UNIT 6
REGISTRATION
In any tax system, registration is the most fundamental requirement for identification of tax payers ensuring tax compliance in the economy. Registration of any business entity under the GST Law implies obtaining a unique number from the concerned tax authorities for the purpose of collecting tax on behalf of the government and to avail input tax credit for the taxes on his inward supplies. Without registration, a person can neither collect tax from his customer nor claim any input Tax Credit of tax paid by him.
Need and Advantages of registration
Registration will confer the following advantages to a taxpayer:
- He is legally recognized as supplier of goods or services.
- He is legally authorized to collect taxes from his customer and pass on the credit of the taxes paid on the goods or services supplied to the purchasers/recipients.
- He can claim Input Tax Credit of taxes paid and utilize the same for payment of taxes due on supply of goods or services.
- Seamless flow of Input Tax Credit from suppliers to recipients at the national level.
1. Every supplier liable to be registered if aggregate turnover in financial year exceeds Rs.40 lakhs / 20 lakhs in Special Category States [SEC 22(1)]:
Every supplier shall be liable to be registered under this Act in the state or Union territory, other than special category states, from where he makes a taxable supply of goods or goods and services both, if his aggregate turnover in a financial year exceeds Rs. 40 lakhs.
Where such person’s makes taxable supplies of goods or services or both from any of the special category states, he shall be liable to be registered if his aggregate turnover in a financial year exceeds Rs. 20 lakhs.
Meaning of Aggregate turnover [SEC 2(6)]: “Aggregate turnover” means the aggregate value of:
- All taxable supplies. (Excluding the value of inward supplies on which tax is payable by a person on reverse charge basis.)
- Exempt supplies.
- Exports of goods or services or both.
- Inter – state supplies.
Of persons having the same PAN number, to be computed on all India basis, but excludes :
a) Central tax
b) State tax
c) Union territory tax
d) Integrated tax and
e) Cess.
2. Every supplier liable for registration will have to take a separate registration in every state even though such supplier may be supplying goods or services or both from more than one state as a single entity.
3. Registrants under existing law required to obtain registration under GST [SEC 22(2)]:
Every person who, on the day immediately preceding the appointed day, is registered or holds a license under an existing law, shall be liable to be registered under this Act with effect from the appointed day.
Appointed day [sec 2(10)]
“Appointed day” means the date on which the provision of this act shall come into force i.e. 1.7.2017.
4. Transfer of Business – Transferee to obtain fresh registration [sec 22(3)]:
Where a business carried on by a taxable person registered under this Act is transferred, whether on account of succession or otherwise, to another person as a going concern, the transferee or the successor, as the case may be, shall be liable to be registered with effect from the date of such transfer or succession.
5. Transfer pursuant to scheme for amalgamation/demerger – transferee liable to be registered from date of incorporation [sec 22(4)]:
Notwithstanding anything contained in sub-section (1) & (3), in a case of transfer pursuant to sanction of a sanction of a scheme or an arrangement for amalgamation or, as the case may be, demerger of two or more companies pursuant to an order of a High Court, Tribunal or otherwise, the transferee shall be liable to be registered, with effect from the date on which the registrar of Companies issues a certificate of incorporation giving effect to such order of the high court or tribunal.
6. Supply of goods by Job- worker to be included in supplies of principal
The supply of goods, after completion of Job-worker by a registered job-worker shall be treated as the supply of goods by the principal referred to in sec 143 and the value of such goods shall not be included in the aggregate turnover of the registered job-worker.
7. Special category States
“Special category States” shall mean the states as specified in article 279 A (4)(g) of the Constitution. They are states which opted for new limit of Rs.20lakhs for sale of goods.
- Arunachal Pradesh
- Meghalaya
- Manipur
- Mizoram
- Puducherry
- Telangana (10 lakhs)
- Nagaland
- Sikkim
- Tripura
- Uttarakhand
Persons not liable for registration [sec 23(1)] :
- Persons engaged exclusively in supplying goods /services/both not liable to tax
- Persons engaged exclusively in supplying goods /services/both wholly exempt
- Agriculturist limited to supply of produce out of cultivation of land
- Specified category of persons notified by the Government
Compulsory registration in certain cases [sec 24] : Notwithstanding anything contained in section 22(1), the following categories of persons shall be required to be registered under this Act –
- Persons making any inter-state taxable supply
- Casual taxable persons making taxable supply
- Persons who are required to pay tax under reverse charge
- Persons who are required to pay tax under sec 9(5) i.e. E- commerce operator who is required to pay tax on specified services
- Non- resident taxable persons making taxable supply
- Persons who are required to deduct tax under sec 51, whether or not separately registered under this Act.
