GST registration for a Kochi business

Which threshold applies to you in Kochi

Section 22(1) of the CGST Act sets the basic figure at twenty lakh rupees of aggregate turnover in a financial year. The forty lakh figure is not in section 22 at all, which surprises people who go looking for it there. It comes from Notification No. 10/2019-Central Tax, made under section 23(2) and dated 7 March 2019, which exempts from registration any person engaged in exclusive supply of goods whose aggregate turnover in the financial year does not exceed forty lakh rupees. It came into force on 1 April 2019.

That notification names the states where the exemption does not apply: Arunachal Pradesh, Manipur, Meghalaya, Mizoram, Nagaland, Puducherry, Sikkim, Telangana, Tripura and Uttarakhand. Kerala is not among them. So in Kochi it is Rs 40 lakh if you deal exclusively in goods, Rs 20 lakh otherwise.

Exclusive supply of goods is stricter than it sounds. Raise one consultancy invoice and you are a mixed supplier back on the Rs 20 lakh figure.

Three things are cut out by the notification's own table: ice cream and other edible ice under tariff item 2105 00 00, pan masala under 2106 90 20, and the whole of Chapter 24, tobacco and manufactured tobacco substitutes. An ice cream parlour selling only goods is on Rs 20 lakh. So is any pan shop. The exemption also does not reach anyone required to register compulsorily under section 24, which is the next problem.

Section 24 overrides the threshold entirely

Section 24 opens with the words notwithstanding anything contained in sub-section (1) of section 22, and then lists nine categories that must register whatever their turnover. Persons making any inter-State taxable supply. Casual taxable persons making taxable supply. Persons required to pay tax under reverse charge. Persons required to pay tax under section 9(5). Non-resident taxable persons making taxable supply. Persons required to deduct tax under section 51. Persons supplying on behalf of other taxable persons, whether as agent or otherwise. Input Service Distributors. And persons supplying through an electronic commerce operator, other than supplies specified under section 9(5).

Read the first of those slowly. On its face, a single sale of goods to a customer in Tamil Nadu makes you liable at any turnover. A Fort Kochi handicraft seller who couriers two orders to Chennai is in a different position from the identical shop that only sells across the counter.

Timing comes from section 25(1). Once you become liable you have thirty days to apply, in every State or Union territory in which you are so liable. A casual taxable person or a non-resident applies at least five days before commencing business, which matters if you are taking a stall at a trade fair somewhere you have no fixed place of business. A unit in a Special Economic Zone, or an SEZ developer, applies for a separate registration from any place of business outside the zone in the same State.

And the notifications that pull some of it back

Section 24 is not the last word, because section 23(2) lets the Government exempt categories from registration, and it has been used in ways that matter here.

Services through an e-commerce operator. Notification No. 65/2017-Central Tax, dated 15 November 2017, exempts persons making supplies of services through an operator required to collect tax at source under section 52, other than supplies specified under section 9(5), whose aggregate turnover computed on an all-India basis does not exceed twenty lakh rupees. A proviso puts the figure at ten lakh rupees for the special category States other than Jammu and Kashmir.

Goods through an e-commerce operator. Notification No. 34/2023-Central Tax, dated 31 July 2023 and in force from 1 October 2023, exempts people selling goods through such an operator whose aggregate turnover in the preceding and the current financial year does not exceed the section 22(1) threshold for that State. The conditions are narrow and cumulative: no inter-State supply of goods at all; supply through an operator in one State or Union territory only; a PAN; a declaration of PAN, address and State on the common portal; and an enrolment number granted on that portal before any supply is made. One enrolment number per State, and it dies the day you are actually registered.

A Kochi seller listing on a marketplace that ships nationwide is making inter-State supplies and falls outside that relief entirely.

The freelancer's question, and why we are hedging it

The most common question we get from Kochi is the freelancer's. A designer in Panampilly Nagar or a developer at Infopark bills clients in Bengaluru. Section 24(i) says persons making any inter-State taxable supply must register. Does that mean from the first rupee?

The answer usually given is no, on the strength of Notification No. 10/2017-Integrated Tax, which is understood to exempt persons making inter-State supplies of taxable services whose aggregate turnover on an all-India basis does not exceed twenty lakh rupees. That relief is read as covering services and not goods.

We are flagging it rather than stating it flat, because we could not open the text of that notification on any official portal while writing this. The GST Council's file server returned nothing for every filename we tried, and CBIC serves its notification archive through a script-driven viewer we could not read. Everything else in this guide we have read in the original; this one we have not.

