Section 139 of the CGST Act, 2017

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GST›CGST Act, 2017›Chapter XX, Transitional Provisions

At a glance

Entitlement and conditions

  • 139(3)Where cancellation follows the person’s application that registration was not required under section 22 or section 24, the provisional certificate is deemed never issued.

Procedure, powers and definitions

  • 139(1)–(2)Existing-law registrants with a valid Permanent Account Number receive provisional certificates from the appointed day in the prescribed form and manner. Unless replaced by final certificates, these are liable to cancellation for non-compliance; final certificates follow prescribed conditions.

Persons registered under existing laws with a valid Permanent Account Number receive provisional registration from the appointed day, subject to prescribed requirements. A final certificate follows under the prescribed process. Failure to meet provisional conditions exposes the certificate to cancellation; cancellation on an application establishing no registration liability treats the provisional certificate as never issued.[1]

Text

The text below is the section as served by the CBIC tax information portal on 17 September 2026, with the portal's own amendment footnote markers (shown as small numerals before a bracket) and its footnotes.[1] The Act as published in the Gazette of India is the legal source.

Section 139, verbatim (show)

* 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. *Enforced w.e.f. 22nd June, 2017.

Questions to answer on the file

Questions a reviewer answers from the engagement file, grouped by the part of the section they come from. They describe what the section asks; they do not decide it.

Provisional issue 139(1) opening

Questions to answer on the file9 questions
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Liability to cancellation 139(1) closing

Questions to answer on the file3 questions
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Final certificate 139(2)

Questions to answer on the file3 questions
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Deemed non-issue 139(3)

Questions to answer on the file4 questions
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Amendment history

The CBIC text carries 1 footnote. The table gives each in the source's own terms. Effective dates are as the footnotes state them.[1]

Amendments to section 139 as footnoted in the CBIC text
NoteEffective from
22.06.2017
Provisions connected to Section 139
ProvisionConnectionWords that tie them
Section 2139(1) defined by Section 2139(1) "the appointed day"; 139(1) "existing laws"
Section 22139(3) requires Section 22139(3) "not liable to registration under section 22"
Section 24139(3) requires Section 24139(3) "or section 24"

Circulars and notifications

Circulars and notifications in the CBIC repository that cite this section, newest first, by number, date and subject. A listing here does not say what an instrument decides; read the instrument.

Notifications (1)

NumberDateSubject
Notification No. 94/2020-Central Tax22 December 2020Seeks to make the Fourteenth amendment (2020) to the CGST Rules, 2017.

See also

References

  1. Central Board of Indirect Taxes and Customs. "Section 139. Migration of existing taxpayers". Central Goods and Services Tax Act, 2017, CBIC tax information portal, with amendment footnotes 1 to 1. Retrieved 17 September 2026.

External links