GST REG-31 Notice: Your GST Registration Has Been Suspended

Source: Section 29(2) proviso, CGST Act 2017; Rule 21A, CGST Rules 2017.

• •Return non-filing: More than 3 consecutive periods of GSTR-3B non-filing (or 2 consecutive quarters for composition dealers).
• •Comparison-based system triggers: The system finds significant differences between GSTR-3B and GSTR-1 across multiple periods.
• •Significant discrepancy in ITC claimed: Claimed ITC is significantly higher than what suppliers have filed.
• •Application for voluntary cancellation filed: Your own application for cancellation can trigger a temporary suspended status while the application is processed.
• •Direction from a higher authority: Based on intelligence, surveys, or investigation outcomes.

• •For return non-filing: File all pending returns immediately with full tax, interest, and late fees. File a response to the REG-31 on the GST portal explaining the situation and confirming that returns have been filed. The officer will review and either restore the registration or proceed to issue REG-17.
• •For system-generated discrepancy triggers: Prepare a reconciliation showing the GSTR-1 vs GSTR-3B differences with explanations. File the response on the portal within 30 days. Attach supporting documents.
• •While suspended: You cannot file GSTR-1 and GSTR-3B (the portal locks these). Focus first on responding to REG-31 to get the suspension lifted, which unlocks the return filing.

• •Inform them immediately that your GSTIN is temporarily suspended and that you are working to restore it.
• •Advise them to hold off claiming ITC on your recent invoices until the suspension is lifted.
• •Once restoration is confirmed, inform them explicitly so they can proceed with ITC claims.
• •Consider holding new invoicing until the restoration is confirmed - issuing invoices while suspended creates ITC risk for your clients and puts your business relationships under strain.