Section 27 – Special provisions for casual taxable person & non-resident taxable person
Section 27 of CGST Act, 2017 – Special Provisions for Casual Taxable Person and Non-Resident Taxable Person
Updated on: February 2026 (as applicable till date)
Prepared by: Yours Tax Consultant
1. Bare Act – Section 27
Section 27(1):
A casual taxable person or a non-resident taxable person
shall apply for registration at least
five days prior
to the commencement of business.
Section 27(2):
The registration granted shall be valid for:
- 90 days from the effective date of registration, or
- Such shorter period as specified in the application
Proviso:
The proper officer may extend the registration period
for a further period not exceeding 90 days.
2. Meaning of Casual Taxable Person (CTP)
As per Section 2(20), a Casual Taxable Person means:
A person who occasionally undertakes transactions involving supply of goods or services in a State or Union Territory where he has no fixed place of business.
Examples:
- Exhibition or trade fair participants
- Seasonal or temporary business operators
- Event-based suppliers
3. Meaning of Non-Resident Taxable Person (NRTP)
As per Section 2(77), a Non-Resident Taxable Person means:
A person who occasionally undertakes supplies but has no fixed place of business or residence in India.
Examples:
- Foreign consultants supplying services in India
- Overseas exhibitors participating in Indian exhibitions
4. Mandatory Advance Registration – Section 27(1)
Unlike normal taxpayers:
- CTP and NRTP must apply in advance
- Application must be filed at least 5 days before commencement
Failure to apply in advance can result in:
- Illegal supply
- Penalty and tax demand
Relevant Rule:
5. Advance Deposit of Tax – Mandatory Condition
A casual taxable person and non-resident taxable person must make an advance deposit of tax equivalent to the estimated tax liability.
This deposit:
- Is made at the time of registration
- Appears in the electronic cash ledger
- Can be used for payment of tax
Without advance deposit, registration is not activated.
6. Validity of Registration – Section 27(2)
Initial validity:
- Maximum 90 days
Extension:
- Further extension up to 90 days
- Subject to payment of additional advance tax
Relevant Rule:
7. Composition Scheme Not Available
CTP and NRTP:
- Cannot opt for composition scheme
- Must pay tax at normal rates
This restriction applies irrespective of turnover.
8. Returns and Compliance
CTP and NRTP are required to:
- File returns for the period of registration
- Pay tax using advance deposit
- Comply with invoice and reporting provisions
Non-compliance can lead to:
- Blocking of refunds
- Penalty proceedings
9. Section 27 vs Regular Registration
| Particular | CTP / NRTP | Regular Taxpayer |
|---|---|---|
| Advance registration | Mandatory | Not required |
| Advance tax deposit | Mandatory | Not applicable |
| Validity period | 90 + 90 days | Continuous |
| Composition scheme | Not allowed | Allowed (if eligible) |
10. Related Provisions
- Section 24 – Compulsory registration
- Section 25 – Procedure for registration
- Section 29 – Cancellation of registration
11. Professional Note
Section 27 is a strict provision. Advance registration and advance tax deposit are mandatory conditions. Any supply without compliance is treated as illegal supply under GST.
Disclaimer: This article is prepared based on the CGST Act, CGST Rules and notifications as applicable till date. Future amendments or judicial rulings may require updates.
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