Other Provisions & Procedure

Migration of existing taxpayers

Section 139, CGST Act

Chapter 20 Text as on 2026-09-05 Source CBIC

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Section 139 provided for MIGRATION of taxpayers registered under the earlier laws (VAT, service tax, excise) to GST, granting provisional and then final registration.

What this means in practice

The parts that actually decide cases — the things a practitioner checks first.

1

Spent for new taxpayers; it still matters when a provisional registration from 2017 is questioned or a migration-era GSTIN is under scrutiny.

How this provision is built

The skeleton, clause by clause — useful when a notice cites a specific sub-clause.

(1) On and from the appointed day, every person registered under any of the existing laws and having a valid Permanent Account Number shall be issued a certificate of registration on provisional basis, subject to such condit…
(2) The final certificate of registration shall be granted in such form and manner and subject to such conditions as may be prescribed.
(3) The certificate of registration issued to a person under sub-section (1) shall be deemed to have not been issued if the said registration is cancelled in pursuance of an application filed by such person that he was not l…

The exact words of the law

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Reproduced from the CBIC text. We explain it above — but you should always be able to read it yourself.

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* Section 139. Migration of existing taxpayers.-

(1) On and from the appointed day, every person registered under any of the existing laws and having a valid Permanent Account Number shall be issued a certificate of registration on provisional basis, subject to such conditions and in such form and manner as may be prescribed , which unless replaced by a final certificate of registration under sub-section (2), shall be liable to be cancelled if the conditions so prescribed are not complied with.

(2) The final certificate of registration shall be granted in such form and manner and subject to such conditions as may be prescribed.

(3) The certificate of registration issued to a person under sub-section

(1) shall be deemed to have not been issued if the said registration is cancelled in pursuance of an application filed by such person that he was not liable to registration under section 22 or section 24 .

What changed, and when

The amendment trail, newest first — because the version that applies to your case depends on the period.

2017-07-01 · Commenced

Provision as originally enacted in the CGST Act, 2017 (Act 12 of 2017) and brought into force w.e.f. 01-07-2017.

Read this with

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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.

section 139 cgstmigration of existing taxpayers

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