Core And Non-Core GST Registration Amendments - Law, Practice, Illustrations & FAQs

Why Every Business Change Must Echo on the GST Portal

In the GST regime, registration is not merely the starting point of a tax relationship; it is the language through which a business continuously speaks to the State. Every detail appearing on the GST portal - the name, address, authorised signatory, nature of business, and places of operation, together narrate who the taxpayer is today , not who it once was. Unlike the pre-GST indirect tax regime, where registration often became a static certificate after approval, GST is built on the assumption that businesses are living, evolving institutions.

This philosophical shift is deliberate. GST is a data-driven tax system in which registration data seamlessly integrates with corporate law records, income-tax filings, banking systems, and regulatory disclosures. In such an ecosystem, outdated registration particulars are not harmless omissions; they distort the system's perception of identity, responsibility, and control . Compliance under GST, therefore, is not episodic; it is continuous, relational, data-driven, and reflective of reality. The following simple Hindi thought captures this expectation:

" व्यवसाय बदलता है समय के साथ ,
कानून बस यही चाहता है —
कि सच भी बदले उसके साथ। "

(Business changes with time; the law only asks that truth changes with it.)

Amendment of GST Registration- Section 28

Section 28 of the CGST Act, 2017, statutorily recognises the evolving character of GST registration. It treats registration not as a concluded procedural event but as a continuing legal declaration by the registered person. When a taxpayer obtains GST registration, he undertakes a legal commitment that the particulars disclosed will remain accurate and up to date for as long as the registration subsists.

Section 28(1) imposes an affirmative obligation on the registered person to intimate any change in registration particulars in the prescribed manner and within the prescribed time. This obligation is proactive, not reactive. The law does not wait for scrutiny or audit to expose discrepancies; it expects voluntary alignment.

Section 28(2) empowers the proper officer to approve or reject such amendments. First proviso to Section 28(2) provides that approval of the proper officer shall not be required in respect of amendments of such particulars as may be prescribed, which are essentially non-core amendments. Further, the second proviso to Section 28(2) ensures that rejection can be made only after an opportunity to be heard has been granted, thereby embedding the principles of natural justice.

 At the same time, Section 28(3 ) introduces the concept of deemed approval, protecting genuine taxpayers from administrative inaction. It provides that any rejection or approval of amendments under the SGST Act or the UTGST Act shall be deemed to be a rejection or approval under the CGST Act.   This provision reflects legislative intent to prevent administrative inertia from paralysing genuine business changes.

Judicial thinking, particularly in writ jurisdiction, has consistently supported this approach. Courts have repeatedly observed that tax registration is intended to reflect the factual reality, and that procedural provisions governing amendments should be interpreted to facilitate, not frustrate, legitimate business operations. The emphasis is on substance over rigidity, provided the taxpayer acts transparently and in good faith.

The Procedural Spine of Registration Amendments-Rule 19

While Section 28 lays down the substantive framework, Rule 19 of the CGST Rules, 2017 provides the procedural machinery that gives it life. Rule 19(1) requires that any change in the particulars furnished at the time of registration shall be submitted electronically in Form GST REG-14 within fifteen days of such change. Rule 19(1) brings clarity and certainty, formally recognising that all amendments are not equal. It draws a clear statutory distinction between core fields, which require verification and approval by the proper officer, and non-core fields, which may be auto-approved by the system. This sub-rule explains why some amendments flow smoothly while others invite scrutiny — not as a matter of discretion, but as a matter of legislative design.

Rule 19(1A) provides that, notwithstanding anything contained in Rule 19(1), any particular of the application for registration shall not stand amended retrospectively from a date earlier than the date of submission of the application in FORM GST REG-14 on the common portal. However, a retrospective amendment can be made with the order of the Commissioner, for reasons to be recorded in writing, subject to specified conditions.

Rule 19(2) provides that where the proper officer is of the opinion that the amendment sought under Rule 19(1) is either not warranted or the documents furnished therewith are incomplete or incorrect, he may, within 15 working days from the date of receipt of the application in FORM GST REG-14, serve a show cause notice in FORM GST REG-3 requiring the registered person to show cause within 7 working days of the service of the said notice, as to why the application submitted shall not be rejected.

According to Rule 19(3), the registered person shall furnish a reply to the aforesaid notice in FORM GST REG-04 within 7 working days of the service of the said notice.