- Input Services Distributor, whether or not separately registered under this act
- Persons who make taxable supply of goods or services or both on behalf of other taxable persons whether as an agent or otherwise
- Persons who supply goods or services or both, other than supplies specified under section 9(5) through such electronic commerce operator who is required to collect tax at source under section 52
- Every electronic commerce operator
- Every person supplying online information and database access or interval services from a place outside India, other than a registered person
- Such other person or class of person as may be notified by the government on the recommendation of the council.
Procedure for registration is governed by section 25 of the CGST Act read with relevant CGST Rules, 2017. Relevant provisions of CGST Rules, 2017 have been incorporated at the relevant places. Further, special provisions have been provided for registration of casual taxable person and non-resident taxable person under section 27. Concept of deemed registration has been elaborated under section 26.
Under GST, the application for registration has to be submitted electronically at the GST Common Portal – www.gst.gov.in, duly signed or verified through Electronic Verification Code (EVC)
Around 30 forms/formats have been prescribed in the CGST Rules, 2017. For every process in the registration chain such as application for registration, acknowledgment, query, rejection, registration certificate, show cause notice for cancellation, reply, cancellation, amendment, field visit report etc., there are standard formats10. This makes the process uniform all over the country. The decision-making process has also been expedited. Strict time lines have been stipulated for completion of different stages of registration process.
- Where and by when to apply for registration? [Section 25(1)]
PARTICULARS | WHERE | WHEN |
Person who is liable to be registered under section 22 or section 24 | In every such State/UT in which he is so liable | Within 30 days from the date on which he becomes liable to registration |
A casual taxable person or a non-resident taxable person | At least 5 days prior to commencement of business |
2. State-wise registration [Section 25(2) read with rule 11]
- One registration per State
- Registration needs to be taken State-wise, i.e. there are no centralized registrations under GST. A business entity having its branches in multiple States will have to take separate State-wise registration for the branches in different States.
- Further, within a State, an entity with different branches shall be granted single registration wherein it can declare one place as principal place of business (PPoB) and other branches as additional place of business (APoB).
b. Separate registration for different places of business within a State/UT may be granted
- Although a taxpayer having multiple places of business in one State is not mandatorily required to obtain separate registration for each such place of business in the State, he has an option to obtain independent registrations with respect to each such separate place of business.
- However, separate registration for each place of business shall be granted provided all separately registered places of business of such person pay tax on supply of goods/services/both made to another registered place of business, of such person and issue a tax invoice/bill of supply for such supply. Separate registration application needs to be filed for each place of business
- A registered person opting to obtain separate registration for a place of business shall submit a separate application in Form GST REG 01 in respect of such place of business.
- The provisions of rules 9 and 10 [Discussed in subsequent paras] relating to verification and grant of registration shall mutatis mutandis apply to an application submitted under this rule.
c. Composition levy in case of separate registration for multiple places of business within a state/UT
- If a person is paying tax for one of his places of business under normal scheme, he shall not pay tax under composition levy for any other place of business.
- If one of the places of business [separately registered] of a registered person becomes ineligible to pay tax under composition levy, all other registered places of business of said person would also become ineligible to pay tax under composition levy.
- The provisions of rules 9 and 10 [Discussed in subsequent paras] relating to verification and grant of registration shall mutatis mutandis apply to an application submitted under this rule.
- Voluntary registration [Section 25(3)]
A person who is not liable to be registered under section 22 or section 24 may get himself registered voluntarily. In case of voluntary registration, all provisions of this Act, as are applicable to a registered person, shall apply to voluntarily registered person. However, once a person obtains voluntary registration, he has to pay tax even though his aggregate turnover does not exceed 20 lakhs/10 lakhs.
Voluntary registration is usually obtained by the business for ensuring seamless flow of credit to their customers.
4. Distinct Persons/ establishments of distinct persons [Section 25(4) & (5)]
A person who has obtained/ is required to obtain more than one registration, whether in one State/ Union territory or more than one State/Union territory shall, in respect of each such registration, be treated as distinct persons.
