Mandatory registration for exporter of service below Rs.20 lacs.

CA Arindam Sain (Practice) (308 Points)

25 June 2020  

Dear Professional Colleagues & Friends,

I have a doubt regarding registration under GST for a person who is exporting service and no turnover in India and total value is less than 20 lacs. As per sec.24 of CGST act for compulsory registration (irrespective of turnover threshold limit ) states inter state taxable supply is subject to mandatory registration. As export is being treated as interstate supply, applying this analogy , export also comes under mandatory registration but by Notification No.10/2017 dated 13th October,2017 it specifically states that Interstate supply of SERVICE is out of mandatory registration if aggregate turnover is below Rs.20 lacs. Again a FAQ published by CBIC on 15th December,2018, where in page no.51 it states that mandatory registration to be required for interstate taxable supply without discussing the above mentioned notification for service providers below 20 lacs.

My query is whether an exporter of service , who's aggregate turnover is less than 20 lacs is required to take registration mandatorily  under the act?

Please share your thoughtful insight which will enrich all of us.