A temporary exhibition needs a registration and cash-flow plan
Where a supplier is a casual taxable person and must register, section 27 requires an advance tax deposit for the registration period. CBIC Circular 71/45/2018-GST clarifies that the estimate is net of due eligible ITC, rather than invariably the gross output tax. The certificate lasts for the requested period or ninety days from its effective date, whichever is earlier; taxable supplies can begin only after the certificate is issued.
This guide applies the CGST Act sections 2(20), 24, 25, 27 and 54, and Rules 8, 15 and 89, together with Circular 71/45/2018-GST dated 26 October 2018, issues 1–2. The GST Council’s casual-taxable-person guidance confirms the REG-01 route. Checked on 23 October 2026, the article concerns a domestic casual taxable person, not a non-resident taxable person using REG-09. Examples assume the relevant registration obligation exists and that no notified registration exemption applies.
Occasional activity in another State is not the only test
Section 2(20) concerns occasional business supplies in a State or Union territory where the person has no fixed place of business, whether acting as principal, agent or otherwise. Establish the actual facts and applicable notification relief before treating every participant as a casual registrant. A temporary visit without the relevant supply activity is not, by itself, the entire statutory test. Do not assume another State’s existing GSTIN automatically covers the exhibition supplies.
Section 25 requires a casual taxable person’s application at least five days before commencement of business. REG-01 is the normal application form for the domestic casual route. Rule 8(6) provides a temporary reference for the advance deposit, with acknowledgement following deposit. Filing five days before the event does not guarantee the certificate will be issued by opening day, so build a practical processing buffer and confirm issuance before taxable supplies.
Estimate due credit, not every tax figure on a supplier quotation
Prepare expected output tax by supply type and tax head, then identify due eligible ITC for the proposed period. Check documentation, eligibility, blocked credits, timing and utilisation restrictions. The circular is not permission to deduct speculative or ineligible credit. The numerical examples assume the stated eligible credits can lawfully offset the indicated liabilities; they do not model cross-head restrictions, reverse-charge cash payments or special cess constraints.
Deposit money is cash-ledger funding; it is not itself the final discharge of every tax liability on all eventual sales. Reconcile actual supplies, eligible credit and tax payment through the applicable returns. If actual net liability grows, provide the additional funding. A lower actual turnover does not automatically return the unused cash to the bank.
The certificate period may be much shorter than ninety days
Read the actual effective and expiry dates. A person requesting twenty days cannot assume the unused portion of a ninety-day maximum is automatically available for more sales. Section 27 permits an extension on sufficient cause by the proper officer, subject to the statutory further-period limit. Rule 15 requires REG-11 before the current validity ends, with the additional estimated-tax deposit needed for acknowledgement. An application or deposit alone does not establish that extension has been granted.
The circular directs exhibitors running beyond 180 days to normal registration rather than indefinite repetition of the casual route. It discusses the exhibition allotment/consent letter as place-of-business evidence and no casual-registration advance tax for that normal registration. Plan a change of route early if the project is no longer temporary; do not carry a casual certificate beyond its lawful period.
Close returns before asking for unused advance tax
Section 54(13) prevents refund of the section 27 advance until all section 39 returns for the certificate’s full operative period have been furnished. Rule 89 also ties the claim to the last required return. Reconcile the electronic cash ledger, actual liability, payment and remaining balance, then use the applicable refund procedure. The balance in an internal spreadsheet is not enough if the portal tax or return record differs.
The casual regime does not supply a general composition option. Retain the exemption/registration decision, event permission, deposit record, actual certificate, outward-supply and ITC working, returns and refund evidence together. This is particularly useful where the head-office team funds the event but local staff issue invoices.
Worked illustrations
These illustrations use fictional facts and expressly stated assumptions. Amounts are Indian rupees unless a different currency or unit is specified. They are independent examples, not findings about any actual client.
Illustrative example 1: Single-rate exhibition with due eligible credit
Assume taxable exhibition sales of ₹12,00,000 at 18%, all amounts exclusive of tax. Estimated output tax = ₹2,16,000. Due eligible and usable ITC is ₹96,000. Estimated net advance deposit = ₹1,20,000. For the assumed intra-State split, output CGST/SGST is ₹1,08,000 each, credit ₹48,000 each, and net cash ₹60,000 each. Do not deposit the gross ₹2,16,000 merely because the estimate starts with turnover.
Illustrative example 2: Separate two rate buckets before netting credit
Assume sales of ₹5,00,000 at 5% and ₹3,00,000 at 18%, with rates already independently established. Output tax = ₹25,000 + ₹54,000 = ₹79,000. Due eligible, usable ITC is ₹19,000, giving net estimated tax ₹60,000. Applying one rate to the whole ₹8,00,000 would misstate the starting liability.
Illustrative example 3: Remove blocked credit from the estimate
Expected taxable sales are ₹7,00,000 at 18%, producing ₹1,26,000 output tax. Purchase records show ₹90,000 GST, but a separate eligibility review establishes ₹40,000 is blocked and ₹50,000 is due eligible and usable. Net deposit = ₹1,26,000 − ₹50,000 = ₹76,000. Deducting all ₹90,000 would predict only ₹36,000, understating funding by ₹40,000.
