Goods and Services Tax (GST) and Corporate Tax Planning · Compliance Rating, Anti-Profiteering, GST Practitioners and Authorised Representative

GST Practitioners under Section 48 of the CGST Act

Updated 11 October 2026 · Fact-checked

A GST practitioner is a person approved under Section 48 of the CGST Act to act for a registered person on the GST portal, such as furnishing outward supply details and returns. Eligibility, approval, duties and removal are set by the rules. The registered person stays responsible for correctness of what is filed.

Understand GST Practitioners

Many taxpayers cannot file GST statements and returns themselves. Section 48 lets them hire an approved GST practitioner to do it. The Act gives only the frame. The manner of approval, eligibility conditions, duties and obligations, manner of removal and other conditions of functioning are all left to be prescribed in the rules.

The Act says what a practitioner may do. A registered person may authorise an approved practitioner to furnish details of outward supplies under section 37, and the return under section 39 (regular returns), section 44 (annual return) or section 45 (final return). The practitioner may also perform such other functions as may be prescribed. The reference to inward supplies under section 38 has been omitted from the Act with effect from 1 October 2022, so do not list it as a function.

The key protection for the Government is section 48(3). Even when a practitioner files, the responsibility for correctness of particulars in the return or other details continues to rest with the registered person. Authorising a practitioner does not shift liability. You can see this as agency: the practitioner acts, the principal answers.

There is also a link to section 116. A person authorised to act as a GST practitioner on behalf of the concerned registered person is one of the persons who can appear as an authorised representative before an officer, the Appellate Authority or the Appellate Tribunal. So a practitioner's role can extend from filing to appearing, when the registered person has authorised it.

For your exam, remember the split. The Act (section 48) gives the power and the liability rule. Details such as qualifications, the enrolment process, any examination, specific duties and the grounds for removal come from the rules. State rule-based details in general terms unless you are sure of the exact rule text.

Key rules to remember

Rule-making power: Section 48(1): approval manner, eligibility, duties, obligations, removal and other conditions = as prescribed; The Act delegates these details to the rules. Say so before describing them.
Authorised functions: Section 48(2): outward supplies under section 37; return under section 39, 44 or 45; other prescribed functions; Authority must come from the registered person and the practitioner must be approved.
Responsibility rule: Section 48(3): correctness of particulars = registered person's responsibility; Applies notwithstanding sub-section (2). The practitioner's filing does not remove the taxpayer's liability.
Inward supplies: Section 38 reference omitted w.e.f. 1-10-2022; Do not state that a practitioner furnishes inward supply details under section 38 as an Act function.
Appearance link: Section 116(2)(e): authorised GST practitioner of the registered person is an authorised representative; Appearance is on behalf of the concerned registered person, who must authorise it.

How to solve GST Practitioners questions

Use this method for any question on GST practitioners, whether it is theory or a short case.

1Identify what is asked: eligibility, functions, duties, liability, removal, or appearance.
2Quote the frame from section 48: details of approval, eligibility, duties and removal are prescribed by rules.
3If functions are asked, list outward supplies under section 37, returns under sections 39, 44 and 45, and other prescribed functions.
4Check the facts: is the person approved, and has the registered person authorised the practitioner?
5Apply section 48(3): decide who is responsible for errors in the filed return.
6If appearance before authorities is involved, link to section 116(2)(e) and the need for authorisation.
7Conclude clearly in one or two lines and add a practical point, such as keeping a written authorisation and reviewing returns before filing.

Quickest way: Three-line answer: Approve, Authorise, Answer

When to use it: Use when time is short and the question asks who is liable or what a practitioner can do.

Approve: only an approved practitioner, under the prescribed manner and conditions, can act.
Authorise: the registered person must authorise the practitioner for the specified functions.
Answer: the registered person remains responsible for correctness under section 48(3).

