Chapter XX - Transitional provisions
Section 139
Section 139: Migration of existing taxpayers
This historical transition provision moved eligible registrations under pre-GST laws into provisional and then final GST registration at the 2017 appointed day.
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Need advice on Section 139?
This article is for general information. Refer to the Central Goods and Services Tax Act, 2017 official text for the official provisions. If you need professional advice for your situation, contact Bizeneed.
Statutory text
Bare law
(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.
Key takeaways
Provisional registration
A person registered under an existing law with a valid PAN was to receive provisional GST registration subject to prescribed conditions.
Final certificate
Final registration depended on prescribed form, manner and conditions; non-compliant provisional registration could be cancelled.
Not liable to register
If a migrated person applied for cancellation because section 22 or 24 did not require registration, the provisional certificate was deemed not issued.
Provisional registration
A person registered under an existing law with a valid PAN was to receive provisional GST registration subject to prescribed conditions.
Final certificate
Final registration depended on prescribed form, manner and conditions; non-compliant provisional registration could be cancelled.
Not liable to register
If a migrated person applied for cancellation because section 22 or 24 did not require registration, the provisional certificate was deemed not issued.
Practical checklist
Do
- Identify the pre-GST registration and PAN at the appointed day.
- Locate provisional and final migration records.
- Check whether a section 22 or 24 non-liability cancellation occurred.
Frequently asked questions
Does section 139 create a new 2026 registration route?
No. It governs migration from existing law at the GST appointed day.
Need help applying this provision to your situation?
Contact BizeneedLast updated 10 October 2026