Do you need GST registration to sell currency notes?

The Simple Truth

GST registration is mandatory only when your aggregate annual turnover from taxable supplies — total sales value, not profit — exceeds ₹20 lakh in a financial year (₹10 lakh for Special Category States). Occasional collectors selling a few notes a year will almost never cross this threshold. Active dealers who cross it are legally required to register, collect GST from buyers, and remit it to the government. Registration below the threshold is voluntary and may be advantageous for dealers who make large purchases from registered suppliers and want to claim Input Tax Credit.

The ₹20 lakh threshold — what counts toward it

The ₹20 lakh threshold is calculated on aggregate annual turnover — the total value of all taxable supplies in a financial year, measured from 1 April to 31 March. Every rupee of sales value counts toward this threshold, not just profit. A dealer who sells 100 notes at an average of ₹3,000 each has ₹3 lakh of turnover — well below threshold. A dealer who sells 20 notes at ₹1,20,000 each has ₹24 lakh of turnover — above threshold, registration mandatory.

For a collector who sells only occasionally — a few notes per year, total sales well below ₹20 lakh — GST registration is not required. The legal obligation simply does not arise. For an active dealer who crosses the threshold, registration is mandatory from the date on which the threshold is exceeded.

What GST registration requires you to do

A GST-registered dealer must: collect GST on each sale at the applicable rate (5% for numismatic coins under HSN 9705; 12% for numismatic notes under HSN 4907); issue a tax invoice complying with GST Rules 2017 for each sale; maintain transaction records; file GST returns (typically monthly or quarterly depending on turnover); and remit collected GST to the government. Non-compliance after registration is more serious than non-registration below the threshold — it can result in penalties, interest, and prosecution.

The 5% vs 12% distinction — critical for mixed inventory

The GST rate for numismatic items is not uniform. Numismatic coins — those classified under HSN 9705 as collector pieces of numismatic interest — attract 5% GST following the GST Council's June 2017 rate reduction. Numismatic banknotes and historical paper currency — classified under HSN 4907 (banknotes, postage stamps, first-day covers) or Chapter 49 — attract 12% GST as historical paper items.

ItemGST RateHSN/SACBasis
Numismatic coins5%HSN 9705GST Council reduced rate, June 2017
Numismatic banknotes / historical paper currency12%HSN 4907 / Chapter 49Standard rate for historical paper items
Gold/Silver bullion3%HSN 7108Precious metal rate
Framing/mounting services18%SAC 999Standard service rate
Birthday frame (composite supply)12%Principal supply = notesComposite supply rate follows principal supply

A dealer selling both coins and notes must apply different GST rates to different items on the same invoice. Applying 5% to banknote sales — because coins attract 5% — is a GST compliance error. A conservative dealer handling significant banknote turnover should seek an Advance Ruling from the GST Authority for Advance Ruling in their state, since the classification of collectible banknotes under HSN 4907 versus other chapters can be debated.

The Section 269ST cash transaction limit

Separate from GST, Section 269ST of the Income Tax Act prohibits any person from receiving ₹2 lakh or more in cash from a single person in a single day, in respect of a single transaction or relating to one event or occasion. The penalty is equal to the full amount of the prohibited cash receipt. A dealer who accepts ₹3 lakh in cash for a single note is in violation regardless of whether the transaction is genuine.

Judicial Authority RBANMS Educational Institution v. B. Gunashekar · Supreme Court of India · 16 April 2025

Courts and sub-registrar offices must report cash transactions of ₹2 lakh or more to jurisdictional Income Tax officers. This Supreme Court direction significantly increases enforcement of §269ST — the era of this provision being routinely ignored at numismatic fairs is over. Use UPI or bank transfer for any transaction above ₹2 lakh.

Laws & authorities referenced in this chapter

CGST Act 2017 — §22 (registration threshold — ₹20 lakh aggregate annual turnover)

CGST Act 2017 — §8 (composite supply — rate follows principal supply)

GST Council decision, June 2017 — numismatic coins reduced to 5% under HSN 9705

HSN 4907 — numismatic banknotes and historical paper currency at 12%

Income Tax Act 1961 — §269ST (cash transaction limit — ₹2 lakh; penalty = full amount)

RBANMS Educational Institution v. B. Gunashekar — Supreme Court, 16 April 2025 — courts must report §269ST violations to IT officers

Key Takeaway

GST registration mandatory when annual turnover exceeds ₹20 lakh. Below threshold: no obligation. Rates: coins 5% (HSN 9705); notes 12% (HSN 4907); services 18%. Mixed inventory: separate rates per item — applying coin rate to notes is a compliance error. Section 269ST: no cash receipts above ₹2 lakh — RBANMS Supreme Court (2025) made this provision court-enforced. Use UPI/bank transfer for high-value transactions.

This is educational content, not legal advice. For a specific situation, please consult a qualified legal professional. Excerpted from Currency, Coins & The Law by Mayank Agarwal, Part 6: The Invisible Obligation.

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