Tax Consultant
1596 Points
Posted on 07 July 2026
This situation has two parts: the penalty for late registration and the GST liability for the gap period.
GST liability for December to May:
Once you crossed Rs 20L, you were required to register within 30 days. From that point, all taxable supplies should have had GST applied even without registration. So you likely owe GST on all invoices raised from January (30 days after crossing in December) to the date of actual registration in May.
How to handle it:
- Compute all supplies made in the gap period
- Calculate GST due (typically 18% for professional services)
- Pay the tax plus interest at 18% per annum for the delay
- File a voluntary disclosure before the department issues a notice
Penalty for late registration:
Section 122 of the CGST Act applies: 10% of tax due or Rs 10,000, whichever is higher. Voluntary disclosure before any notice typically results in the lower end of the penalty scale.
The practical priority: compute and pay the gap-period tax now. Once that is done, the penalty becomes secondary.
For the full interest and late fee calculation framework, this [GST late fee and penalty guide](https://taxgarden.in/blog/gst-late-fee-interest-penalty-gstr-3b-gstr-1-gstr-9-guide) covers Sections 47 and 50 in detail.