Our GST registration was suspended and a REG-31 arrived — what it blocks and how it lifts

The email says the registration has been suspended and points to a form called REG-31 (the notice that starts a suspension and asks you to explain). The business is still running, invoices are still being asked for, and nobody is sure whether the next sale can be billed at all. The common advice is "file the pending returns and it will be back", which is right for one kind of suspension and wrong for the other — and the difference is written into rule 21A of the CGST Rules.

What a REG-31 actually is

Suspension under rule 21A(2A) is not a penalty imposed after a hearing. It follows either a comparison of data or a contravention of rule 10A:

"(2A) Where, — (a) a comparison of the returns furnished by a registered person under section 39 with the details of outward supplies furnished in FORM GSTR-1, as amended in FORM GSTR-1A if any, or the details of inward supplies derived based on the details of outward supplies furnished by his suppliers in their FORM GSTR-1 or in FORM GSTR-1A of the previous tax period, if any, or such other analysis, as may be carried out on the recommendations of the Council, show that there are significant differences or anomalies indicating contravention of the provisions of the Act or the rules made thereunder, leading to cancellation of registration of the said person, or (b) there is a contravention of the provisions of rule 10A by the registered person, the registration of such person shall be suspended and the said person shall be intimated in FORM GST REG-31 … asking him to explain, within a period of thirty days, as to why his registration shall not be cancelled" (rule 21A(2A)).

Two features of that sentence decide most of the practical questions.

First, limb (a) compares the returns furnished under section 39 with the outward supplies furnished in GSTR-1 (as amended in GSTR-1A, if any), and with the inward supplies derived from your suppliers' GSTR-1. The test is "significant differences or anomalies", not a missed due date. A business that has filed everything can therefore still receive a REG-31 if the figures do not line up. Limb (b) is separate: a contravention of rule 10A.

Second, the thirty days in the sub-rule is a period to explain, in response to the REG-31, why the registration should not be cancelled. It is not a filing window, and by itself it does not lift a suspension.

There is a second suspension power, in rule 21A(2), where the proper officer has reasons to believe the registration is liable to be cancelled under section 29 or under rule 21 and suspends it with effect from a date he determines, pending the proceedings under rule 22. There is also rule 21A(1), under which a registration is deemed suspended when the registered person has himself applied for cancellation under rule 20. The block described below applies to all three, but the way each is lifted differs, which is why the next sections are separate.

What suspension stops, immediately

"(3) A registered person, whose registration has been suspended under sub-rule (1) or sub-rule (2) or sub-rule (2A), shall not make any taxable supply during the period of suspension and shall not be required to furnish any return under section 39" (rule 21A(3)).

And the Explanation says what "shall not make any taxable supply" means in the only way that matters to an accounts team:

"For the purposes of this sub-rule, the expression 'shall not make any taxable supply' shall mean that the registered person shall not issue a tax invoice and, accordingly, not charge tax on supplies made by him during the period of suspension" (Explanation to rule 21A(3)).

So the block is on the tax invoice, and with it on charging tax. Note the second half of sub-rule (3): you are also not required to furnish a return under section 39 while suspended. Read that together with the provisos below — for some suspensions it is the furnishing of all pending returns that triggers revocation.

One more consequence sits in the next sub-rule:

"(3A) A registered person, whose registration has been suspended under sub-rule (2) or sub-rule (2A), shall not be granted any refund under section 54, during the period of suspension of his registration" (rule 21A(3A)).

So no refund under section 54 can be granted while the suspension stands.

How a suspension lifts — the ordinary route and the deemed routes

By the officer's proceedings finishing. Sub-rule (4):

"(4) The suspension of registration under sub-rule (1) or sub-rule (2) or sub-rule (2A) shall be deemed to be revoked upon completion of the proceedings by the proper officer under rule 22 and such revocation shall be effective from the date on which the suspension had come into effect" (rule 21A(4)).

"Effective from the date on which the suspension had come into effect" is the sentence to hold on to. The revocation is effective from the suspension date, not from the date of the order. That matters for invoices dealt with in the last section below.

By the officer's discretion. The first proviso to sub-rule (4) says the suspension "may be revoked by the proper officer, anytime during the pendency of the proceedings for cancellation, if he deems fit". It is a power, not an entitlement, so it is not something to plan around.

By furnishing all pending returns, in a defined case. The second proviso to sub-rule (4):

"Provided further that where the registration has been suspended under sub-rule (2A) for contravention of the provisions contained in clause (b) or clause (c) of sub-section (2) of section 29 and the registration has not already been cancelled by the proper officer under rule 22, the suspension of registration shall be deemed to be revoked upon furnishing of all the pending returns" (second proviso to rule 21A(4)).

This is the "just file the returns" advice, and it is accurate only inside those conditions. The suspension must be one under sub-rule (2A); the contravention must be of clause (b) or clause (c) of section 29(2); the registration must not already have been cancelled; and all the pending returns must be furnished. Clause (b) of section 29(2) concerns a person paying tax under section 10 who has not furnished the return for a financial year beyond three months from the due date. Clause (c) concerns a registered person who has not furnished returns for such continuous tax period as may be prescribed.

By complying with rule 10A, in the other defined case. The third proviso (introduced by "Provided also") deals with a suspension under sub-rule (2A) for contravention of rule 10A, and says it is deemed revoked "upon compliance with the provisions of rule 10A" — again only where the registration has not already been cancelled under rule 22. Filing returns is not the stated trigger there.

A note on reading these together: sub-rule (2A) describes suspension on a comparison showing differences, or on a rule 10A contravention, while the second proviso speaks of a suspension under (2A) "for contravention of" clause (b) or (c) of section 29(2). The two are not written in the same words. The proviso should therefore not be assumed to apply just because a suspension looks like a filing failure; the REG-31 itself, which must highlight the differences, anomalies or non-compliances, shows which limb the notice rests on.

