Persons not liable for registration
Section 23, CGST Act
Straight from CBIC
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Amendment history
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You are not required to register if you deal exclusively in goods/services that are wholly exempt or non-taxable under GST, or you are an agriculturist supplying your own farm produce. The Government can also exempt further categories by notification – and after the 2023 amendment this exemption power overrides even the compulsory-registration list in section 24.
What this means in practice
The parts that actually decide cases — the things a practitioner checks first.
Since the Finance Act 2023 (retrospective to 01-07-2017) section 23 OVERRIDES section 24 – a person supplying only exempt or non-taxable goods or services need not register even if he falls in a compulsory-registration category.
An agriculturist is outside only for supply of produce out of cultivation of his own land.
Notification 10/2019 (the Rs 40 lakh goods exemption) and Notification 05/2017 (persons supplying only reverse-charge supplies) are both issued under this section.
Questions people actually ask
Real questions we get on this provision, answered straight.
We only make exempt supplies but we pay reverse charge on freight. Must we register?+
No, if all your outward supplies are wholly exempt. Section 23, which now overrides section 24, keeps you outside registration even though section 24(iii) would otherwise catch a reverse-charge payer – a change made retrospectively from 01-07-2017 by the Finance Act 2023.
How this provision is built
The skeleton, clause by clause — useful when a notice cites a specific sub-clause.
The exact words of the law
714 characters, uneditedReproduced from the CBIC text. We explain it above — but you should always be able to read it yourself.
Read the full provision+
(1) The following persons shall not be liable to registration, namely:-
(a) any person engaged exclusively in the business of supplying goods or services or both that are not liable to tax or wholly exempt from tax under this Act or under the Integrated Goods and Services Tax Act;
(b) an agriculturist, to the extent of supply of produce out of cultivation of land.
(2) Notwithstanding anything to the contrary contained in sub-section
(1) of section 22 or section 24, the Government may, on the recommendations of the Council, by notification, subject to such conditions and restrictions as may be specified therein, specify the category of persons who may be exempted from obtaining registration under this Act.
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.
What changed, and when
The amendment trail, newest first — because the version that applies to your case depends on the period.
2017-07-01 · Section commenced
Original s.23 with agriculturist + wholly-exempt exclusions.
2017-07-01 · Sub-section (2) substituted with non-obstante clause (RETROSPECTIVE)
Replaced old (2) with ‘Notwithstanding anything to the contrary in s.22(1) or s.24 … subject to conditions/restrictions …’; gives s.23 exemptions overriding effect. Enacted 2023, effective retrospectively from 01-07-2017.
Read this with
A provision rarely works alone. These are the ones it points to.
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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Reading the section is one thing. Knowing whether it bites on your facts, and what it costs if it does, is another. Send us the situation – we will tell you straight, and only take it on if we can genuinely help.
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