Further, where a person who has obtained or is required to obtain registration in a State or Union territory in respect of an establishment, has an establishment in another State or Union territory, then such establishments shall be treated as establishments of distinct persons.
5. PAN must for obtaining registration [Section 25(6) & (7)]
Permanent Account Number is mandatory to be eligible for grant of registration.
6. Unique Identity Number (UIN) [Section 25(9) & (10) read with rule 17]
Any specialized agency of the United Nations Organization or any Multilateral Financial institution and organization as notified under the United Nations (Privileges and Immunities)
Act, 1947, consulate or embassy of foreign countries and another person notified by the Commissioner, is required to obtain a UIN from the GSTN portal.
This UIN is needed for claiming refund of taxes paid on notified supplies of goods and/or services received by them, and for such other purpose as may be notified. UIN granted is a centralized UIN i.e. it shall be applicable to the territory of India. A person having UIN is not registered person and thus, is not a taxable person.
The proper officer may, upon submission of an application in prescribed form or after filling up the said form or after receiving a recommendation from the Ministry of External Affairs, Government of India, assign a UIN to the said person and issue registration certificate within 3 working days from the date of submission of application.
7. Suo-motu registration by the proper officer [Section 25(8) read with rule 16]
Where, pursuant to any survey, enquiry, inspection, search or any other proceedings under the Act, the proper officer finds that a person liable to registration under the Act** has failed to apply for such registration, such officer may register the said person on a temporary basis and issue an order in prescribed form.
**Such person shall either:
- Submit an application for registration in prescribed form within 90 days from the date of grant of temporary registration, or
- File an appeal against such temporary registration.
In case (ii), if the Appellate Authority upholds the liability to registration, application for registration shall be submitted within 30 days from the date of issuance of such order of the Appellate Tribunal.
Provisions relating to verification and issue of registration certificate [as contained in rules 9 and 10] [discussed in subsequent paras] shall, mutatis mutandis, apply to such application submitted by the person granted temporary registration. GSTIN thereafter granted shall be effective from the date of order of proper officer granting temporary registration.
8. Procedure for registration [Section 25 read with rules 8, 9 & 10]
Provisions relating to procedure for application for registration, verification of the application and approval & issue of registration certificate are contained in the rules 8, 9 and 10 of the CGST Rules, 2017 respectively. The same have to be read in conjunction with section 25 provisions. However, procedure so laid down will not apply to:
Non-resident taxable person
A person required to deduct tax at source under section 51
A person required to collect tax at source under section 52
A person supplying OIDAR services from a place outside India to a non-taxable online recipient referred to in section 14 of IGST Act.
Thus, procedure for registration prescribed under rules 8, 9 and 10 are also applicable to a person paying tax under composition levy, every person seeking voluntary registration as well as a casual taxable person.
Such persons shall apply for registration in Form GST REG 01. The application for registration in GST Form REG 01 is divided into two parts – Part A and Part B.
In order to cater to the needs of tax payers who are not IT savvy, Facilitation centres have been established which help the taxpayer in submitting the application for registration, amending the registration certificate, submitting application for cancellation of registration, revocation of cancellation of registration, etc. Facilitation Centre shall be responsible for the digitization and/or uploading of the forms and documents.
Application for registration by Special Economic Zone (SEZ) [Second proviso to section 25(1): A person having unit in SEZ/an SEZ developer will have to make a separate application for registration as distinct from his place of business located outside SEZ in the same State/UT. Thus, there may be a case where two units of a tax payer are located in same State/UT - one in SEZ and another outside SEZ. In that case, separate registrations have to be obtained for each of the two units as separate places of business.
9. Effective date of registration [Rule 10]
Where an applicant submits application for registration | Effective date of registration is |
Within 30 days from the date he becomes liable to registration | The date on which he becomes liable to registration |
After 30 days from the date he becomes liable to registration | Date of grant of registration |
Registration under GST is not tax specific, which means that there is single registration for all the taxes i.e. CGST, SGST/UTGST, IGST and cesses.
Grant of registration/UIN under any SGST Act/ UTGST Act is deemed to be registration/UIN granted under CGST Act provided application for registration has not been rejected under CGST Act.
Further, rejection of application for registration/UIN under SGST Act/UTGST Act is deemed to be rejection of application for registration under CGST Act.
