GSTN has issued an important advisory on 5th December 2025 about auto suspension of GST registration for not updating the Bank Account details.
As per CGST Rule 10A, all taxpayers (except those registered under TCS, TDS, or suo-moto registrations) must update their bank account details within 30 days of registration or before filing GSTR-1 or IFF, whichever is earlier.
Key Updates on GST Portal Regarding Rule 10A:
2. How to Add Bank Account Details: Update your bank account details using a non-core amendment at “Services > Registration > Amendment of Registration (Non-Core Fields)”
4. Manual Option to Drop Proceedings: If cancellation proceedings are not dropped automatically on the same day, you can manually initiate the process at “Services > User Services > View Notices and Orders > Initiate Drop Proceedings”
5. Exemptions: OIDAR and NRTP taxpayers are not required to furnish bank account details. However, OIDAR taxpayers who select “Representative Appointed in India” as Yes must provide bank account details.
For official/updated details from GSTN, please refer the Advisory dated 05/12/2025
This advisory from GSTN lacks several critical details that could lead to confusion and compliance risks. It does not clarify the business impact of suspension, like inability to file returns, generate e-way bills, etc. nor does it warn about cancellation of registration if bank details remain unfurnished beyond some time period. The timeline for furnishing bank details is ambiguous, and exemptions for OIDAR and NRTP taxpayers are not fully clarified. It also fails to emphasize that suspension is automatic and system-driven, with no prior manual notice, and overlooks the requirement to declare all business-linked bank accounts, not just one. These gaps make the advisory incomplete:
1. Impact of Suspension Not Mentioned Clearly: The advisory fails to explain the operational consequences of suspension. When a GST registration is suspended, the taxpayer cannot file returns (like GSTR-1 or IFF), cannot generate e-way bills, and recipients may lose Input Tax Credit (ITC). These are critical business impacts that taxpayers need to know upfront to avoid disruptions in supply chain and compliance.
2. Ambiguity on Timeline: The advisory states “within 30 days of grant of registration” but does not clarify whether this period starts from the approval date or the effective date of registration. This ambiguity can lead to misinterpretation and unintentional non-compliance. A clear definition with examples (e.g., “If registration is approved on 1st Dec, deadline is 31st Dec”) should be included.
3. OIDAR Clause Could Mislead: The advisory mentions that furnishing bank details is not mandatory for OIDAR taxpayers unless they appoint a representative in India. However, it does not clarify similar conditions for NRTP (Non-Resident Taxable Persons). This incomplete information can mislead foreign businesses and cause compliance gaps.
4. No Warning About System-Driven Action: The advisory should emphasize that suspension is automatic and system-driven, without any prior manual notice from a tax officer. Many taxpayers assume they will receive a warning or notice before suspension, which is incorrect. This misunderstanding can result in sudden suspension and business disruption.
5. No Mention of Consequences for Delay Beyond Suspension: While the advisory explains how to drop cancellation proceedings after furnishing bank details, it does not warn that if details are not updated even after suspension, cancellation proceedings will start, potentially leading to permanent loss of GSTIN. This is a serious consequence that should be highlighted.
6. Does Not Emphasize Multiple Bank Accounts: Rule 10A expects taxpayers to declare all bank accounts linked to their business, not just one. The advisory ignores this requirement, which could lead to partial compliance and future notices. It should clearly state that all operational bank accounts must be furnished.
I tried to keep the comment shorter but unable to explain all these issues with lesser words.