Summary: The CBIC issued Instruction No. 03/2025-GST on April 17, 2025, to address delays and inconsistent practices in processing GST registration applications. This replaces the earlier 2023 guideline and aims to streamline procedures while minimizing fraudulent registrations. The instruction outlines acceptable documentation for the principal place of business. Owned premises require any one ownership document like a utility bill, while rented premises need a lease agreement and the lessor’s proof of ownership or ID. Consent letters with ID and ownership proof are valid when premises belong to relatives. SEZ applicants must submit SEZ-related government documents. For business constitution, only relevant legal documents like partnership deeds or registration certificates are required. Officers are instructed not to demand MSME certificates, trade licenses, or raise presumptive queries like questioning residential address location or business feasibility from a given location. The processing timeline remains seven working days for standard applications and 30 days for high-risk or non-Aadhaar-authenticated applications. Physical verifications must be completed five days before the 30-day limit and documented with GPS-tagged photos. Clarifications (via GST REG-03) should only be sought for valid reasons, and additional document requests need prior approval. Forms involved include GST REG-01 (application), REG-03 (clarification), REG-04 (reply), REG-05 (rejection), and REG-30 (verification report). Senior officers are held accountable for timely processing, staffing, and adherence to protocol, with disciplinary measures for non-compliance. For implementation issues, departments may contact gst-cbec@gov.in. This directive emphasizes balancing fraud prevention with minimizing unnecessary obstacles for genuine applicants.
Why This Instruction Was Needed
- Applicants are facing problems because officers often ask for documents not listed in the application (GST REG-01).
- There’s also concern about fake registrations used to pass ITC fraudulently.
- This circular tries to strike a balance—prevent fraud, but don’t harass genuine applicants.
Documents – What Officers Should (and Shouldn’t) Ask For
Principal Place of Business (PPOB)
- If the place is owned, any one document like electricity bill, property tax receipt, or water bill is enough. No need for original copies.
- If the place is rented:
- A valid rent/lease agreement plus one ownership proof of the lessor is enough.
- If the agreement is unregistered, then also submit lessor’s ID proof.
- If the agreement is registered, no ID proof of the lessor is needed.
- If the utility bill is in the applicant’s name, that + rent agreement is enough.
- If the place is owned by a relative/spouse, then a consent letter + ID proof of consenter + one ownership document is sufficient.
- If there’s no rent agreement, then an affidavit on stamp paper with any proof like an electricity bill in the applicant’s name is valid.
- SEZ applicants must submit documents issued by the Government for SEZ status.
Constitution of Business
- For partnerships, just the Partnership Deed is required.
- For societies, trusts, government bodies, etc., upload registration proof.
- Officers should not ask for MSME certificate, trade license, shop act license, etc.
Presumptive Queries to Avoid
Officers should not ask questions like:
- Why the residential address is in a different state,
- Why a certain HSN code is used,
- Whether business can be conducted from a specific location.
Only ask for clarifications relevant to documents actually submitted.
Processing Timelines
| Type of Application | Time to Process | Notes |
|---|---|---|
| Normal (non-risky) | 7 working days | If complete, approve without delay |
| Risky or Aadhaar not authenticated | 30 days | Physical verification required |
- Physical verification (if needed) must be completed and uploaded 5 days before the 30-day deadline.
- Reports should include GPS-tagged photos and verification details.
Forms Used in the Process
- GST REG-01: Application form
- GST REG-03: Officer’s notice for clarification
- GST REG-04: Applicant’s reply
- GST REG-05: Rejection order
- GST REG-30: Physical verification report
Important: REG-03 notices should only be sent for justified reasons. Officers must take prior approval to ask for anything beyond the listed documents.
Responsibility of Senior Officers
- Supervising registration timelines and field activity.
- Ensuring sufficient staff are available to handle applications.
- Issuing local notices for area-specific documentary needs.
- Taking strict action against officers who don’t follow instructions.
For Any Issues
Departments facing issues in implementation can write to gst-cbec@gov.in.
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