We have obtained dual registration in Delhi, one for Financing and other for govt business. We are now feeling that dual registration are not useful and unnecessary increasing compliance formalities. Can I surrender one registration and transfer my ITC in other registration
As per Section 29(1) registration can be cancelled only when business in discontinued / transferred etc or there is change in constitution of the business or a taxable person is no longer liable to be registered u/s 22 or 24 of the CGST Act, 2017.
Prima-facie based on facts stated it appears none of the conditions are fulfilled and thus it seems registration cannot be surrendered.
Further even if we assume registration is cancelled, specific provisions of ITC transfer in such cases does not exists and there could be chance of credit loss. Thus even if we want to surrender, it is better to first utilise the entire credit and thus apply for surrender. This will insulate us from any credit loss.
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