Finance Compliance Consultant
692 Points
Posted on 09 May 2026
Since the services were provided before the effective date of GST registration, GST cannot be charged for that earlier period, provided the client was not liable for compulsory registration earlier and the turnover threshold was not crossed before registration.
Hence, the treatment would generally be as follows:
- Issue a normal commercial invoice / bill for the past services.
- Mention clearly:
- “Services rendered prior to GST registration date”
- “GST not applicable”
- Do not charge GST on such invoices if:
- registration was obtained later voluntarily or after threshold crossing in Feb 2026, and
- services were completed before the liability date.
However, if:
- the person had already crossed the threshold limit earlier, or
- GST liability actually arose before Feb 2026,
then GST may become payable from the date he became liable for registration under Section 22, even if registration was obtained later. In that situation, tax invoices with GST may need to be issued and GST liability may arise with interest implications.
Practical approach:
- Check aggregate turnover month-wise.
- Determine the exact “liable for registration” date.
- If liability started only from Feb 2026 onward, then old services remain outside GST.
Example:
- GST Registration Date: 15 Feb 2026
- Work completed: July 2025
- Invoice raised now in May 2026
If not liable earlier:
→ Raise invoice now without GST mentioning:
“Supply pertains to pre-registration period.”