Illustrative example 4: Actual trading needs more funding
A ₹1,20,000 advance was deposited. At closing, actual output tax is ₹2,60,000 and actual eligible usable credit ₹1,05,000. Net tax is ₹1,55,000, so additional cash funding is ₹35,000, assuming no other ledger balances, charges or adjustments. The advance estimate does not cap the actual liability.
Illustrative example 5: Extension carries its own estimate
A duly requested thirty-day extension is expected to generate ₹4,00,000 of sales at an assumed 18%, ₹72,000 output tax. Due eligible usable credit for that additional period is ₹22,000. Additional estimated tax deposit is ₹50,000. Submit REG-11 before existing validity ends and verify the extension order; the ₹50,000 deposit does not itself authorise continued supplies.
Illustrative example 6: Unused advance is a refund reconciliation
Advance cash deposit is ₹1,20,000; final net tax lawfully discharged from it is ₹87,000. With no other debits or adjustments, unused balance is ₹33,000. That amount is a potential refund balance to reconcile, not an automatic bank payment on the event’s closing date. Furnish all required section 39 returns for the operative registration period before the section 27 advance-refund claim.
Illustrative example 7: A short request ends before the statutory maximum
Assume a certificate explicitly effective 1 November 2026 through 20 November 2026 for a twenty-day exhibition. Using the certificate’s stated inclusive dates, validity is twenty days; ninety days from 1 November on the same inclusive counting basis would end 29 January 2027. The earlier period controls, so sales on 21 November are not covered unless a lawful extension or other valid registration applies. For business beginning 20 November, the five-calendar-day advance-application date is 15 November; practical filing should allow more processing time.
Ten-step verification table
| Step | Verification | Evidence to retain |
|---|---|---|
| 1 | Determine whether the domestic casual-person definition fits. | State, fixed-place facts and supply activity. |
| 2 | Check the registration obligation and any notification exemption. | Threshold/exemption conclusion with source. |
| 3 | Schedule REG-01 early enough for processing and the five-day rule. | Event opening date and application acknowledgement. |
| 4 | Estimate output tax by supply and tax head. | Turnover forecast and verified rate working. |
| 5 | Verify due eligible and usable ITC. | Invoices, credit conditions and blocked-credit assessment. |
| 6 | Fund the net estimated deposit and track acknowledgement. | Temporary reference, challan and cash-ledger entry. |
| 7 | Confirm certificate issuance and its actual dates. | Registration certificate and invoicing control. |
| 8 | Monitor extensions before current expiry. | REG-11, additional estimate/deposit and extension approval. |
| 9 | Reconcile actual supply tax, ITC and extra funding. | Returns, ledger and head-office/event accounts. |
| 10 | Complete required returns and substantiate unused-advance refund. | Final return status, cash reconciliation and refund evidence. |
Sixteen practitioner FAQs
1. Is every visiting exhibitor automatically a casual taxable person?
No. Apply section 2(20) to the actual supply and fixed-place-of-business facts, then check applicable registration relief.
2. Can an existing GSTIN from another State simply be reused?
Do not assume so. Establish the registration and place-of-supply/establishment position for the exhibition State.
3. Does a domestic casual applicant use REG-09?
No. REG-09 is the non-resident taxable-person route; the domestic casual applicant uses REG-01.
4. How far before business must the application be made?
At least five days under section 25; allow additional processing time and verify certificate issuance.
5. Can taxable supplies begin while the certificate is pending?
Section 27 requires issuance of the certificate before those taxable supplies begin.
6. Is the advance always gross output tax?
No. Circular 71 clarifies deduction of due eligible ITC when calculating the estimated net tax deposit.
7. Can blocked or merely expected credit reduce funding?
Only due eligible credit that can lawfully be used should enter the estimate; substantiate eligibility and utilisation.
8. Does the deposit itself settle every eventual return liability?
No. Reconcile actual tax, credit and the cash-ledger discharge through the applicable returns.
9. Does every certificate remain valid for ninety days?
No. The requested period or ninety days from the effective date, whichever is earlier, governs.
10. Is extension automatic after REG-11 filing?
No. The statutory cause, application, deposit and proper-officer extension process must be satisfied.
11. When should REG-11 be submitted?
Rule 15 requires submission before the existing registration validity ends.
12. Does the extension need another tax estimate?
Yes. Section 27 requires an additional deposit for the estimated liability of the extension period.
13. Can exhibitions continue indefinitely on casual extensions?
No. Circular 71 addresses normal registration for exhibitions running beyond 180 days.
14. What if actual net liability exceeds the advance?
Provide additional funding and discharge the actual tax; the original estimate is not a ceiling.
15. Can the unused advance be refunded before all period returns are filed?
Section 54(13) blocks that advance refund until all required section 39 returns for the operative period are furnished.
16. Can a casual taxable person opt for composition?
The casual-person regime does not provide that option; check the section 10 restrictions rather than assuming small event turnover allows it.
Working-paper organisation
Keep the source documents, calculation and final conclusion together for the same entity and period. If using assureTax or other assureOffice tools, use only confirmed available functions and retain this evidence with the output.
Conclusion
Treat the exhibition as a bounded registration period with a documented net-tax funding plan. Verify certificate dates, fund extensions before expiry, and close the tax and return record before seeking the unused advance.