Rule 19(4) provides that where the reply furnished under Rule 19(3) is found to be not satisfactory or where no reply is furnished in response to the notice issued under Rule 19(2) within the period prescribed in Rule 19(3), the proper officer shall reject the application submitted under Rule 19(1) and pass an order in FORM GST REG-05.

According to Rule 19(5), if the proper officer fails to take any action-

the certificate of registration shall stand amended to the extent applied for, and the amended certificate shall be made available to the registered person on the common portal

Thus, in essence, Rules 19(2) to 19(5) complete the procedural chain by addressing approval, the effective date, and the communication of amendments. Together, these provisions ensure that the amendment process remains structured, time-bound, and transparent while remaining responsive to business realities.

Change of Authorised Signatory — The Digital Voice of the Taxpayer- Section 28 read with Rule 19(1), 19(1A) and 19(2)

Illustration: A company's finance manager, who was the authorised signatory, resigned 0n 3.12.2025. A new finance head joins on 01.10.2026. By promptly filing a non-core amendment to add the new authorised signatory and designate him as the primary signatory, the company ensures uninterrupted return filings and timely responses to notices, without waiting for officer approval.

In practice, this single amendment often determines whether a taxpayer remains compliant or becomes ex parte. Courts, while dealing with disputes involving filing defaults or missed communications, have acknowledged that authorised signatories act as agents of the taxpayer and that procedural law should not be applied so rigidly as to defeat substantive compliance.  Many ex parte orders under GST have their genesis not in non-compliance, but in missed digital communication.

 As an Urdu couplet reassures:

"कानून की राह कठिन नहीं होती ,
नियत साफ़ हो तो मंज़िल दूर नहीं होती। "

Other Non-Core Amendments - Small Changes, Large Compliance Impact - Rule 19(2) read with Section 28

Non-core amendments often appear innocuous, but in practice, they carry disproportionate compliance consequences. Changes in email address or mobile number directly determine whether OTPs, notices, deficiency memos, and refund intimations are received or missed. Many disputes originate not from tax evasion but from silence, silence caused by outdated electronic contact details.

Similarly, bank account amendments, though non-core, sit at the intersection of GST compliance and financial settlement. Refunds frequently get stalled not because tax is unpaid, but because bank details on the portal no longer match operational reality. Additional places of business and changes in the nature of goods or services supplied also fall in this category. Though auto-approved, these details are closely examined during audits and inspections, where inconsistencies often trigger deeper enquiry. During audits, officers often treat these ‘auto-approved' fields as indicators of intent rather than mere data points.

Illustration: A registered person adds export services to his business but fails to update the nature of services on the GST portal. During refund processing, mismatches between declared business activity and refund claims can lead to detailed scrutiny, delaying legitimate refunds.

As experience shows:

" जो बदलाव छोटे लगते हैं ,
वही बाद में सबसे बड़े प्रश्न बन जाते हैं। "

Directors, Partners and Promoters - When Governance Changes Become Core Amendments - Section 28(2) & (4) read with Rule 19(1A) and 19(3)

Changes in directors, partners, promoters, karta, or trustees strike at the heart of governance and control. GST law treats such changes as core amendments because they alter the tax administration's understanding of who controls the business and who bears ultimate responsibility for compliance.

GST does not permit these changes to be recognised independently of corporate law. The appointment or resignation of directors must first be effected under the Companies Act, 2013, and reflected by filing Form DIR-12 with the Registrar of Companies. Only thereafter can the GST portal be amended, subject to the approval of the proper officer. Until such approval is granted, the earlier particulars continue to remain valid for GST purposes, including issuance of notices and determination of responsibility, on the portal. While MCA compliance is a prerequisite, GST approval remains a distinct statutory satisfaction.

Illustration: A company appoints a new director on 1 January and files DIR-12 on 5 January. The GST core amendment is filed on 10 January. Until the proper officer approves the amendment, the GST portal continues to reflect the earlier board composition, even though the MCA records have already been updated.

Judicial reasoning consistently supports this approach. Courts have observed that tax authorities are entitled to rely on statutory records and that legal recognition flows from formal documentation, not merely from internal resolutions.