(A) Meaning of casual taxable person and non-resident taxable person
Before going into nuances of the registration provisions of CTP and NRTP, let us first understand the meaning of casual taxable person and non-resident taxable person:
Casual Taxable Person
There may be case where a person has a registered business in some State in India, but wants to effect supplies from some other State in which he does not have any fixed place of business. Such person needs to register in the Stat from where he seeks to supply as a ‘casual taxable person’.
CGST Act defines a casual person as a person who occasionally undertakes transactions involving supply of goods or services or both in the course or furtherance of business, whether as principal, agent or in any other capacity, in a State/UT where he has no fixed place of business [Section 2(20)]. He cannot exercise the option to pay tax under composition levy.
Non-Resident Taxable Person
A person who is a foreigner and occasionally wants to effect taxable supplies from any State in India needs GST registration for the same. Such person needs to register in the State from where he seeks to supply as a non-resident taxable person. CGST Act defines non-resident taxable person as any person who occasionally undertakes transactions involving supply of goods or services or both, whether as principal or agent or in any other capacity, but who has no fixed place of business or residence in India [Section 2(77)]. He cannot exercise the option to pay tax under composition levy.
Based on the aforesaid definitions, following points merit consideration:
A CTP does not have a fixed place of business in the State/UT where he undertakes supply though he might be registered with regard to his fixed place of business in some other State/UT, while a NRTP does not have fixed place of business/residence in India at all.
A CTP has to undertake transactions in the course or furtherance of business whereas the business test is absent in the definition of NRTP.
(B) Special registration provisions of casual taxable person and non- resident taxable person
GST law prescribes special procedure for registration, as also for extension of the operation period of such casual or non-resident taxable persons. They have to apply for registration at least 5 days in advance before making any supply. Also, registration is granted to them or period of operation is extended, only after they make advance deposit of the estimated tax liability. The special registration procedure pertaining to CTP and NRTP are as follows:
Both CTP and NRTP have to compulsorily get registered under GST irrespective of the threshold limit, at least 5 days prior to commencement of business.
As per section 25(6), every person must have a PAN to be eligible for registration. Since NRTP will generally not have a PAN of India, he may be granted registration on the basis of other prescribed documents.
He has to submit a self-attested copy of his valid passport along with the application signed by his authorized signatory who is an Indian Resident having valid PAN. However, in case of a business entity incorporated or established outside India, the application for registration shall be submitted along with its tax identification number or unique number on the basis of which the entity is identified by the Government of that country or its PAN, if available.
Application will be submitted by NRTP in a different prescribed form whereas CTP will submit the application for registration in the normal form for application for registration i.e. Form GST REG 01 and his registration of CTP will be a PAN based registration.
(C) Period of validity of registration certificate granted to CTP/NRTP
Registration Certificate granted to CTP/NRTP will be valid for:
(i) Period specified in the registration application, or
(ii) 90 days from the effective date of registration [can be extended further by a period not exceeding 90 days by making an application before the end of the validity of registration granted to him**]
Whichever is earlier.
Provisions relating to verification of application and grant of registration [under rules 9 and 10] will apply mutatis mutandis, to an application for registration filed by NRTP.
(D) Advance deposit of tax
At the time of submitting the registration application, CTP/NRTP are required to make an advance deposit of tax in an amount equivalent to the estimated tax liability of such person for the period for which the registration is sought.
Such person will get a TRN for making an advance deposit of tax which shall be credited to his electronic cash ledger. An acknowledgement of receipt of application for registration is issued only after said deposit.
A registered person may need to make some changes/amendments in the registration application. There are two categories of details in registration application – core and non-core fields.
Core fields are name of the business, (legal name) if there is no change in pan, addition / deletion of stakeholders, principal place of business (other than change in State) or additional place of business (other than change in State).
All other fields are non-core fields like name of day to day functionaries, e-mail Ids, mobile numbers etc.
In case the changes is in core information in the registration application, the taxable person will apply for amendment within 15 days of the event necessitating the change. The proper officer, then, will approve the amendment within next 15 days.
For other changes – non-core information, no approval of the proper officer is required, and the amendment can be affected by the taxable person on his own on the common portal.
The provisions relating to amendment of registration are contained in section 28 read with rule 19 of CGST Rules, 2017.
The significant aspects of the same are discussed hereunder:
Where there is any change in the particulars furnished in registration application/UIN application, registered person shall submit an application in prescribed manner, either at the time of obtaining registration or Unique Identity Number or as amended from time to time, within 15 days of such change, along with documents relating to such change at the Common Portal.
