Issues / Concerns of Compulsory registration:
a. Mandatory registration: Although a person engaged exclusively in the supply of exempted goods/services is exempted from obtaining registration u/s 23 of the Act, he will be required to obtain registration u/s 24, if he procures the notified goods /services (covered under the provisions of Section 9(3) of the CGST Act), even though Section 23 gives immunity to such persons from registration. Section 23 and Section 24 of the Act are independent sections and Section 24 cannot override Section 23 of the Act (or vice – versa) and mandate registrations for such persons who are exempted from registration under Section 23 of the Act.
It appears that this is an anomaly in law. It simply means that a person not liable for registration should under no circumstance be required to register.
It may note that vide Notification 10/ 2017 – IGST dated 13 October 2017, persons making inter-state supply of services and having turnover not exceeding INR 20 lakhs have been exempted from obtaining registration. Accordingly, only persons who make inter-state supply of goods have to compulsorily obtain registration irrespective of the all- India turnover.
However, the aggregate value of supply of services should not exceed INR 10 lakhs in respect of States as mentioned in Article 279A( 4) (g), i.e. Jammu and Kashmir, Himachal Pradesh, Uttarakhand, Sikkim, Arunachal Pradesh, Nagaland, Mizoram, Meghalaya, Manipur, Assam and Tripura.