" कानून इरादों को नहीं ,
रिकॉर्ड को देखता है। "

Other Core Amendments - Identity, Place and Constitution of Business -Section 28 read with Rule 19(3) to 19(5)

Core amendments extend beyond governance changes. A change in the business's legal name, even without a PAN alteration, affects invoices, e-way bills, and public identity and therefore requires officer approval. A change in the principal place of business affects jurisdiction, inspection authority, and place-of-supply considerations, often triggering physical verification.

Changes in the constitution of business, such as admission or retirement of partners within the same PAN, also require core amendment approval. Where the PAN itself changes — for example, conversion of a proprietorship into a company - GST law mandates fresh registration, cancellation of the old registration, and transfer of ITC where permissible. Rule 19(4) clarifies the effective date of approved amendments, while Rule 19(5) ensures formal communication of approval or rejection, completing the statutory loop. Failure to distinguish between amendment and fresh registration is a frequent source of irreversible ITC loss.

Residual Penalty Exposure - Section 125 of the CGST Act

While neither Section 28 of the CGST Act nor Rule 19 of the CGST Rules prescribes a specific penalty for failure to amend registration particulars, it is important to note that Section 125 of the CGST Act, 2017 provides for a residual penalty. This provision empowers the tax authorities to levy an effective penalty up to 50,000 [up to Rs. 25,000 each under the CGST Act and relevant SGST Act] under the CGST Act where a person contravenes any provision of the Act or the Rules for which no separate penalty is expressly provided.

In theory, therefore, failure to intimate changes in registration particulars within the prescribed time may attract scrutiny under Section 125. However, legislative design and judicial approach indicate that this provision is intended to address substantive contraventions with compliance impact, not routine procedural lapses. In practice, Section 125 is invoked sparingly and generally only where non-amendment of registration particulars results in misrepresentation, prolonged non-alignment of records, or obstruction of tax administration.

Thus, Section 125 operates not as an automatic penal trigger, but as a statutory backstop, reinforcing the expectation that registration particulars must reflect business reality.

When Governance Ultimately Speaks Through Records

GST is often described as a tax on supply, but in substance, it is equally a tax on transparency. The law does not merely ask what you supply; it asks who you are, where you operate, and who stands behind your compliance. Section 28 of the CGST Act and Rule 19 of the CGST Rules together make it clear that registration is the backbone of this transparency.

Many disputes that appear technical at first glance are, at their core, failures of alignment between business reality and statutory records. When boardroom decisions do not echo on the GST portal, governance becomes silent where it should speak. Timely and accurate amendments protect the taxpayer not through litigation, but through discipline .

A final thought worth carrying forward:

"कानून से बचने की कोशिश नहीं ,
कानून के साथ चलने की आदत
व्यवसाय को सुरक्षित रखती है।

Frequently Asked Questions (FAQs)

FAQ 1: Is the amendment of GST registration optional or mandatory when business particulars change?

Reply 1: Amendment of GST registration is not a matter of choice; it is a statutory obligation. Section 28(1) of the CGST Act, 2017, places a positive and continuing duty on every registered person to intimate any change in the particulars furnished at the time of registration. The law proceeds on the assumption that registration reflects current business reality rather than historical facts. Failure to amend registration particulars within the prescribed time does not merely result in procedural non-compliance; it may vitiate return filings, invalidate refund claims, and weaken the taxpayer's defence in scrutiny, audit, or enforcement proceedings.

FAQ 2: What is the legal distinction between core and non-core amendments under GST?

Reply 2: The distinction between core and non-core amendments flows from legislative design, not administrative discretion. Core amendments are those that affect the identity, governance, or jurisdictional footprint of the registered person—such as the legal name, principal place of business, directors, partners, promoters, or the business's constitution. These require verification and approval by the proper officer .

Non-core amendments, on the other hand, relate to operational or communicative particulars such as authorised signatory details, mobile number, email address, bank account, or additional places of business. These are generally auto-approved by the system , recognising the need for agility in day-to-day business operations. However, auto-approval does not dilute their legal importance.

FAQ 3: Can GST registration amendments be made retrospectively?

Reply 3: As a general rule, amendments to GST registration cannot operate retrospectively. Rule 19(1A) expressly provides that no amendment shall take effect from a date earlier than the date of submission of Form GST REG-14. This ensures data integrity in a system that relies heavily on timelines for compliance, matching, and analytics. However, the law does provide a limited exception. A retrospective amendment may be permitted only with the Commissioner's approval, for reasons recorded in writing and subject to the prescribed conditions. This power is intended to address genuine hardship, not routine oversight.

