Question

Can we register two separate firms under the GST, operating from the same premises and having the same address?

Answer

Facts of the case: A separate GST registration is needed to for 2 separate firms operating from the same premises having same address.

Law Applicable:
(i) As per sec 22(1) of CGST;
"Every supplier shall be liable to be registered under this Act in the State or Union territory, other than special category States, from where he makes a taxable supply of goods or services or both, if his aggregate turnover in a financial year exceeds twenty lakh rupees"

(ii) Sub Section 6 of section 2 CGST defines Aggregate Turnover as;
"aggregate value of all taxable supplies (excluding the value of inward supplies on which tax is payable by a person on reverse charge basis), exempt supplies, exports of goods or services or both and inter-State supplies of persons having the same Permanent Account Number, to be computed on all India basis but excludes central tax, State tax, Union territory tax, integrated tax and cess"

Interpretation:
Registration limit is governed by Aggregate Turnover which is computed PAN wise. Since you have 2 different firms having 2 different PAN therefore mandatory separate registration is required if limit is exceeded.
Two firms can have the same address and therefore the registration can be availed over a same address for 2 firms.

Conclusion: You can get different registration under the same address but you are advised to differentiate the details of address floor wise or room wise. For example Firm 1 address can be"Room 1 Building 35 Street 23 Delhi" and address of Firm 2 can be "Room 2 Building 35 Street 23 Delhi"
You are also advised to keep books of accounts separately and stock of the 2 firms separately. There should clear demarcation of the stock between two firms so that no audit objection is raised. (Reply dt.01/05/2019)