What about supplies made while suspended

Once an order having the effect of revoking the suspension has been passed, the next sub-rule engages:

"(5) Where any order having the effect of revocation of suspension of registration has been passed, the provisions of clause (a) of sub-section (3) of section 31 and section 40 in respect of the supplies made during the period of suspension and the procedure specified therein shall apply" (rule 21A(5)).

Read it as a pointer: the rule sends you to section 31(3)(a) and section 40 for supplies made during the suspension. Those provisions are not reproduced here, so this note makes no claim about what they require of the invoices or the tax charged. What the sub-rule does show is that supplies during suspension are contemplated and have a procedure attached after revocation.

What follows if the suspension is not lifted: rule 22

Suspension is pending the proceedings for cancellation under rule 22. Where the proper officer has reasons to believe the registration is liable to be cancelled under section 29:

"(1) Where the proper officer has reasons to believe that the registration of a person is liable to be cancelled under section 29, he shall issue a notice to such person in FORM GST REG-17, requiring him to show cause, within a period of seven working days from the date of the service of such notice, as to why his registration shall not be cancelled" (rule 22(1)).

The reply to a notice under rule 22(1) is furnished in FORM REG-18 within that period (rule 22(2)). Rule 22(4) adds that where the reply "or in response to the notice issued under sub-rule (2A) of rule 21A" is found satisfactory, the proper officer shall drop the proceedings and pass an order in FORM GST REG-20. Rule 22(3) provides for cancellation by order in FORM GST REG-19 where the registration is liable to be cancelled, and the thirty-day period there runs from the date of the reply to the show-cause, including one issued under rule 21A(2A).

Rule 22(4) also carries a proviso:

"Provided that where the person instead of replying to the notice served under sub-rule (1) for contravention of the provisions contained in clause (b) or clause (c) of sub-section (2) of section 29, furnishes all the pending returns and makes full payment of the tax dues along with applicable interest and late fee, the proper officer shall drop the proceedings and pass an order in FORM GST REG-20" (proviso to rule 22(4)).

Where the contravention is of clause (b) or (c) of section 29(2), furnishing all the pending returns and paying the tax dues with applicable interest and late fee, instead of replying, makes it mandatory ("shall") for the officer to drop the proceedings. That is a stronger word than the discretion in rule 21A's first proviso. Note that the proviso is worded around a notice served under sub-rule (1) of rule 22, that is, the REG-17.

Why a filing-failure suspension happens

Where it is a filing failure, the ground is in section 29(2):

"(c) any registered person, other than a person specified in clause (b), has not furnished returns for a such continuous tax period as may be prescribed" (s.29(2)(c)).

Rule 21 prescribes the period:

"(h) being a registered person required to file return under subsection (1) of section 39 for each month or part thereof, has not furnished returns for a continuous period of six months" (rule 21(h)).

Quarterly filers have a continuous period of two tax periods instead (rule 21(i)). So the arrears that put a monthly filer in this position are deeper than one missed month, which is worth knowing before counting how much has to be filed.

FAQ

We filed everything and were still suspended. How?
Rule 21A(2A) does not require a missed return. A comparison of the section 39 returns with GSTR-1 (as amended in GSTR-1A, if any), or with the inward supplies derived from suppliers' GSTR-1, showing significant differences or anomalies, is enough, as is a rule 10A contravention. Read the REG-31 for the differences or non-compliances it highlights.

Is the thirty days a deadline to file the returns?
No. The thirty days is the period to explain why the registration should not be cancelled. Furnishing all pending returns is the trigger for a deemed revocation under the second proviso to rule 21A(4), in the case that proviso describes. They are separate provisions.

Can we raise a tax invoice while suspended?
Rule 21A(3) with its Explanation says no: no tax invoice, and no charging of tax on supplies made during the period of suspension.

We have a refund pending. Will it be processed?
Rule 21A(3A) says a registration suspended under sub-rule (2) or (2A) shall not be granted any refund under section 54 during the period of suspension.

The suspension is revoked. What about supplies made in the meantime?
Rule 21A(5) sends you to section 31(3)(a) and section 40 for supplies made during suspension. The revocation is effective from the date the suspension began (rule 21A(4)).

We have not filed for eight months. Is this a suspension or already a cancellation?
Look at the form and the order. A REG-31 is the suspension intimation under rule 21A(2A); a REG-17 is the show-cause notice under rule 22(1); cancellation is by an order in REG-19. The provisos that deem a suspension revoked apply only where the registration "has not already been cancelled" under rule 22.

What to do now

• Read the REG-31 and find which ground it states: differences between returns, or a rule 10A contravention (rule 21A(2A)).
• Send your explanation within thirty days of the REG-31 (rule 21A(2A)). Missing it leaves the registration open to cancellation under rule 22.
• Do not issue a tax invoice or charge tax while the suspension stands (rule 21A(3)).
• If the ground is a filing failure under section 29(2)(b) or (c), file all pending returns; that deems the suspension revoked (second proviso to rule 21A(4)).

Have a CA review your facts before you reply to the REG-31. The ground in the notice decides which route applies.

Rules and sections quoted from the CGST Act 2017 and CGST Rules 2017 as amended to November 2025. This note is general information about the provisions, not advice on a particular registration.

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See Also

• Our GST registration was cancelled — can it still be restored, and what if the window has closed?
• I generated an e-way bill but the trip got cancelled — it's past 24 hours
• The squad stopped my truck and detained the goods — what do I do with the order in my hand?