So: if you are a Kochi freelancer with out-of-state clients and you are below Rs 20 lakh, do not act on this paragraph alone. Get the notification put in front of you by a practitioner, or ask the jurisdictional office in writing. The gap between registering and not registering is too large to settle on a guide's say-so, ours included.

Aggregate turnover is wider than your sales figure

Section 2(6) defines aggregate turnover, and it is not the number at the top of your profit and loss account. It is the aggregate value of all taxable supplies, exempt supplies, exports of goods or services or both, and inter-State supplies of persons having the same Permanent Account Number, computed on an all-India basis. It excludes central, State, Union territory and integrated tax and cess, and it excludes the value of inward supplies on which you pay tax under reverse charge.

Three consequences get missed in practice.

Exempt supplies count. A Kochi clinic whose consultation income is exempt but which also lets out a first-floor room adds both together for the threshold test.

Exports count. Design or software work billed to a client abroad goes into the number in full. A zero-rated supply is not an exempt one, and the definition names exports explicitly.

Same PAN, everything aggregates. A proprietor running a shop in Kaloor and a separate trade in Aluva under one PAN has a single aggregate turnover, not two. Two proprietorships do not buy you two thresholds.

The financial year is the unit of measurement. You cross the threshold on the day the running total for that year passes it, and the thirty-day clock in section 25(1) starts from that day, not from 1 April of the following year. People who wait for the accountant's year-end are already late.

Centre or State: you do not choose your officer

GST registration in Kerala is a single application on the common portal producing one GSTIN valid for both the central and the state administration. The file is then allocated to one of them, and you do not pick.

If it goes to the Centre, you are in the CGST Kochi Commissionerate, part of the Thiruvananthapuram Zone. Its own site describes seven divisions and thirty-five ranges, and gives a GST Seva Kendra at the Central Revenue Building, I.S. Press Road, Kochi, open 9.00 a.m. to 5.30 p.m., with a Deputy Commissioner as Public Grievance Officer on 0484-2390404. In our own register the Ernakulam Division sits at the Central Excise Bhavan, Kathrikadavu, Kaloor, the building everyone in the city calls GST Bhavan.

If it goes to the State, you are with the Kerala State GST Department. Ernakulam is headed by a Joint Commissioner for Taxpayer Services at the SGST Complex, Perumanoor P.O., Thevara, with deputy commissioners over Ernakulam South, Ernakulam North, Kakkanad and Thrippunithura. There are thirteen taxpayer services circles, split by PIN code: Kochi, Panampilly Nagar, Ernakulam Central, Ernakulam North, Vypin, Kaloor, Palarivattom, Edappally, Kakkanad, Thrikkakkara, Kadavanthra, Vyttila and Thrippunithura. They sit at Perumanoor, at the Civil Station in Kakkanad, and at the Mini Civil Station in Thrippunithura.

We could not confirm the current basis on which files are divided between the two administrations, so assume nothing about it. Check the jurisdiction shown on your own registration once the GSTIN issues, and write it down. Every later notice comes from that office.

Address proof, and the instruction that changed the argument

The commonest reason a registration stalls is proof of the principal place of business. Instruction No. 03/2025-GST, dated 17 April 2025, was issued precisely because officers were demanding papers that were never on the list. It supersedes the 2023 instruction and is worth having open when you reply to anything.

For owned premises, any one document from the list appended to Form GST REG-01 suffices: the latest property tax receipt, the municipal khata copy, or a copy of the electricity bill of the owner. The instruction adds that any similar document, such as a water bill or anything prescribed under State or local law that clearly establishes ownership, should also do. One document is enough, no additional ownership document should be requested, and no original physical copy may be demanded.

For rented premises, the valid rent or lease agreement plus any one such document establishing the lessor's ownership. Where the agreement is registered, no identity proof of the lessor should be sought. Where it is unregistered, one identity proof of the lessor may be. And where the electricity or water connection is already in the applicant tenant's name, that document with the rent agreement is to be accepted and no additional papers about the lessor sought at all.

Where the premises belongs to a spouse or relative, a consent letter on plain paper, a copy of the consenter's identity proof, and one ownership document. Where no agreement exists, an affidavit on non-judicial stamp paper of minimum value, executed before a First-Class Judicial Magistrate, an Executive Magistrate or a Notary Public, with a possession document such as an electricity bill in your own name.

