tax.
- File outward-supply details: the GST Portal states that registered taxable persons generally report outward supplies electronically in Form GSTR-1. Nil returns are required where applicable, even when there are no reportable outward supplies.
- Track input tax credit: retain eligible purchase invoices and reconcile supplier data before claiming credit; registration alone does not make every purchase creditable.
- Maintain records: preserve sales, purchases, exports, exemption evidence, e-commerce statements, reverse-charge documents and bank records for the statutory retention period.
- Update the registration: changes in address, constitution, authorised signatory or business activity may require an amendment rather than a new application.
Return frequency, payment forms and other filings depend on the taxpayer category and current rules. Build a calendar from the portal’s applicable compliance obligations instead of assuming that a newly registered small business has no filing duty in a quiet month.
Voluntary registration below the threshold
A business below the threshold may choose to register. CBIC states that a voluntary registrant is treated as a normal taxable person and must pay GST on taxable supplies made after registration.
| Choice | Advantages | Costs and risks |
|---|---|---|
| Remain under the threshold, where legally permitted | Fewer GST returns and less invoicing administration; no GST collection on supplies while unregistered. | No GST registration number for customers that require one; no normal input-tax-credit chain as a registered supplier; compulsory rules can still override the choice. |
| Register voluntarily | Can issue GST tax invoices, participate in a registered buyer’s procurement process and potentially claim eligible input tax credit. | GST must be charged and paid on post-registration taxable supplies, returns must be filed, records must be maintained and late compliance can create interest or penalties. |
Choose voluntary registration for a documented commercial or credit reason, not merely because a customer asks for a number without checking whether the expected benefit exceeds the recurring compliance work. Once registered, cancelling later requires satisfying the cancellation rules and settling outstanding obligations.
Worked examples
| Example | Facts | Likely analysis |
|---|---|---|
| Local goods trader | ₹18 lakh of taxable intra-State goods sales in a State using the ₹40 lakh goods threshold; no special category. | Below the ordinary threshold, unless another compulsory-registration condition applies. |
| Goods trader with multiple States | ₹25 lakh in one State and ₹18 lakh in another under one PAN. | Aggregate turnover is ₹43 lakh across India. The business cannot test each State in isolation; review the applicable goods threshold and registration requirements for each location. |
| Service consultant | ₹12 lakh of taxable services in a State where the service threshold is ₹20 lakh. | Below the ordinary threshold, provided there is no inter-State taxable supply or other Section 24 trigger. |
| Exempt-only seller | ₹30 lakh turnover, all supplies wholly exempt and no taxable side activity. | Section 23 can exclude the person from registration despite turnover above ₹20 lakh, subject to confirming that every supply is genuinely exempt or non-taxable. |
| Small online goods supplier | ₹7 lakh of taxable goods sold through an operator required to collect TCS. | The goods-marketplace compulsory rule may apply below the threshold; verify the operator’s status and any notified exception before selling. |
| Voluntary registrant | ₹8 lakh of taxable local services; registers to satisfy a corporate customer. | After registration, the supplier is treated as a normal taxable person and must charge and report GST on post-registration taxable supplies. |
Common mistakes and how to correct them
- Using only taxable turnover: add exempt supplies and exports when calculating aggregate turnover, then exclude GST itself.
- Applying the ₹40 lakh figure to services: services generally use the ₹20 lakh or ₹10 lakh threshold, not the goods limit.
- Assuming every State has the same limit: verify whether the State falls in the specified category in the current notification.
- Treating every online sale alike: distinguish goods subject to TCS, notified service exemptions and Section 9(5) services.
- Ignoring a small inter-State invoice: a single taxable inter-State business line can create liability before turnover reaches the ordinary limit.
- Missing the 30-day deadline: identify the date of threshold crossing or the Section 24 event, then submit REG-01 within 30 days.
- Registering without a compliance plan: set up invoice numbering, return ownership, purchase records and a calendar before the first taxable invoice.
- Calling mixed supplies exempt-only: one taxable product or service can remove the Section 23 exclusion for the whole business.
Bottom line for a small-business owner
Start with the PAN-wide aggregate turnover, not the turnover of one outlet. Apply the correct goods or services threshold for the State, then separately test Section 23 exclusions and Section 24 compulsory categories. If liability arises, file FORM GST REG-01 electronically within 30 days and prepare for invoicing, GSTR-1 and continuing record-keeping. If you register voluntarily, plan for normal-taxpayer obligations from the date of registration rather than treating the certificate as a one-time formality.
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