Common mistakes in GST Practitioners

Saying the practitioner alone is liable for errors in the return.
Students think the person who files bears the blame.
Fix: Quote section 48(3): responsibility for correctness continues to rest with the registered person.
Listing inward supplies under section 38 as a practitioner function.
Older notes carry the earlier wording of section 48(2).
Fix: The reference was omitted w.e.f. 1 October 2022. Mention only section 37 outward supplies and returns under sections 39, 44 and 45.
Stating detailed eligibility and removal conditions as if they are in the Act.
Students mix the Act with the rules.
Fix: Say that section 48(1) leaves these to be prescribed, and describe them as rule-based.
Assuming any person can file returns for a taxpayer.
Confusing a practitioner with an employee or agent.
Fix: Section 48(2) refers to an approved practitioner authorised by the registered person.
Forgetting that a practitioner can appear as authorised representative.
Section 48 and section 116 are studied separately.
Fix: Link section 116(2)(e): a person authorised to act as GST practitioner for the concerned registered person qualifies as an authorised representative.

Worked examples

Example 1

Sharma Traders Pvt. Ltd. authorised an approved GST practitioner to file its monthly return under section 39. The practitioner reported a wrong figure of outward supplies and tax was short paid. The company says the practitioner alone is liable. Advise.

Show the solution

Provision: section 48(2) allows a registered person to authorise an approved practitioner to furnish outward supply details under section 37 and the return under section 39.
Analysis: the practitioner acted within the authorised function, so the filing is valid in form.
Section 48(3) says that, notwithstanding sub-section (2), responsibility for correctness of particulars in the return continues to rest with the registered person.
Here the company is the registered person, so the responsibility for the incorrect figure rests with it.
Conclusion: the company's contention fails. Practically, it should review returns before filing and may seek recourse against the practitioner under their engagement terms.

Answer: The company remains responsible for the correctness of the return under section 48(3). Authorising the practitioner does not transfer that responsibility.

Example 2

Mehta Industries Ltd. has authorised its GST practitioner to file returns. A notice is issued and the company wants the same practitioner to appear before the Appellate Authority. Can the practitioner appear?

Show the solution

Provision: section 116(1) allows a person entitled to appear before an officer, the Appellate Authority or the Appellate Tribunal to appear by an authorised representative, except where personal appearance for examination on oath or affirmation is required.
Section 116(2)(e) includes within authorised representative any person authorised to act as a GST practitioner on behalf of the concerned registered person.
Analysis: the practitioner is authorised by the company for the concerned registered person, so the clause applies.
Check disqualifications under section 116(3), such as dismissal from Government service or being adjudged an insolvent; none is stated in the facts.
Conclusion: the practitioner can appear, unless personal appearance on oath or affirmation is required.

Answer: Yes. Under section 116(2)(e) the practitioner is an authorised representative and can appear before the Appellate Authority for the company, subject to section 116(3) and the exception for personal examination on oath.

Exam tips

Begin with section 48(1) and say that details are prescribed. This shows you know what comes from the Act and what from the rules.
In case questions on errors in returns, always conclude with section 48(3).
Write the functions list precisely: section 37 outward supplies and returns under sections 39, 44 and 45.
For a company secretary question, link to section 116(2)(c): a company secretary holding a certificate of practice and not debarred can be an authorised representative.
Add one drafting or compliance point, such as a written authorisation letter.

Practice questions from Compliance Rating, Anti-Profiteering, GST Practitioners and Authorised Representative

GST Practitioners in other exams

The same ground in other exams, if you are preparing for more than one or want another angle on it.

CS ExecutiveGST Practitioners

GST Practitioners: frequently asked questions

What does section 48 of the CGST Act deal with?

It deals with approved GST practitioners. It leaves approval, eligibility, duties and removal to the rules, lists functions a registered person may authorise, and says the registered person stays responsible for correctness of filed particulars.

What can a GST practitioner file?

An approved practitioner, if authorised, can furnish outward supply details under section 37 and the return under section 39, 44 or 45. They can also perform other prescribed functions.

Who is responsible if a GST practitioner makes an error?

The registered person. Section 48(3) says responsibility for correctness continues to rest with the registered person on whose behalf the return or details are filed.

Can a company secretary act as a GST practitioner?

The eligibility conditions are prescribed in the rules, so check the current rules for the exact list. Separately, section 116(2)(c) lets a company secretary holding a certificate of practice and not debarred appear as an authorised representative.