GST Registration Without a Bank Account: Updated Rules, Timelines & Compliance Requirements

1. Grant of New GST Registration Without Bank Account

GST registration can be initially granted without pre-existing bank account details.

Legal Basis:

• Rule 10A of CGST Rules (as amended by Notification No. 31/2019-CT dated 28.06.2019, further amended by Notification No. 38/2023-CT dated 04.08.2023):

  • The requirement to furnish bank account details is not a pre-condition for the grant of GST registration.

  • Registration is granted based on application and verification; the bank account details must be provided after the registration is approved and the GSTIN is issued.

2. Formalities After Grant of Registration

Time Limit and Procedure

• As per Rule 10A (read with Notification No. 38/2023-CT dt. 04.08.2023, effective 4 August 2023):

  • Registered persons (except those registered under Rule 12 or Rule 16) must furnish their bank account details, which:

    • Are in the name of the registered person,

    • Are obtained on the PAN of the registered person,

    • Must be furnished within 30 days from the date of grant of registration OR before furnishing outward supply details in FORM GSTR-1 or using the Invoice Furnishing Facility, whichever is earlier.

  • Proprietorship Firms: The PAN of the proprietor must be linked with the Aadhaar number of the proprietor.

Process Summary

3. Consequences of Not Updating Bank Account Details

Legal Action for Non-Compliance

• Rule 10A mandates the timely furnishing of bank account details. Non-compliance is treated as a lapse in registration.

Possible Actions by Authorities:

• Suspension/ Cancellation of Registration:

  • If a registered person does not furnish bank account details within the prescribed time, the registration is liable to be cancelled under Section 29 and rules thereunder.

  • GST portal automation may block the facility to upload invoices, file GSTR-1/3B, or claim refunds.

Practical Impact:

• Inability to generate tax invoices (may be blocked by portal),

• Loss of eligibility to claim input tax credit,

• Frozen operations under GST till compliance is restored.

4. Summary Table — Key Provisions

5. Key Legal Citations and Amendments

• Rule 10A of CGST Rules: Prescribes post-registration furnishing of bank account details (Notification No. 31/2019-CT).

• Notification No. 38/2023-CT dated 04.08.2023: Latest amendment reducing time to submit bank account to 30 days (was 45 days earlier).

• Section 29(2)(c) of the CGST Act, 2017 (read with Rule 21): Registration may be cancelled if a registered person violates provisions of the Act or the Rules.

6. Practical Guidance for Taxpayers

• Bank account opening can occur after GSTIN is allotted.

• Act promptly post-registration to open bank account and update details to ensure uninterrupted GST compliance.

• Monitor portal notifications post-registration—delays invite cancellation and disruption in business transactions.

Conclusion:

New GST registrations can be granted even if the applicant has not yet opened a bank account. However, it is mandatory to update bank account details on the GST portal within 30 days of registration grant or before filing details of outward supplies (GSTR-1), whichever is earlier. Non-compliance will lead to suspension or cancellation of GST registration and related compliance penalties.

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