Goods and Services Tax (GST) and Corporate Tax Planning · Overview of Goods and Services Tax

GST Practitioners under Section 48 of the CGST Act

Updated 11 October 2026 · Fact-checked

A GST practitioner (GSTP) is a person approved under the CGST Rules who a registered person may authorise to furnish outward supply details and returns, and to perform other prescribed functions. Under section 48(3), the registered person stays responsible for the correctness of everything the practitioner files.

Understand Goods and Services Tax Practitioners

A registered person has many compliance tasks: uploading outward supplies, filing returns and more. Many businesses hand this work to a professional. Section 48 gives that arrangement a legal frame. It lets a registered person use an approved goods and services tax practitioner instead of doing the filing personally.

Section 48 has three parts. Sub-section (1) says the manner of approval, eligibility conditions, duties, obligations, manner of removal and other conditions of functioning are as prescribed, so the detail sits in the CGST Rules. Sub-section (2) says what a practitioner can be authorised to do. Sub-section (3) fixes responsibility.

Under sub-section (2), the registered person may authorise an approved practitioner to furnish the details of outward supplies under section 37, and the return under section 39 (regular return), section 44 (annual return) or section 45 (final return). The practitioner may also perform such other functions as are prescribed. The earlier reference to details of inward supplies under section 38 was omitted by Act 6 of 2022 from 1 October 2022.

The key point is sub-section (3). Even though the practitioner files, the responsibility for the correctness of the particulars in the return or other details continues to rest with the registered person. You cannot escape liability by saying the practitioner made the error. The registered person can seek recourse against the practitioner privately, but the department looks to the registered person.

In practice, the Rules lay down who can enrol. These include retired tax officers of a certain rank, persons with a specified degree, and those who have passed the final examination of ICAI, ICSI or ICMAI. A company secretary who has passed the final examination of ICSI therefore falls within the prescribed categories. Enrolment is done through the common portal, and the taxpayer authorises the practitioner on the portal for specific work.

Key rules to remember

Source of the rules: Section 48(1): approval, eligibility, duties, obligations and removal = as prescribed; The Act only creates the framework. The detail on eligibility and conduct is in the CGST Rules.
Authorised functions: Outward supplies (s.37) + returns (s.39, s.44, s.45) + other prescribed functions; Section 48(2). Inward supply details under section 38 were omitted from this sub-section from 1 October 2022.
Who authorises: Registered person authorises an approved GSTP; The practitioner acts only for persons who have authorised them. Without the authorisation, the practitioner cannot file for that taxpayer.
Responsibility rule: Responsibility for correctness = registered person, always; Section 48(3), notwithstanding sub-section (2). Filing by a GSTP does not shift liability.
Eligibility categories (in plain words): Indian citizen, sound mind, not insolvent, no serious conviction + one of the prescribed qualifications; Qualifications include retired tax officer, long-standing sales tax practitioner, prescribed degree, or final examination passed of ICAI, ICSI or ICMAI. Check the exact wording in the Rules before the exam.

How to solve Goods and Services Tax Practitioners questions

Most questions on this topic are short cases. They ask who can be a practitioner, what a practitioner may do, or who is liable for a wrong return. Use the same pattern each time.

1Identify the issue: eligibility or enrolment, scope of work, or liability.
2State the provision: section 48 for the framework and the prescribed rules for detail. Use words from the section, such as 'approved', 'authorise' and 'continue to rest'.
3List the facts that matter: the person's qualification, whether the registered person has authorised them, and what work was done.
4For eligibility, match the person to one prescribed category. Also check the general conditions such as citizenship, soundness of mind and no insolvency.
5For scope, check whether the task is outward supplies under section 37, a return under section 39, 44 or 45, or another prescribed function.
6For liability, apply section 48(3): the registered person remains responsible for the correctness of particulars.
7Conclude clearly in one line. Add a practical point, such as taking a written authorisation and reviewing the return before it is filed.

Quickest way: Three-question check

When to use it: Use this for a short-answer or case question when you have only a few minutes.

Is the person approved or enrolled as a GSTP? If not, they cannot act under section 48.
Has the registered person authorised them for this task? If not, they cannot file for that taxpayer.
Who bears responsibility for errors? Always the registered person under section 48(3). Then write the conclusion.

