Chapter XII - Assessment
Section 63
Section 63: Assessment of unregistered persons
Section 63 permits best-judgment assessment of a taxable person who failed to register despite liability or whose registration was cancelled while tax was still due.
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Need advice on Section 63?
This article is for general information. Refer to the Central Goods and Services Tax Act, 2017 official text for the official provisions. If you need professional advice for your situation, contact Bizeneed.
Statutory text
Bare law
Notwithstanding anything to the contrary contained in section 73 or section 74 or section 74A, where a taxable person fails to obtain registration even though liable to do so or whose registration has been cancelled under sub-section (2) of section 29 but who was liable to pay tax, the proper officer may proceed to assess the tax liability of such taxable person to the best of his judgment for the relevant tax periods and issue an assessment order within a period of five years from the date specified under section 44 for furnishing of the annual return for the financial year to which the tax not paid relates: Provided that no such assessment order shall be passed without giving the person an opportunity of being heard.
Introduction
Failure to hold an active GST registration does not prevent assessment for periods in which a person was liable to tax.
Key takeaways
Who is covered
The section concerns a person who should have registered but did not, or whose registration was cancelled under section 29(2) while tax remained due.
Best judgment
The officer may assess relevant periods using available material and issue the order within the Act’s five-year framework tied to section 44.
Hearing right
No assessment order may be passed under this section without giving the person an opportunity of being heard.
Who is covered
The section concerns a person who should have registered but did not, or whose registration was cancelled under section 29(2) while tax remained due.
Best judgment
The officer may assess relevant periods using available material and issue the order within the Act’s five-year framework tied to section 44.
Hearing right
No assessment order may be passed under this section without giving the person an opportunity of being heard.
Practical checklist
Do
- Test registration liability for each period.
- Reconstruct taxable supplies and payments from records.
- Respond to the hearing notice with supporting evidence.
Avoid
- Assume a prescribed or notified detail without checking the applicable current instrument.
Frequently asked questions
Can an unregistered person be assessed without a hearing?
No. Section 63 expressly requires an opportunity of being heard before the order.
Need help applying this provision to your situation?
Contact BizeneedLast updated 10 October 2026