Introduction
CBIC has constituted a Working Group to examine the proposal for centralised administration of taxpayers having the same PAN and multiple GSTINs registered under various Central Tax jurisdictions. The stated object is to promote ease of doing business and enhance administrative efficiency.
This is an important development for large and multi-State taxpayers. At present, GST is registration-centric. A person having more than one registration, whether in one State/UT or more than one State/UT, is treated as distinct persons for GST purposes under section 25(4) of the CGST Act.
Therefore, the proposal should be understood carefully. It is not necessarily a proposal for “centralised GST registration”. It is, at this stage, a proposal for centralised administration of GSTINs that are already under Central Tax jurisdiction.
Composition of the Working Group
| S. No. | Member | Designation / Office | Role |
| 1 | Shri Vinayak Chandra Gupta | Chief Commissioner, Lucknow CGST & CX Zone | Chairman |
| 2 | Shri Sanjay Mahendru | Pr. Additional Director General, HRM-I, DGHRD | Member |
| 3 | Shri Gaurav Singh | Commissioner, GST Policy Wing | Member |
| 4 | Dr. Kotraswamy M. | Commissioner, Bengaluru South CGST & CX | Member |
| 5 | Shri Pradip Gurumurthy | Commissioner, Aurangabad CGST & CX | Member |
| 6 | Officer nominated by CEO, GSTN | GSTN | Member |
| 7 | ADG (HQ), DGPM | Directorate General of Performance Management | Member |
| 8 | ADG (HQ), DG Audit | Directorate General of Audit | Member |
| 9 | Ms. Sarika Shah | Additional Commissioner, Thane Audit CGST & CX | Member |
| 10 | Ms. Shrunkhala Kangale | Director, GST Policy Wing | Member |
| 11 | Ms. Saumya Gupta | Deputy Commissioner, GST Policy Wing | Member |
The Working Group may also co-opt any officer or expert, and is required to submit its report with implementation roadmap and draft proposals within 30 days from the Office Memorandum.
Why Has This Working Group Been Formed?
The reasons flow directly from the Terms of Reference:
Same PAN
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Multiple GSTINs
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Different Central Tax jurisdictions
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Multiple interactions, audits, notices and administrative approaches
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Need to examine centralised administration
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Ease of doing business + administrative efficiency
The concern is genuine. A single legal entity may have GST registrations in many States. Different formations may examine similar issues differently. This creates duplication for taxpayers and also duplication for the Department.
Deliberation on Each Term of Reference
| Term of Reference | Key Issue | Professional Deliberation |
| 1. Examine difficulties due to multiple tax administrations | Multiple Central Tax formations deal with same PAN but different GSTINs | This can lead to repeated information requests, parallel audits, inconsistent interpretations and increased compliance cost. The Group should collect taxpayer-wise data on frequency of notices, audit overlap, summons, refunds and adjudication. |
| 2. Study erstwhile centralised registration, LTU and international best practices | Whether GST needs centralised administration by one Central Tax authority | The erstwhile Service Tax regime had centralised registration where centralised billing or accounting existed. LTU also worked as a single-window concept for large taxpayers. However, GST is a dual federal tax and State-wise registration remains core to the design. |
| 3. Optional or mandatory | Should eligible taxpayers be compelled to join? | Optional is preferable at the first stage. Mandatory centralisation may create resistance and practical issues. A graded model may be adopted: voluntary pilot, then optional scheme for eligible taxpayers, and only later mandatory for specific risk/turnover categories if legally supported. |
| 4. Extent of coverage | Only all-Central GSTINs or also mixed Central/State taxpayers? | The safer first phase should cover taxpayers whose relevant GSTINs are all under Central Tax jurisdiction. For mixed taxpayers, only Central Tax GSTINs can be covered; State-administered GSTINs should remain outside unless GST Council-level coordination is evolved. |
| 5. Criteria for deciding administering jurisdiction | Largest turnover, head office, manpower, convenience | The criteria should not be arbitrary. A weighted model may be used: largest taxable turnover, head office location, principal place of business, number of GSTINs, pending litigation, sector expertise and manpower availability. |
| 6. Administrative, legal and system-level changes | GST portal, jurisdiction mapping, notices, audit, adjudication | GSTN must support PAN-level dashboards, role-based officer access, centralised communication trail and seamless transfer of records. Legal backing may be needed for proper officer jurisdiction, audit assignment and adjudication. |
| 7. Any other measure | Residual reforms | The Group should recommend SOPs, safeguards against overlapping proceedings, taxpayer consent, migration rules, dispute allocation, monitoring mechanism and a sunset/review clause. |
Suggested Administrative Model
Eligible taxpayer identified
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PAN-level risk and compliance profile prepared
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Taxpayer opts / is selected under notified criteria
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Lead Central Tax jurisdiction assigned
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GSTIN-wise jurisdiction retained for local verification, if needed
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Centralised cell handles audit, scrutiny coordination, notices and taxpayer interface
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Local formations support physical verification and State-specific facts
This model respects GST’s registration-wise structure while reducing administrative duplication.