Common mistakes in Goods and Services Tax Practitioners

Writing that the practitioner alone is liable for errors in a return they filed.
Students think the person who files must be the person responsible.
Fix: Quote section 48(3): the responsibility for correctness continues to rest with the registered person. Any claim against the practitioner is a private matter.
Saying a GST practitioner can act for any taxpayer once enrolled.
Enrolment and authorisation get mixed up.
Fix: Enrolment makes a person an approved practitioner. Each registered person must still authorise them before they can act for that person.
Listing section 38 inward supply details as a function under section 48(2).
Older notes still carry the earlier wording.
Fix: The reference to section 38 was omitted by Act 6 of 2022 from 1 October 2022. Stick to section 37 and the returns under sections 39, 44 and 45, plus other prescribed functions.
Quoting rule numbers or details from memory and getting them wrong.
The eligibility conditions sit in the Rules, not in the Act.
Fix: Describe the conditions in plain words. Cite only section 48 unless you are certain of the rule number.
Saying section 48 itself lists the qualifications.
Students assume the section carries the detail.
Fix: Section 48(1) leaves approval, eligibility, duties and removal to be prescribed. Say that the Rules set them.

Worked examples

Example 1

Meera has passed the final examination of the Institute of Company Secretaries of India. She wants to work as a GST practitioner. Advise whether she can, and what she may do for a client, Sunrise Textiles Pvt Ltd, a registered person.

Show the solution

Issue: whether Meera can be an approved GST practitioner, and the scope of her work.
Provision: under section 48(1), approval and eligibility are as prescribed. The Rules include persons who have passed the final examination of ICSI among the eligible categories.
Application: Meera belongs to that category. She must also meet the general conditions, such as being an Indian citizen of sound mind, not insolvent and without a disqualifying conviction. She must enrol and be approved through the common portal.
Scope: once approved and authorised by Sunrise Textiles, she may furnish outward supply details under section 37 and the returns under section 39, 44 or 45. She may also do other prescribed functions.
Responsibility: under section 48(3), Sunrise Textiles remains responsible for the correctness of what she files.

Answer: Yes. Meera can become a GST practitioner if she meets the general conditions and is approved. Once Sunrise Textiles authorises her, she may file outward supply details and returns for it. The company remains responsible for their correctness.

Example 2

Kiran Traders authorised a GST practitioner to file its monthly return. The practitioner reported a lower value of outward supplies than Kiran Traders' invoices showed. Kiran Traders argues that the practitioner alone is liable. Examine.

Show the solution

Issue: who bears responsibility for the incorrect return.
Provision: section 48(2) allows a registered person to authorise an approved practitioner to furnish the return under section 39. Section 48(3) applies notwithstanding sub-section (2).
Rule: the responsibility for correctness of particulars in the return continues to rest with the registered person on whose behalf it is filed.
Application: the practitioner filed on behalf of Kiran Traders, so Kiran Traders is the registered person responsible. Authorisation did not transfer the responsibility.
Practical point: Kiran Traders may have a contractual remedy against the practitioner. The practitioner may also face action under the conduct conditions in the Rules. This does not remove Kiran Traders' liability to the department.

Answer: Kiran Traders' argument fails. Under section 48(3), it remains responsible for the correctness of the return. It should review returns before filing and keep its remedy against the practitioner separate.

Exam tips

Quote section 48(3) in any liability question. Examiners look for that sub-section.
Keep the Act and the Rules separate in your answer: section 48 gives the framework, and the Rules give eligibility and conduct detail.
Give a practical point at the end, such as obtaining written authorisation and checking returns before filing. Case answers earn marks for practical drafting.
Be able to list the functions in section 48(2) by section number: 37, 39, 44, 45, plus other prescribed functions.

Practice questions from Overview of Goods and Services Tax

Goods and Services Tax 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

Goods and Services Tax Practitioners: frequently asked questions

Can a company secretary be a GST practitioner?

Yes, if the person meets the prescribed conditions. The Rules list those who have passed the final examination of ICSI, ICAI or ICMAI among the eligible categories. The person must also meet the general conditions and be approved through the common portal.

What can a GST practitioner do under section 48?

When authorised by a registered person, a practitioner can furnish details of outward supplies under section 37 and file returns under sections 39, 44 and 45. The practitioner can also perform other functions that are prescribed.

Is the practitioner liable if the return is wrong?

Under section 48(3), responsibility for the correctness of the particulars stays with the registered person. The practitioner's own conduct can still be examined under the Rules, and the taxpayer may have a private remedy.

Where are the eligibility conditions for a GST practitioner found?

Section 48(1) says they are as prescribed, so they are in the CGST Rules. The section itself does not list qualifications, duties or the manner of removal.