In case of amendment of core fields of information, the proper officer may, on the basis of information furnished or as ascertained by him, approve or reject amendments in the registration particulars in the prescribed manner. Such amendment shall take effect from the date of occurrence of event warranting such amendment.
However, where change relates to non-core fields of information, registration certificate shall stand amended upon submission of the application for amendment on the Common Portal.
The proper officer shall not reject the application for amendment in the registration particulars without giving the person an opportunity of being heard.
Any rejection or approval of amendments under the SGST/UTGST Act shall be deemed to be a rejection or approval under this Act.
Any particular of the application for registration shall not stand amended with effect from a date earlier than date of submission of application for amendment on common portal except with order of Commissioner for reasons to be recorded in writing and subject to conditions specified by Commissioner in the said order
Application for amendment of registration cannot be filed for change in PAN because GST registration is PAN-based. One needs to make fresh application for registration in case there is change in PAN. Thus. Where a change in the constitution of any business results in change of PAN of a registered person, the said person shall apply for fresh registration.
Similarly, application for amendment of registration form cannot be filled if there is change in place of business from one State to the other because GST registrations are State-specific. If one wishes to relocate his business to another State, he must voluntarily cancel his current registration and apply for a fresh registration in the State he is relocating his business.
Cancellation of Registration [Section29]:
1. Cancellation of Registration Either suo motu or on Application by Registered Person Section 29(1)]:
The proper officer may:
a) either on his own motion, or
b) on an application field
i) by the registered person, or
Ii) by his legal heirs, in case of death of such person,
Cancel the registration, in such manner and within such period as may be prescribed.
Circumstances in Which Registration is Cancelled:
The registration can be cancelled having regard to the following circumstances where:
a) the business has been:
i) discounted
Ii) transferred fully for any reason including death of the proprietor,
Iii) amalgamated with other legal entity,
Iv) demerged, or
v) otherwise disposed of; or
b) there is any change in the constitution of the business; or
c) the taxable person, other than the person registered under Section 25(3) i.e. voluntary registration, is no longer liable to be registered under Section 22 or Section 24.
2. Cancellation of Registration by Proper Officer [Section 29(2)]:
The proper officer may cancel the registration of a person from such date, including any retrospective date, as he may deem fit, where:
a) a registered person has contravened such provisions of the Act or the rules made there under as may be prescribed; or
b) a person paying tax under Section 10 i.e. composite levy has not furnished returns for 3 consecutive tax periods; or
c) any registered person, other than a person specified in Section 29(1)(b), has not furnished returns for a continuous period of 6 months; or
d) any person who has taken voluntary registration under Section 25(3) has not commenced business within 6 months from the date of registration; or
e) registration has been obtained by means of fraud, willful misstatement or suppression of facts.
Opportunity of Being Heard:
The proper officer shall not cancel the registration without giving the person an opportunity of being heard.
3. Cancellation of Registration not to Affect Tax Liability [Section 29(3)]:
The cancellation of registration under this section shall not affect the liability of the person to pay tax and other dues under this Act or to discharge any obligation under this Act or the rules made there under for any period prior to the date of cancellation whether or not such tax and other dues are determined before or after the date of cancellation.
4. Cancellation Under SGST/ UTGST Act Deemed Cancellation CGST Act [Section 29(4)]:
The cancellation of registration under the State Goods and Services Tax Act or the Union Territory Goods and Services Tax Act, as the case may be, shall be deemed to be a cancellation of registration under this act.
5. Pay ITC Availed on Goods in Stock or Output Tax Whichever is Higher [Section 29(5)]:
Every registered person whose registration is cancelled shall pay an amount calculated in such manner as may be prescribed, by way of debit in the electronic credit ledger or electronic cash ledger:
a) equivalent to the credit of input tax in respect of:
i) inputs held in stock, or
Ii) inputs contained in semi – finished goods held in stock, or
Iii) inputs contained in finished goods held in stock, or
Iv) capital goods or plant and machinery
On the day immediately preceding the date of such cancellation, or
b) the output tax payable on such goods,
Whichever is higher.
