Assessment of unregistered persons
Section 63, CGST Act
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Section 63 covers assessment of UNREGISTERED persons (who were liable but did not register) or those whose registration was cancelled – the officer assesses tax to the best of judgement within five years, after a hearing.
What this means in practice
The parts that actually decide cases — the things a practitioner checks first.
Five years from the due date of the annual return for the year; notice in ASMT-14 and order in ASMT-15, with a hearing.
It applies to persons who were liable but did not register, and to those whose registration was cancelled but who continued to be liable.
The exact words of the law
795 characters, uneditedReproduced from the CBIC text. We explain it above — but you should always be able to read it yourself.
Read the full provision+
(2) of section 29 but who was liable to pay tax, the proper officer may proceed to assess the tax liability of such taxable person to the best of his judgment for the relevant tax periods and issue an assessment order within a period of five years from the date specified under section 44 for furnishing of the annual return for the financial year to which the tax not paid relates: Provided that no such assessment order shall be passed without giving the person an opportunity of being heard.
High Court cases on this section
Judgments in our index that cite this provision. Being listed does not make a case good law — it may have been appealed or distinguished since. Read it before relying on it.
LAXMIKANTA PANIGRAHI v. THE COMMISSIONER CT AND GST ODISHA
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Tvl.SRP Communications v. The State Tax Officer (Intelligence), Inspection I
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Tvl Periyasamy Chandran v. The Deputy State Tax Officer (ST) -1,
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What changed, and when
The amendment trail, newest first — because the version that applies to your case depends on the period.
date not stated · Inserted
Inserted by section 131 of The Finance Act (No. 2) Act, 2024 No. 15 of 2024 dated 16.08.2024.
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Where this comes from
Text reproduced from the Central Board of Indirect Taxes and Customs, as available on 2026-09-05. The explanation and practice notes above are GSTZone’s own, written for this hub. If you spot anything out of date, tell us and we’ll fix it — this hub is checked daily against CBIC.
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