FAQ 4: Is approval of the proper officer required for a change of authorised signatory?

Reply 4: Change of authorised signatory is categorised as a non-core amendment , and therefore does not ordinarily require prior approval of the proper officer. Once filed, the amendment becomes effective through system auto-approval.

That said, the importance of this amendment cannot be overstated. The authorised signatory is the taxpayer's digital voice. All notices, OTPs, acknowledgements, and electronic communications under GST are routed through this channel. Courts have repeatedly recognised that many procedural defaults arise not from intent, but from failure to update authorised signatory details in time.

FAQ 5: What happens if the proper officer does not act on an amendment application?

Reply 5: GST law consciously guards against administrative inaction. Rule 19(5) provides for deemed approval where the proper officer fails to take action within the prescribed timelines, either within 15 working days of application or within 7 working days of receipt of a reply to a show cause notice. In such cases, the registration certificate stands amended by operation of law , and the amended certificate is made available on the common portal. This provision reflects the principle that genuine business changes should not be held hostage to procedural delay.

FAQ 6: Can changes in directors or partners be directly updated on the GST portal?

Reply 6: No. Changes in directors, partners, or promoters cannot be recognised under GST in isolation. Such changes must first be legally effected under the governing law , such as the Companies Act, 2013 or the Partnership Act, as applicable. For companies, filing of Form DIR-12 with the Registrar of Companies is a statutory precondition. Only after the change is formally recorded in the corporate law records can a core amendment be filed on the GST portal, subject to the proper officer's approval. Until such approval is granted, earlier particulars continue to remain valid for GST purposes.

FAQ 7: Does a change in PAN require an amendment or a fresh GST registration?

Reply 7: A change in PAN strikes at the root of registration identity. Where the PAN changes, for instance, on conversion of a proprietorship into a company, the GST law does not permit amendment of the existing registration. Instead, it mandates cancellation of the old registration, obtaining a fresh registration, and transfer of the eligible input tax credit in accordance with Section 18 of the CGST Act and the relevant rules. Amendments are permitted only where the PAN remains unchanged.

FAQ 8: Are non-core amendments examined during audit or inspection?

Reply 8: Yes. While non-core amendments may be auto-approved, they are not immune from scrutiny . During audits, inspections, or refund processing, officers routinely examine email IDs, bank accounts, the nature of the business, and additional places of business to verify consistency with returns and claims. Many disputes arise not because tax is unpaid, but because the registration data does not support the taxpayer's transaction narrative.

FAQ 9: Can failure to amend registration particulars lead to adverse proceedings?

Reply 9: Indirectly, yes. While failure to amend registration may not automatically trigger penal action, it often weakens the taxpayer's position in proceedings under Sections 61, 65, 67, 73, or 74. Missed notices, jurisdictional objections, refund rejections, and adverse inference regarding intent frequently trace back to outdated registration particulars. GST law expects alignment, not perfection, but silence where disclosure is expected can prove costly.

FAQ 10: Is there any penalty for failure to amend GST registration particulars under Section 28 read with Rule 19?

Reply 10: The GST law does not prescribe any specific or automatic penalty for mere failure to amend registration particulars under Section 28 of the CGST Act read with Rule 19 of the CGST Rules. These provisions create a statutory obligation but are essentially compliance-corrective, not offence-creating. However, Section 125 provides for a residual effective penalty up to Rs. 50,000 [Rs. 25,000 each under the CGST Act and the respective SGST Act] where any provision of the Act or Rules is contravened and no specific penalty is prescribed elsewhere. In exceptional cases, prolonged or deliberate failure to amend registration particulars, especially where it results in misrepresentation, administrative obstruction, or misleading statutory records, may expose the taxpayer to penalty under Section 125. Importantly, a penalty under Section 125 is not automatic and is generally discouraged for bona fide procedural lapses without revenue implications. GST law expects alignment with business reality, not punitive action for every delay.

FAQ 11: What is the practical compliance takeaway for businesses?

Reply 10: The true compliance lesson under GST is simple yet profound: Boardroom decisions must echo on the GST portal without delay. Whether the change relates to governance, operations, communication, or location, timely amendment of registration particulars is not defensive compliance—it is preventive discipline. In a data-driven tax system, transparency is not merely a virtue; it is protection.