Payment in Case of Capital Goods:
In case of capital goods or plant and machinery, the taxable person shall pay:
a) an amount equal to the input tax credit taken on the said capital goods or plant and machinery, reduced by such percentage points as may be prescribed; or
b) the tax on the transaction value of such capital goods or plant and machinery under Section 15,
Whichever is higher.
6. Computation of Amount Payable in Prescribed Manner [Section 29(6)]:
The amount payable under Section 29(5) shall ne calculated in such manner as may be prescribed.
7. Procedure for cancellation of registration [Rules 20 and 22]
(a) Voluntary cancellation by registered person Application
- A registered person seeking cancellation of registration shall electronically submit the application for cancellation of registration in prescribed form within 30 days of occurrence of the event warranting cancellation.
- He is required to furnish in the application the details of inputs held in stock or inputs contained in semi-finished/finished goods held in stock and of capital goods held in stock on the date from which cancellation of registration is sought, liability thereon, details of the payment, if any, made against such liability and may furnish relevant documents thereof.
Order
- Where a person who has submitted an application for cancellation of his registration is no longer liable to be registered, proper officer shall issue the order of cancellation of registration within 30 days from the date of submission of application for cancellation.
(b) Suo-motu cancellation by the Department
- Where the proper officer cancels the registration suo-motu, he shall not cancel the same without giving a show cause notice and without giving a reasonable opportunity of being heard, to the registered person. The reply to such show cause notice (SCN) has to be submitted within 7 days of service of notice.
- If reply to SCN is satisfactory, proper officer shall drop the proceedings and pass an order in prescribed form. However, where the person instead of replying to the SCN served for failure to furnish returns for a continuous period of 6 months (3 months in case of composition scheme supplier)14 furnishes all the pending returns and makes full payment of the tax dues along with applicable interest and late fee, the proper officer shall drop the proceedings and pass an order.
Where registration of a person is liable to be cancelled, proper officer shall issue the order of cancellation of registration within 30 days from the date of reply to SCN.
(c) Effective date of cancellation
The cancellation of registration shall be effective from a date to be determined by the proper officer and mentioned in the cancellation order. He will direct the taxable person to pay arrears of any tax, interest or penalty including the amount liable to be paid under section 29(5).
Revocation of cancellation of registration [Section 30 read with rule 23]
(a) Procedure for revocation of cancellation
Where the registration of a person is cancelled suo-motu by the proper officer, such registered person may apply for revocation of the cancellation to such proper officer, within 30 days from the date of service of the order of cancellation of registration.
If the proper officer is satisfied that there are sufficient grounds for revocation of cancellation, he may revoke the cancellation of registration, by an order within 30 days of receipt of application and communicate the same to applicant.
Otherwise, he may reject the revocation application. However, before rejecting the application, he has to first issue SCN to the applicant who shall furnish the clarification within 7 working days of service of SCN. The proper officer shall dipose the application (accept/reject the same) within 30 days of receipt of clarification.
(b) Where registration was cancelled for failure of registered person to furnish returns
Where registration was cancelled for failure of registered person to furnish returns, before applying for revocation, the person has to make good the defaults, i.e. the person needs to file such returns. However, the registration may have been cancelled by the proper officer either from the date of order of cancellation of registration or from a retrospective date.
(1) Where the registration has been cancelled with effect from the date of order of cancellation of registration
As we have already seen that the common portal does not allow furnishing of returns after the effective date of cancellation, but returns for the earlier period (i.e. for the period before date of cancellation mentioned in the cancellation order) can be furnished after cancellation.
Where the registration is cancelled with effect from the date of order of cancellation of registration, person applying for revocation of cancellation has to furnish all returns due till the date of such cancellation before the application for revocation can be filed and has to pay any amount due as tax, in terms of such returns along with any amount payable towards interest, penalties or late fee payable in respect of the said returns. However, since the portal does not allow to furnish returns after the date of cancellation of registration, all returns due for the period from the date of order of cancellation till the date of order of revocation of cancellation of registration have to be furnished within a period of 30 days from the date of the order of revocation.
(2) Where the registration has been cancelled with retrospective effect
Where the registration has been cancelled with retrospective effect, it is not possible to furnish the returns before filing the application for revocation of cancellation of registration. In that case, the application for revocation of cancellation of registration is allowed to be filed, subject to the condition that all returns relating to the period from the effective date of cancellation of registration till the date of order of revocation of cancellation of registration shall be filed within a period of 30 days from the date of order of such revocation of cancellation of registration.