The landmark tax reform GST came into force from 1st July 2017. Many people who weren’t registered under earlier indirect tax laws, who surrendered their registrations under earlier laws and more and more diverse sort of people came into the GST net voluntarily. In some cases the tax officers themselves approached the potential taxpayers and made them get registered under GST. So many events happened in the months of April-June 2017 and even after that.
The existing taxpayers who were registered under the earlier indirect tax regime such as VAT or Service Tax or Central Excise were given a provisional ID, the migration process for the same to be completed by 31st March 2018. There were some people who forgot to migrate by the said date. When approached, the website said to make a fresh application. And those people got their GSTIN with the 13th character being 2. The 13th digit indicates number of registrations in a state. Now this new registration obtained stands to be second registration in a state. And the earlier one (provisional ID with 13th digit as 1) being the first registration is standing like a soul of dead person. The soul is to be merged with the body. But what to do, the soul has to wait.
There are another set of people. They were taxpayers who surrendered their registrations under earlier regime such as VAT/ST/CE. But these people have been granted provisional ID. But without knowing this, they applied for a new registration voluntarily while GST came into force. One person had cancelled his service tax registration way back in 2008 or 2009. But for him provisional ID has been generated. This was discovered now in September 2018. How? This person also has got the 13th character as 2 in his GSTIN. When he logged in to GST portal and under the search taxpayer -> search by PAN option, when he typed his GST number, he was alarmed to know that one registration number bearing his PAN with 13th character as 1 with status ‘inactive’ and another with 13th character 2 with status as ‘active’.
So his soul was departed from body and new soul is now being active! Now only one soul can be in a body right? So, for the departed soul a new body is to be created and thus the soul is to be activated. Notification 31/2018 – Central Tax dated 6th August 2018 laid down the procedure for activating the soul 1. The notification said 31st August 2018 was last date. But, The Hindu Businessline newspaper dated 03rd September 2018 reported that 1800 taxpayers migrated under this window and it was said by an official that still state tax officers are compiling data.
So, the moral of story is:
- Taxpayers who forgot or did not complete their migration by 31st March 2018 and were said to apply for a fresh registration and have got the fresh registration with 13th character 2.
- Taxpayers who have been earlier registered with VAT/ST/CE but cancelled their registrations under earlier laws, whether or not they have applied for registration under GST, they are provided with provisional ID. So, they shall approach nodal officers of the state or central tax office as said in notification 31/2018 – central tax and activate the souls.
In other words, if you have two businesses and have knowingly taken two registrations then 13th character being 2 is correct. Else, your soul with 13th character 1 is hanging in the air. Go and give re-birth for it!
Good news is that, once the soul is re-born, GSTR 3B beginning from July 2017 till November 2018 can be filed on or before 31st December 2018. And GSTR 1 monthly return can be filed for the same period before 31st December 2018. GSTR 1 quarterly return till quarter ending 30th September 2018 can be filed before 31st December 2018.