Standardized Guidelines for Processing of GST Registration Applications

🔰 Summary of CBIC Instruction No. 03/2025-GST dated 17th April 2025

Purpose of the Instruction:

To standardize procedures and eliminate arbitrary practices in GST registration under FORM GST REG-01, ensuring that:

• Genuine applicants are not harassed, and
• Fraudulent registrations for wrongful ITC claims are curtailed.
• This instruction supersedes Instruction No. 03/2023-GST dated 14th June 2023

Document Requirements for GST Registration:

A. Principal Place of Business (PPOB)

1. Owned Premises:
   • Submit any one of the following (or similar document as per State/local law):
     • Latest Property Tax Receipt / Municipal Khata / Electricity Bill
     • Water Bill or similar document showing ownership
   • No original document or additional proof to be demanded.
2. Rented/Leased Premises:
   • Unregistered Rent Agreement:
     • Rent Agreement + ownership proof of lessor (as above) + ID proof of lessor
   • Registered Rent Agreement:
     • Rent Agreement + ownership proof of lessor (no ID proof needed)
   • Electricity/Water Bill in tenant’s name: Acceptable with rent agreement
   • No PAN/Aadhaar/photo of lessor to be asked
3. Premises with Relatives/Spouse:
   • Consent Letter + ID proof of consenter + ownership document as above
4. Shared Premises:
   • Same treatment as rented premises based on registration status of agreement
   • In absence of Rent Agreement, use Consent Letter + ID proof + ownership proof
5. No Rent Agreement Available:
   • Affidavit (on non-judicial stamp paper before Magistrate/Notary) + ownership document (e.g., electricity bill in applicant’s name)
6. SEZ Premises:
   • Submit SEZ allocation documents/certificates issued by Govt. of India

B. Constitution of Business

1. Partnership Firm:
   • Upload Partnership Deed only.
   • Do not ask for Udyam/MSME/Trade License/Shop Act Certificate.
2. Society, Trust, Club, Govt. Entity, etc.:
   • Submit only the Registration Certificate or valid proof of constitution.

Prohibited Practices

• Do not raise presumptive queries, such as:
  • Why residential address differs from business location
  • HSN code mentioned is banned in the state
  • Activity not suitable for stated premises
• Do not demand additional or irrelevant documents, even if suspected.

Processing of GST Registration Application

1. Initial Scrutiny:
   • Documents must be legible, complete, and relevant.
   • Scrutinize address and match with supporting documents.
   • Cross-verify address through public portals (land records, electricity, etc.)
2. Timelines:
   • If not risky, registration must be granted within 7 working days.
   • If flagged risky / Aadhaar not verified / officer deems verification needed, grant within 30 days after physical verification.
3. Physical Verification (if required):
   • Conducted as per Rule 25.
   • Must upload GPS-enabled photos, site report (in REG-30), and documents at least 5 days before 30-day deadline.
   • Include:
     • Status of existence
     • Details of effort made if entity not found
     • Transfer to correct jurisdiction if misassigned

Seeking Clarification (REG-03)

Permitted only for:

• Illegible/incomplete documents
• Mismatch of address and documents
• Incomplete/vague addresses
• PAN-linked GSTINs suspended/cancelled — only if relevant

❗ Any extra documents beyond those listed can only be sought with prior approval of Deputy/Assistant Commissioner.

Reply and Action Timelines

• Applicant’s reply (REG-04): Within 7 working days
• Officer’s Action:
  • If satisfied – approve within 7 days from the date of submission of application in case where the application has not been flagged as risky
  • Where application has been flagged as risky or Aadhar not verified or officer consider that verification is needed, within 30 days from the date of submission of the application
  • If unsatisfied – reject with reasons in REG-05 within 7 days or 30 days (in case application flagged as risky)
• If no reply of query by the applicant – rejection of application via REG-05 within 7 days of reply deadline

Supervisory Responsibilities

Principal Chief Commissioners / Chief Commissioners must:

• Monitor registration processing and physical verifications
• Review nature of queries and curb deemed approvals
• Ensure adequate staff deployment
• Issue local Trade Notices for documentation norms
• Take action against non-compliance with these instructions

Limitation: The purpose of this article is for knowledge sharing purpose. Views expressed in this note are personal views of the author. The same should not be construed as professional advise.