The queries officers are told not to raise

Paragraph 7 of the same instruction names the presumptive queries that had become routine and forbids them. Three are given by name: that the residential address of the applicant, managing director or authorised signatory is not in the same city or State where registration is sought; that the HSN code declared is for goods banned or prohibited for sale in that State; and that the kind of activity described cannot be carried on from those premises. Officers are told not to ask any presumptive query unrelated to the documents or information actually submitted.

On constitution of business the instruction is equally specific. Where the applicant is one of the partners, the partnership deed is the proof, and no Udhyam certificate, MSME certificate, shop establishment certificate or trade licence should be sought in addition. A society, trust, club, government department, association of persons, body of individuals, local authority or statutory body uploads its registration certificate or proof of constitution and nothing more.

Anything outside the listed documents requires the approval of the concerned Deputy or Assistant Commissioner before it can be asked for. Officers are also told not to raise queries over minor deficiencies irrelevant to establishing the place of business or the constitution.

None of this makes an improper query impossible. It makes one answerable. The instruction itself records that field formations had been demanding a photograph of the lessor in front of or inside the property. If that lands in your Form GST REG-03, reply in Form GST REG-04 and cite the paragraph.

Aadhaar, and whether you have to turn up

Aadhaar authentication decides which track your application takes, and Instruction 03/2025 sets out the consequences plainly.

Where the application is not flagged as risky on the common portal on data analysis and risk parameters, and is complete and without deficiency, officers are to approve it within seven working days of submission.

The thirty-day track, with physical verification of the place of business, applies in three cases: where the applicant has undergone Aadhaar authentication but is flagged as risky on the portal; where the applicant fails to undergo Aadhaar authentication or does not opt for it; and where the officer deems physical verification fit, with the approval of an officer not below the rank of Assistant Commissioner. In those cases the verification report, with GPS-enabled site photographs, must be uploaded in Form GST REG-30 at least five days before the thirty-day period expires.

Declining Aadhaar authentication is therefore permitted but expensive in time. It moves you from a one-week desk decision to a month with an officer at your door.

What we could not confirm is the in-person side of it. Applicants in several states are routed to book an appointment at a designated GST Suvidha Kendra for biometric authentication and document verification rather than an OTP. We could not open a current GSTN advisory confirming the date Kerala came onto that track, nor find any published list of Kendra locations in Ernakulam. If the portal routes you to a Kendra, the address arrives in the appointment mail and the slot is time-bound. Read that mail the day it lands.

How applications actually get rejected

Rejection is procedural rather than arbitrary, and it runs in a fixed sequence set out in Instruction 03/2025.

The officer issues a notice in Form GST REG-03. For an application not flagged as risky, that notice must go out within seven working days of submission; for a flagged one, within thirty days. You then have seven working days from receipt to reply in Form GST REG-04. If the officer is satisfied, approval follows within seven working days of the reply. If not, rejection follows in Form GST REG-05 within seven working days of the reply, for reasons recorded in writing.

The failure mode that costs most applications is silence. Where no reply is filed within seven working days of the notice, the officer may reject in Form GST REG-05 within seven working days of that deadline passing. Nobody telephones. The notice lands on the portal and against the email address and mobile number you registered, which is a good reason to give a number somebody actually watches.

The grounds on which a notice may be issued are confined by the instruction to four: a document that is incomplete or not legible; an address that does not match the document uploaded, or an uploaded document that does not appear to be valid proof of that address; an address that is incomplete or vague; and any GSTIN linked to your PAN found cancelled or suspended.

That last one is the quiet killer. A dead registration anywhere in India, yours or a co-promoter's, is something you will be asked to explain before this one is granted.

After the GSTIN arrives

Registration is granted in Form GST REG-06 and the certificate is downloaded from the portal. Two things follow at once.

Display it. The certificate goes up at the principal place of business and at every additional place declared, and the GSTIN goes on the name board at the entry of those premises. This gets checked in the field more often than people expect, and it costs nothing to get right on day one.

Bank details. Rule 10A of the CGST Rules requires bank account details in the name of the registered person and linked to the PAN to be furnished after registration, and a registration can be cancelled for failing to do it. We could not open CBIC's live rule text to confirm the exact deadline wording, so treat the portal's own prompt and countdown as the authority rather than a date read anywhere else, including here.

Then check whether you sit with the Centre or the State, note the office, and file returns. A registration with no returns behind it draws cancellation proceedings. And a cancelled GSTIN attached to your PAN is precisely the thing that will hold up the next application you make, including one for a business you are connected to only by a shared director. The four grounds for a Form GST REG-03 notice are worth rereading once a year for that reason alone.