What are the GST liabilities of a dealer selling numismatic items at a physical exhibition — including the temporary registration requirement?

Who is a Casual Taxable Person — the critical definition

CGST Act Section 2(20) defines a 'Casual Taxable Person' (CTP) as a person who occasionally undertakes transactions involving supply of goods or services in a State or Union Territory where they have no fixed place of business. A numismatic dealer based in Mumbai who attends a numismatic exhibition in Delhi has no fixed place of business in Delhi — they are a Casual Taxable Person for that Delhi exhibition.

The consequence of being a CTP: Section 24(ii) of the CGST Act mandates that a Casual Taxable Person making taxable supplies must register for GST — compulsorily, with no turnover threshold. A Mumbai dealer whose annual numismatic turnover is ₹8 lakh (below the ₹20 lakh regular registration threshold) who sells at a Delhi exhibition must still register as a CTP. The ₹20 lakh turnover exemption does not apply to CTPs.

The CTP registration process — the 'temporary GST number'

The CTP registration is what collectors and dealers commonly call a 'temporary GST number.' It is a proper GST registration, but with a defined validity period. Under CGST Act Section 27(1), the CTP registration is valid for the period specified in the application or 90 days from the effective date — whichever is earlier. The proper officer may extend this by a further 90 days on sufficient cause. For a numismatic exhibition lasting 3 days, the CTP registration would be applied for covering those 3 days.

Application timing: the application must be filed at least 5 days before the commencement of business (i.e., before the exhibition starts). It is filed on the GST portal (gst.gov.in) as a CTP application. The exhibition allotment letter — the document confirming the dealer's stall allocation — serves as proof of Place of Business for CTP registration purposes.

Advance tax deposit — the mandatory prepayment

Section 27(2) of the CGST Act imposes a unique requirement on CTPs: an advance deposit of estimated tax liability for the entire registration period must be paid at the time of applying for registration. The registration is not granted until this advance deposit is made. The deposit is calculated on the estimated net tax liability (after eligible input tax credit) for the sales expected during the exhibition.

Example calculation: a dealer expects to sell ₹2 lakh worth of numismatic notes (HSN 4907, 12% GST) and ₹50,000 worth of coins (HSN 9705, 5% GST) at the exhibition. Estimated GST = ₹24,000 on notes + ₹2,500 on coins = ₹26,500. This ₹26,500 must be deposited in advance before registration is granted. If actual sales are lower, the excess advance deposit is refundable after filing the CTP return.

Which scenario applies — same state vs different state

Scenario 1 — Dealer is already registered in the state where the exhibition is held: No CTP registration needed. The dealer uses their existing GSTIN. They charge CGST + SGST on intra-state sales (buyer from same state) or IGST on inter-state sales (buyer from different state). They file their normal GST returns including the exhibition sales.

Scenario 2 — Dealer is registered in a different state from the exhibition: CTP registration mandatory in the exhibition state. All sales at the exhibition attract CGST + SGST of the exhibition state (being intra-state supplies from the CTP's temporary exhibition location). IGST applies if the buyer is from yet another state.

Scenario 3 — Dealer is not registered for GST at all (below ₹20 lakh threshold) and sells only in their home state: If the exhibition is also in their home state — no CTP registration; their normal non-registration exemption applies (below threshold). If the exhibition is in a different state — CTP registration is mandatory regardless of turnover, because any supply in a state where they have no fixed place of business triggers the CTP obligation.

What the CTP must do during and after the exhibition

During the exhibition: issue a proper tax invoice for every supply (Section 31 CGST Act read with Rule 46). The invoice must show: the dealer's CTP GSTIN; description of goods (note denomination, series — enough to identify the HSN); HSN code (9705 for coins, 4907 for notes); quantity; taxable value; and GST amount broken up into CGST + SGST or IGST as applicable. A handwritten note on letterhead is not sufficient — the GST invoice must contain all prescribed particulars.

After the exhibition: file a GST return in Form GSTR-1 (outward supplies) within 7 days of the last day of validity of the CTP registration or within 7 days of the end of the exhibition, whichever is earlier. If the advance deposit exceeded actual tax liability, file for refund in Form GST RFD-01.

The exhibition organiser's GST obligation

The organiser charges dealers for stall space — this is a supply of services. GST at 18% (general services rate) applies on the stall rental fee. The organiser charges CGST + SGST if the exhibition is in the organiser's home state, or IGST if the organiser is from a different state. The organiser's GST on stall fees is separate from the dealer's GST on their own numismatic sales.

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CTP registration is mandatory — no turnover threshold — if you are selling numismatic items at an exhibition in a state where you have no fixed place of business. This applies even if your annual turnover is ₹5 lakh. Apply at least 5 days before the exhibition. Make the advance tax deposit at the time of application. Issue GST invoices for every sale at the exhibition. Missing CTP registration when required: interest + penalty under CGST Act.

Scenario	GST obligation	Risk if ignored
Registered dealer, selling in home state	Use existing GSTIN. CGST + SGST on intra-state. Normal return filing.	None if compliant
Registered dealer, exhibition in another state	CTP registration in exhibition state mandatory. CGST + SGST of exhibition state applies.	Penalty for unregistered supply + interest on tax due
Unregistered dealer (below ₹20L), home state exhibition	No CTP needed if exhibition in own state. Normal exemption applies.	None
Unregistered dealer (below ₹20L), different state exhibition	CTP registration MANDATORY — no turnover threshold for CTPs. Advance deposit required.	Penalty for unregistered supply even if turnover is low
Long exhibition (more than 180 days)	Normal GST registration required — not CTP. Surrender after exhibition ends.	CTP registration invalid beyond 180 days

CTP registration — step by step for exhibition dealers Step 1: Determine if you are already registered in the exhibition state → if yes, use existing GSTIN, skip CTP Step 2: If not registered in exhibition state → apply for CTP registration on gst.gov.in at least 5 days before the exhibition Step 3: Attach exhibition allotment letter as proof of Place of Business Step 4: Estimate total GST liability for the exhibition period → pay advance deposit at time of application Step 5: Receive CTP GSTIN valid for exhibition duration (up to 90 days) Step 6: Issue proper GST tax invoices for EVERY sale at the exhibition (HSN 9705 / 5% for coins; HSN 4907 / 12% for notes) Step 7: File GST return within 7 days of exhibition end or registration expiry Step 8: Apply for refund of excess advance deposit if actual sales were lower than estimated

Laws & authorities referenced in this chapter

CGST Act 2017 — §2(20) (Casual Taxable Person definition)

CGST Act 2017 — §24(ii) (CTP must register compulsorily; no turnover threshold)

CGST Act 2017 — §27(1) (CTP registration: valid for period applied or 90 days; extendable by 90 more days)

CGST Act 2017 — §27(2) (advance deposit of estimated tax liability mandatory at time of CTP registration)

CGST Act 2017 — §31 read with Rule 46 (tax invoice required for every supply)

GST Council — HSN 9705 (numismatic coins: 5%), HSN 4907 (numismatic banknotes: 12%)

Ministry of Finance Circular — exhibition allotment letter accepted as proof of Place of Business for CTP

CGST Rules 2017 — Rule 15 (extension of CTP registration); Form GST REG-11 (extension application)