Under the CGST Act, 2017, uploading a geo-tagged photograph of a director is not mandatory for declaring or amending an additional place of business. The Act itself does not prescribe any requirement for uploading photographs—geo-tagged or otherwise—of either the director or the premises at the time of registration amendment. The only statutory reference to photographs appears in Rule 25 of the CGST Rules, 2017, which applies solely when the proper officer orders physical verification of a place of business after registration. Even then, the rule requires photographs of the place of business, not of the director, and the obligation is officer-driven, not applicant-driven. Amendments to registration, including the addition of an additional place of business, are governed by Section 28 of the CGST Act read with Rule 19 of the CGST Rules, neither of which mandates uploading photographs. Any GST portal requirement for geo-tagged photos arises from administrative or system-based checks to curb fake registrations and lacks statutory backing.
1. Whether uploading of geo-tagged photograph with director for additional place of business under GST is mandatory?
No.
There is no provision in the CGST Act 2017 which mandates uploading of a geo-tagged photograph of the director for declaring or amending an additional place of business.
The GST Act itself does not prescribe any requirement relating to uploading photographs (geo-tagged or otherwise), either of the director or of the premises, at the time of addition of an additional place of business.
2. What does the law actually provide?
The statutory requirement flows only from the CGST Rules, and that too in the context of physical verification, not as a mandatory condition for amendment in all cases.
Relevant statutory provision:
Rule 25 of the CGST Rules, 2017 – Physical verification of place of business
“Where the proper officer is satisfied that the physical verification of the place of business of a person is required after grant of registration, he may get such verification done and the verification report along with other documents, including photographs, shall be uploaded in FORM GST REG-30 on the common portal within fifteen working days following the date of such verification.”
Key points from Rule 25:
- Photographs are required only when physical verification is conducted by the department.
- The rule refers to photographs of the place of business, not of the director.
- There is no distinction made between principal place and additional place of business for this purpose.
- This is not an applicant-driven mandatory upload, but an officer-driven compliance during verification.
3. Amendment for additional place of business
Amendment of registration (including addition of an additional place of business) is governed by Section 28 of the CGST Act, 2017 read with Rule 19 of the CGST Rules, 2017.
Neither Section 28 nor Rule 19 mandates uploading:
- geo-tagged photographs, or
- photographs of the director.
4. Practical aspect (portal requirement)
If the GST portal, in certain cases, asks for geo-tagged photographs of premises, such requirement arises from administrative instructions / system-based checks to curb fake registrations.
However, this requirement does not have backing in the CGST Act and cannot be treated as a statutory mandate under the Act.
Conclusion
- Uploading geo-tagged photo of the director is NOT mandatory for addition of an additional place of business under the CGST Act.
- The CGST Act contains no such requirement.
- Photographs (including of premises) are contemplated only under Rule 25, and that too when physical verification is ordered by the proper officer.
- Any insistence beyond this is procedural/portal-driven, not statutory.
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