Registration in case of supply of goods through an ECO, Goods and Services Tax - GST

[Satyam Agarwal]

If a person is engaged in intra state supply of goods through an ECO, he is not liable for registration if his aggregate turnover in the preceding and current financial year does not exceed the threshold limit.

Since he is exclusively engaged in making supply of goods, though through an ECO, will the threshold of 40L limit be available?

Posts / Replies

[KASTURI SETHI]

Compulsory Registration for supply of goods through ECO is required only if that person is to collect tax at source under Section 52 of CGST Act.

Read Notification no.34/23-CT dated 31.7.23.

In other words, it is conditional exemption from registration for ECO. 

[Shilpi Jain]

Certain States still have 20L only as turnover limit. Pls share which State are you from.

[Yash Shah]

According to Section 24(ix) of the CGST Act 2017, a person supplying goods or services or both, through an ECO who is collecting tax at source u/s 52 other than supplies specified u/s 9(5), is compulsorily required to take registration.

However, according to N/No. 34/2023 CT, persons supplying goods through an ECO who is collecting tax u/s 52 and aggregate turnover in the preceding FY & the current FY does not exceed the threshold limit for registration u/s 22(1), are exempted from obtaining registration subject to inter alia following conditions:

• Making intra-state supply of goods
• Supplying goods through ECO in only 1 state or union territory
• Having PAN under the Income Tax Act

Further, according to Section 22(1) & N/No. 10/2019-CT, a person, who is engaged in exclusive supply of goods other than persons engaged in making intra-State supplies in the States of Arunachal Pradesh, Manipur, Meghalaya, Mizoram, Nagaland, Puducherry, Sikkim, Telangana, Tripura, and Uttarakhand is exempt from obtaining registration if aggregate turnover in the FY does not exceed Rs. 40 lakhs.

In the given case, if the aggregate turnover of the preceding & current FY does not exceed Rs. 40 lakhs, then a person is not liable for registration, assuming all remaining conditions of N/No. 34/2023 CT are satisfied and he is not engaged in making intra-state supplies from above-mentioned states.