Service taxregistration issue

This query is : Resolved

Querist : Anonymous

Querist : Anonymous (Querist)

03 September 2013

My client is engaged in providing diagnostic lab testing service having its registered office at Mumbai with a corporate office situated at Delhi.

Mumbai is looking after the all India operations plus Delhi and under Delhi there is 7 different labs in north India where system of centralised billing is not adopted.

Mumbai do separate billings and Delhi do their own. Further, the other Labs coming under Delhi region also do separate billings but the accounts however is compiled

together of all locations and a single return is submitted in the IT deptt.

So, my query is that whether if Delhi wants to apply for service tax registration No. then whether it would apply for centralized registration for Delhi and Labs coming under

Delhi region or single registration have to be done for Delhi and its Labs separately.

Would feel glad to have a reply from your side. Awaiting for your response.

Thanking you in anticipation.

Arun Kumar Singh

Arun Kumar Singh (Expert)
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03 September 2013 You can choose for any location for centralize registration as per your convenient. You should consult with any professional.

Querist : Anonymous

Querist : Anonymous (Querist)

03 September 2013 Dear Mr. Arun,
Thanks for your prompt reply. but It means that in your word I have to apply for different registration no for different Locations...?

Arun Kumar Singh

Arun Kumar Singh (Expert)
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03 September 2013 I am not telling you that different registration no. for different locations but you can apply for centralize registration for all units as per your convenient.

Querist : Anonymous

Querist : Anonymous (Querist)

03 September 2013 ok thank you sir.
I got you now.

But can we apply for Delhi+ labs under Delhi by a single registration and For Mumbai a different reg. no.??

Aashok Kumar Sharma

Aashok Kumar Sharma (Expert)
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25 July 2025 Yes, your understanding is now correct.

Given your client’s operational structure, **you can apply for centralized registration** for **Delhi and the 7 labs under the Delhi region**, and have a **separate registration for Mumbai**, provided the following conditions are met:

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### ✅ **Centralized Service Tax Registration – Key Conditions (as per Rule 4(2)(i) of Service Tax Rules, 1994):**

1. **Billing or accounting is centralized** at one premise for multiple service locations.
2. The centralized premise must be registered under the **Companies Act / other applicable laws**.
3. The centralized premise must handle **billing or accounting** for all the associated units.
4. The centralized location must be **responsible for discharging the service tax liability** for all associated premises.

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### ✔ Your Case:

| Location | Billing Status | Eligible for Centralized Reg.? | Notes |
| -------- | ---------------- | -------------------------------- | ------------------------------------------------------------------------------------------------------------------------- |
| Mumbai | Does own billing | Yes (Separate Registration) | Mumbai handles All India ops, can remain independently registered. |
| Delhi | Does own billing | Yes (with labs under it) | If Delhi corporate office manages **accounting/tax compliance** for its 7 labs, it can seek **centralized registration**. |
| 7 Labs | Do own billing | Covered under Delhi Central Reg. | If accounts are consolidated in Delhi, labs don’t need separate ST registrations. |

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### 📌 Final Answer:

Yes, **you can have:**

* **One Service Tax Registration** for **Delhi + its 7 labs** (centralized registration, if Delhi handles their accounting/tax).
* **A separate Service Tax Registration** for **Mumbai**.

Ensure proper documentation, declarations, and justification are submitted with the ST-1 form while applying for centralized registration.

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Let me know if you'd like help drafting the application or explanation for centralized registration.

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