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Suo Moto Registration under GST

What is Suo Moto Registration?

Where a tax officer finds that a person liable to registration under the Goods & Service Tax has failed to apply for such registration, the officer may register the said person on a temporary basis by allotment of temporary ID.

Tax officials in the role of Registration Enforcement can initiate the suo moto registration to deposit the amount collected from unregistered persons especially during enforcement proceedings.


Recent updates related to GST registration

28th May 2021

The last date for filing an application for revocation of canceled GSTIN falling between 15th April 2021 to 29th June 2021 extended to 30th June 2021.

5th March 2021

The search ARN functionality for registration on the common portal has been enhanced for taxpayers.

31st January 2021

(i) SEZs while applying for GST registration will have to provide the validity period as per the letter of authorisation (LOA).

(ii) Aadhaar authentication has been implemented on the Common portal for existing taxpayers.

31st December 2020

(i) For new registrants who opted for Aadhaar authentication, the authentication would be required only for one Primary Authorized Signatory and one Promoter instead of all.

(ii) Now, GST practitioners can apply cancellation of GST registration in Form GST PMT-06.


How Suo Moto Registration will be initiated?

Suo moto GST registration can be initiated by the proper officer in two ways given below-

  1. Access the official interface of the GST Portal and input the details of the unregistered person. This will generate a temporary ID and complete the suo moto registration of the unregistered person.
  2. Send SMS from the registered mobile phone number of the officers to initiate suo moto registration. This method is used in case of enforcement activities carried from outside the office like check posts or borders.

What is Temporary ID?

Temporary ID is an alphanumeric number generated by the tax officer to initiate the process of suo moto registration. structure of Temporary ID is 15 characters. A sample Temporary ID is 22 17 12345678 TMP, where

  • First 2 digits indicate State Code
  • Next 2 digits indicate YY
  • Next 8 digits include serial number starting from 1 each financial year
  • Last 3 digits include alphabets TMP

Options to deposit tax in Suo Moto Registration

Tax can be deposited in the following two ways:

(a) The unregistered person after receiving the Temporary ID, requests the officer to collect cash and deposit Cash. In such as case:

  • The unregistered person handovers cash to the officer
  • The proper officer will log in to the official Interface of the GST Portal and completes the Suo Moto Registration.
  • Officer will generate a challan and selects the payment mode as Over The Counter (Cash, Cheque/ DD) and selects the Bank in which the State Tax Office has the Bank account.
  • Tax Officer will collect the cash from the unregistered person.
  • Tax Office deposits the cash in the select Bank for the Challan generated. The cash collected is reflected in The Electronic Cash Ledger of the taxpayer who has been issued the Temporary ID.

(b) The detailed unregistered person after receiving the Temporary ID, makes a payment. In such as case:

  • The unregistered person after receiving Temporary ID logs in to the GST Portal.
  • The taxpayer who has been issued Temporary ID, generates challan and makes a payment in any of the available online or offline payment modes. The cash collected is reflected in the Electronic Cash Ledger of the taxpayer who has been issued the Temporary ID.

Frequently asked questions (FAQs)

Certificate is not generated for temporary registration. Only a Temporary ID is issued to you until you apply for registration within the specified period.

The unregistered person will be intimated of Temporary ID and Password by SMS and e-mail message if an e-mail address was provided by the unregistered person. The same can be used by the taxpayer to log in to the GST Portal and they will have access to limited functionalities like payment, notices, orders, registration, etc.

You can log in to the GST Portal and the amount will be reflected in your Electronic Cash Ledger. Navigate to Services > Ledgers > Electronic Cash Ledger.

The taxpayer will be required to apply for fresh registration within 90 days from the grant of temporary ID or within 30 days from the date of issuance of order upholding the liability to register against the appeal filed by the taxpayer.

During such registration, the applicant must mention the Temporary ID.

When applying for Registration using the New Registration Application, in Part B of the application, under the Business Details section, there is an option to Indicate Existing Registrations.

When applying for Registration using the New Registration Application, in Part B of the application, under the Business Details section, there is an option to Indicate Existing Registrations.

A taxpayer is recommended to enter the Temporary ID in this section in the Application for New Registration when the taxpayer is applying for a GSTIN / Permanent registration for the linkage to be captured in the GST Portal.

An alert will be sent to Tax Official, in case you do not file the Application for new registration, within 90 days from the date on which the temporary registration has been granted. In case you have filed an appeal against the grant of temporary registration, in such case, the application for registration shall be submitted, within a period of 30 days from the date of issuance of the order upholding the liability to registration by the Appellate authority.

You can log in to the GST Portal with Temporary ID and Password received on your email address/ SMS and Navigate to Services > User Services > View Notices and Orders to see the order of allotment of temporary registration.

You can click the Download link to download the order of allotment of temporary registration.

A taxpayer will be intimated of Temporary ID & Password SMS and e-mail message if an e-mail address was provided by the unregistered person. The same can be used by the taxpayer to log in to the GST Portal and have access to limited functionalities like payment, notices, orders, appeal, registration, etc.

The taxpayer will be required to apply for fresh registration within 90 days from the grant of temporary registration or within 30 days from the date of issuance of order upholding the liability to register against the appeal filed by the taxpayer.

View Profile fields are blank for the temporary users. You need to register with GST to furnish all the details.

After the amount is deposited, the liability register is updated and from there you can adjust your liabilities.

You can change your mobile number while applying for fresh registration on the GST Portal. There is no facility to update the mobile phone number for the temporary ID generated by the Tax Official during the Suo Moto registration.

At the time of disposal, the taxpayer can provide his GSTIN and request the enforcement officer to pass an order against that GSTIN tagging the temporary ID.


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TaxGyata Team

TaxGyata Team