Legal Caution: Centralised Administration Is Not Centralised Registration
Under GST, registration is State/UT based. Section 25 provides for registration and treats multiple registrations of the same person as distinct persons.
Further, GST law contains provisions for authorisation/cross-empowerment of proper officers in certain circumstances, but such authorisation must operate within the statute and notifications.
Therefore, any centralised cell must be legally empowered. It cannot simply assume jurisdiction over all GSTINs merely because they belong to the same PAN.
Lessons from Erstwhile Law
| Erstwhile mechanism | Concern addressed | Inference for GST |
| Centralised registration under Service Tax | Businesses with centralised billing/accounting wanted one compliance point | GST may consider centralised administration, but centralised registration is difficult because GST is State-wise and destination-based. |
| Large Taxpayer Unit mechanism | Large taxpayers needed single-window interface and coordinated handling | A PAN-based central cell can reduce duplication for large taxpayers. |
| Transfer of matters to LTU / central authority | Avoid multiplicity of departmental interfaces | GST centralised cell should clearly define transfer of audit, scrutiny, adjudication and pending matters. |
| Optional participation in LTU-style structure | Taxpayers could choose single-window benefit | GST should begin with optional participation, especially for compliant large taxpayers. |
| Centralised records and returns | Department could examine consolidated compliance | GSTN should create PAN-level dashboards but preserve GSTIN-wise liabilities, ITC and place-of-supply consequences. |
Under the old Service Tax framework, centralised registration was linked to centralised billing or accounting. Trade notices under Rule 4 of the Service Tax Rules, 1994 recognised centralised registration procedures. The LTU mechanism also recognised special procedures for large taxpayers, including Rule 12BB references under Central Excise Rules, 2002.
The clear inference is: centralisation works only when law, systems, jurisdiction and records move together.
Pros of a Centralised Cell
| Advantage | Impact |
| Single point of interface | Reduces taxpayer visits and repeated replies |
| Uniform view on common issues | Avoids contradictory departmental positions |
| Better PAN-level risk assessment | Helps department detect real risk rather than fragmented risk |
| Efficient audit planning | Avoids multiple audits on similar issues |
| Faster dispute management | Common facts can be examined once |
| Better taxpayer experience | Supports ease of doing business |
Cons and Risks
| Risk | Concern |
| Jurisdictional challenge | Orders may be contested if proper officer empowerment is unclear |
| Federal sensitivity | State-administered GSTINs cannot be disturbed administratively by Centre alone |
| Over-centralisation | A distant officer may not appreciate local business facts |
| Workload concentration | One formation may become overburdened |
| Data-access concerns | GSTN access and role controls must be precise |
| Possible taxpayer hardship | If mandatory, taxpayers may lose local support and familiarity |
Recommended Way Forward
The Working Group may consider a phased and legally supported model.
First, introduce an optional pilot for taxpayers having multiple GSTINs, all under Central Tax jurisdiction. Second, provide a clear SOP for scrutiny, audit, adjudication, refund, anti-evasion references and summons. Third, build a GSTN-based PAN dashboard with GSTIN-wise drill-down. Fourth, ensure that no proceeding is duplicated on the same subject matter.
The centralised cell should be a coordination and administration mechanism, not a shortcut to disturb the statutory identity of each GSTIN.
Conclusion
The constitution of this Working Group is a welcome and timely step. Large taxpayers need certainty, consistency and a single-window approach. The Department also needs efficient, risk-based and data-driven administration.
However, the success of the proposal will depend on three safeguards:
Clear legal authority
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Robust GSTN system design
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Taxpayer-friendly implementation
If these safeguards are built in, centralised administration can become a meaningful reform. If not, it may create another layer of jurisdictional disputes.
The best approach is to begin with an optional, transparent and legally notified framework for Central Tax-administered GSTINs, and then expand only after experience, feedback and GST Council-level coordination.
Disclaimer
This article is for academic and professional discussion only. It is based on the CBIC Office Memorandum dated 18.07.2026 constituting a Working Group on centralised administration of taxpayers, and the broad statutory scheme of GST law as available on date. The proposal is only under examination and is not yet law. Readers should examine the final notification, circular, amendment or administrative instruction, as and when issued, before taking any tax position.
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