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Section 27 of the CGST Act, 2017: Special Provisions for a Casual Taxable Person and a Non-Resident Taxable Person

The certificate is valid for the period specified in the application or ninety days from the effective date of registration, whichever is earlier. The proper officer may, on...

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Published
October 2, 2026
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Oct 3, 2026
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Last updated: October 2026Applies to: FY 2026-27Verified against: Government sources

Section 27 of the Central Goods and Services Tax Act, 2017 carries three special rules for a casual taxable person and a non-resident taxable person: how long the certificate of registration is valid, an advance deposit of tax at the time of application, and where that deposit goes. It is a short section of three sub-sections, but each has a proviso or a cross-reference that matters.

This article follows the CGST Act, 2017 as amended up to 31 October 2025 in the compilation consulted; notifications issued after that date should be checked.

The section behind the rules

Section 27 sits in Chapter VI, "Registration". Who a casual or non-resident taxable person is, and how each applies, is covered by sections 2, 24 and 25 and by rules 13 to 15; see rules 13 to 15 on non-resident taxable persons, OIDAR suppliers and extension of the period and section 25: procedure for registration, which sets the five-day advance application for these two kinds of person. This article is confined to what section 27 itself prints. If you plan a temporary business in India or have a foreign principal making supplies here, our registration service for all types of taxpayers can map the steps.

Section 27(1): validity and the extension

"The certificate of registration issued to a casual taxable person or a non-resident taxable person shall be valid for the period specified in the application for registration or ninety days from the effective date of registration, whichever is earlier and such person shall make taxable supplies only after the issuance of the certificate of registration".

The sub-section therefore does two things:

  1. It caps the validity. The shorter of the period the applicant asked for and ninety days from the effective date.
  2. It bars supplies before the certificate. The person makes taxable supplies "only after the issuance of the certificate of registration".

The proviso gives the proper officer a discretion: "the proper officer may, on sufficient cause being shown by the said taxable person, extend the said period of ninety days by a further period not exceeding ninety days". The words are "may", "sufficient cause being shown" and "not exceeding ninety days". The section does not say how the extension is applied for; the rules do (see rules 13 to 15). The extension is on the ninety days, so the outer limit set by the section is ninety plus ninety days, when the application itself asked for a long enough period.

Section 27(2): the advance deposit

"A casual taxable person or a non-resident taxable person shall, at the time of submission of application for registration under sub-section (1) of section 25, 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".

The deposit is tied to three things: the time (when the application is submitted), the amount (the estimated tax liability) and the period (the one for which registration is sought). The proviso adds: "where any extension of time is sought under sub-section (1), such taxable person shall deposit an additional amount of tax equivalent to the estimated tax liability of such person for the period for which the extension is sought".

The section does not say who makes the estimate, how it is made or what happens if the estimate proves wrong. It leaves those points to the rules and the form.

Section 27(3): where the deposit goes

"The amount deposited under sub-section (2) shall be credited to the electronic cash ledger of such person and shall be utilised in the manner provided under section 49." See sections 49 to 53: payment and electronic ledgers for section 49. Sub-section (3) thus treats the deposit as ordinary cash in the person's own ledger, available to pay tax in the order section 49 provides.

Section 27 at a glance

Sub-sectionSubjectKey words as printed
27(1)Validity"the period specified in the application for registration or ninety days from the effective date of registration, whichever is earlier"
Proviso to 27(1)Extension"extend the said period of ninety days by a further period not exceeding ninety days"
27(2)Advance deposit"an amount equivalent to the estimated tax liability" for the period sought
Proviso to 27(2)Deposit on extension"an additional amount of tax equivalent to the estimated tax liability" for the extension
27(3)Credit of deposit"credited to the electronic cash ledger" and "utilised in the manner provided under section 49"

Who does what, by when

WhoWhatWhen
Casual or non-resident taxable personMakes the advance deposit of estimated tax for the period soughtAt the time of submission of the application under section 25(1)
Same personMakes suppliesOnly after the certificate of registration is issued
Proper officerMay extend the ninety days by up to ninety daysOn sufficient cause being shown
Same personDeposits additional tax for the extension periodWhen the extension is sought

A worked example

All names and amounts are assumed. Alpine Expo Services, an invented trade-fair organiser from outside the State, will run a stall business for eighty days and applies for registration as a casual taxable person, specifying that period in its application. Its certificate is valid for the period specified or ninety days from the effective date, whichever is earlier: eighty days. At the time of submitting the application it deposits tax equal to its estimated liability for those eighty days, say 2,40,000 rupees, and the amount is credited to its electronic cash ledger (sub-section (3)). It makes no taxable supply until the certificate is issued.

Halfway through, the fair is extended. The proper officer, on sufficient cause being shown, may extend the period by a further period not exceeding ninety days. For the extension, Alpine Expo Services deposits an additional amount equal to the estimated liability for the extra period, say 1,00,000 rupees, under the proviso to sub-section (2).

Points to watch

  • The word "earlier". A long period in the application does not stretch the certificate beyond ninety days from the effective date.
  • Supply only after issue. The prohibition is in sub-section (1) itself.
  • The deposit is not a fee. It is credited to the electronic cash ledger of the person.
  • Extension is not automatic. It needs sufficient cause and the officer's decision.

Need help registering a temporary or foreign business?

The validity, the deposit estimate and the extension all depend on the plan for the business. We help you decide the period to apply for, estimate the deposit and prepare the application. See our registration service for all types of taxpayers.

Key takeaways

  • A casual or non-resident taxable person's certificate is valid for the period in the application or ninety days from the effective date, whichever is earlier.
  • The proper officer may extend the ninety days by a further period not exceeding ninety days, on sufficient cause.
  • An advance deposit equal to the estimated tax liability is made at the time of the application; an additional deposit is made for an extension.
  • The deposit is credited to the electronic cash ledger and used under section 49.
  • Taxable supplies may be made only after the certificate is issued.

Read next

Disclaimer: Based on the Central Goods and Services Tax Rules, 2017 and the GST Acts as amended up to 31 October 2025 in the compilation consulted, read with the Finance Act, 2026 where this article says so, as consulted on 2 October 2026. Notifications, circulars and amendments issued after that date, the forms on the common portal and the way the tax authorities apply these provisions should be checked. This article is general information, not legal advice; check the official text before acting.

Quick recapKey facts & short answers

Key Facts About Section 27

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

How long is the certificate valid?

For the period specified in the application or ninety days from the effective date of registration, whichever is earlier (section 27(1)).

Can it be extended?

Yes, by the proper officer, on sufficient cause being shown, by a further period not exceeding ninety days.

Do not copy last year's filing without checking whether last year's law still applies.

— TaxClue Compliance Desk

Section 27: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

For the period specified in the application or ninety days from the effective date of registration, whichever is earlier (section 27(1)).

Yes, by the proper officer, on sufficient cause being shown, by a further period not exceeding ninety days.

An amount equivalent to the estimated tax liability for the period for which registration is sought (section 27(2)); an additional amount for any extension.

At the time of submission of the application for registration under section 25(1).

It is credited to the electronic cash ledger of the person and utilised in the manner provided under section 49 (section 27(3)).

No. Section 27(1) says taxable supplies are made only after the certificate of registration is issued.