Understanding Suo Moto Registration under GST

What is Suo Moto Registration?

In the realm of Goods and Services Tax (GST) in India, tax officials can unilaterally initiate and complete the registration process for businesses or individuals who are liable to be registered but have failed to do so voluntarily. This mechanism is called Suo Moto Registration. Tax authorities generate and allot a Temporary ID to such unregistered persons through the GST Portal, ensuring the enforcement of tax compliance.

How Do Tax Officials Initiate Suo Moto Registration?

Tax officials in the role of Registration Enforcement have multiple methods to initiate Suo Moto registration:

1. Via GST Portal Interface:
   • Access the GST Portal’s Tax Official Interface.
   • Fill in the details of the unregistered person.
   • Generate a Temporary ID to complete the Suo Moto registration.
2. Using Mobile Phones:
   • Useful for enforcement activities outside the office, such as at check posts or borders.
   • Send an SMS from the registered mobile number of the tax official to generate a Temporary ID.
   • Access the GST Portal and enter the unregistered person’s details to complete the registration.

Structure of the Temporary ID

The Temporary ID generated during Suo Moto registration comprises 15 characters:

• First 2 digits: State Code
• Next 2 digits: Year (YY)
• Next 8 digits: Serial number starting from 1 each financial year
• Last 3 characters: TMP (indicating Temporary)

For example, the Temporary ID 221712345678TMP breaks down as:

• 22 – State Code
• 17 – Year
• 12345678 – Serial Number
• TMP – Temporary

Registration Certificate for Temporary Registration

A Registration Certificate is not generated for temporary registrations. Instead, the unregistered person receives a Temporary ID, which they must use to apply for permanent registration within a specified period.

Notification of Temporary ID & Password

Once Suo Moto registration is completed, the unregistered person receives their Temporary ID and password via SMS and email (if provided). They can use these credentials to log in to the GST Portal and gain access to limited functionalities such as payment, notices, orders, and registration.

Depositing Tax via Suo Moto Registration

Tax can be deposited through two primary methods:

1. Through Tax Official:
   • The unregistered person hands over cash to the tax official.
   • The tax official generates a challan, selects payment mode (Over The Counter), and deposits the cash in a designated bank.
   • The system reflects the amount in the unregistered person’s Electronic Cash Ledger.
2. By the Unregistered Person:
   • They log in to the GST Portal using the Temporary ID.
   • Generate a challan and make a payment via available online or offline modes.
   • The system updates the amount in the Electronic Cash Ledger.

Viewing Deposited Amount

The unregistered person can view the deposited amount in the Electronic Cash Ledger by navigating to Services > Ledgers > Electronic Cash Ledger on the GST Portal.

Applying for Fresh Registration

The unregistered person must apply for fresh registration within 90 days of receiving the Temporary ID or within 30 days from the date of order upholding liability in case of an appeal. During the registration process, they must mention the Temporary ID under the Existing Registrations section in Part B of the application.

Consequences of Not Applying for New Registration

If the unregistered person does not file the application for new registration within 90 days, the system sends an alert to the tax official. The unregistered person must then submit the registration application within 30 days from the date of the order upholding the liability to register.

Viewing the Order of Allotment

The unregistered person can view and download the order of allotment from the GST Portal under Services > User Services > View Notices and Orders.

Next Steps After Order of Allotment

Once the order is generated, the unregistered person receives the Temporary ID and password via SMS and email, which they can use to access limited functionalities on the GST Portal. They must apply for permanent registration within the stipulated period.

Profile Information and Temporary ID

Profile fields remain blank for temporary users. The unregistered person must furnish complete details upon applying for permanent registration.

Adjusting Deposited Amount

Once the unregistered person deposits the amount, the liability register updates, allowing for liability adjustments.

Changing Mobile Number

The unregistered person can only change the mobile number during the application for fresh registration on the GST Portal. There is no option to update the mobile number for a Temporary ID.

Handling Temporary IDs Issued by Mistake

If a temporary ID is issued mistakenly, such as in the case of a driver unaware of the GSTIN, the unregistered person can request the enforcement officer to tag the temporary ID with the correct GSTIN.

By understanding these processes and guidelines, businesses and individuals can ensure compliance and avoid potential penalties associated with unregistered operations under GST.

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This article is only a knowledge-sharing initiative and is based on the Relevant Provisions as applicable and as per the information existing at the time of the preparation. In no event, RMPS & Co. or the Author or any other persons be liable for any direct and indirect result from this Article or any inadvertent omission of the provisions, update, etc if any.

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