Notice in Form GST REG-03 for seeking clarification relating to GST Registration

In case you have applied for GST registration, you may receive notice in form REG-03 seeking additional information / clarification / documents relating to application for GST registration. As per provision of GST law, GST officer examines the GST registration application filed by you in Form GST REG-01. While examining, if the officer requires an additional information/ document/ clarification, then the notice in Form GST REG-03 will be served. List of additional documents which can be asked by GST department is not prescribed under law; hence GST officer based on certain risk parameters can ask you various documents. In the absence of standard list of additional Information required by department, the same varies for different taxpayers, Centre/State GST authority, States, Tax Officers etc. Few of such documents are mentioned as under-

1. Geo Tagged photographs of the business premises

2. Photographs of the Inventory

Notice in Form GST REG-03 for seeking clarification relating to GST Registration

3. Income Tax Returns of Proprietor / Firm / Company

4. No Objection Certificate (NOC) from competent authority regarding carrying commercial activity (Principal place of business as residence cum office) in residential area.

5. Copy of aadhar card of Proprietor/Partners.

6. Copy of PAN card of Proprietor/Partners.

7. Valid proof of blood relation in case of consent letter is attached as supporting document for business premises. For example, grandmother is giving her own premises to granddaughter for carrying business activity, without any rent i.e. on consent letter basis, taxpayer is being asked to submit document to establish the relation between grandmother & granddaughter.

8. Site Plan of Business Premises with surrounding locations

9. Bank statement of company/proprietor

10. Details for type of business activity carried in the Place of business

11. Copy of Aadhar card of Landlord of rented premises

12. Get copy of Rent Deed or Partnership deed duly notarized by Notary Public (If earlier you have uploaded documents without notary attested)

13. Specific product or service details relating to HSN/SAC code mentioned in registration application.

Important to Note

a) In case certain information is not applicable in your specific case, e.g. in case of newly commenced business for applying GST registration on voluntarily basis, you might not have following documents:-

1. Photograph of inventory due to non purchase of stock items

2. Bank account statement due to non opening of account

3. Income Tax Return with Business Income, as earlier you might be salaried employee or carrying on different activity/small scale business

You can simply mention the fact that these documents are not applicable as you not started the business operations yet.

b) After COVID-19 pandemic, many small business owners have started operating remotely on work from home (WFH) basis, without physical interaction. However for such residential office, usually as such there is no requirement of additional permission from land authorities i.e. Municipal Corporation, Improvement Trust, Urban Development Authority, Housing Board, Co-operative Housing Society.

Author’s concluding remarks

For ease of doing business, Government should implement certain specific checklist of document/information, which can be additionally asked by Tax Officer, otherwise it leads to unnecessary burden on taxpayers to arrange all the documents in time bound manner. Non submission of any such information might lead to rejection of GST registration application.

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Author can be reached at [email protected] for any queries, issues & recommendations relating to article. Any feedback for improvement would be really appreciated.

Disclaimer: The contents of this article are for information purposes only and does not constitute an advice or a legal opinion and are personal views of the author. It is based upon relevant law and/or facts available at that point of time and prepared with due accuracy & reliability. Readers are requested to check and refer relevant provisions of statute, latest judicial pronouncements, circulars, clarifications etc before acting on the basis of the above write up.  The possibility of other views on the subject matter cannot be ruled out. By the use of the said information, you agree that Author / TaxGuru is not responsible or liable in any manner for the authenticity, accuracy, completeness, errors or any kind of omissions in this piece of information for any action taken thereof. This is not any kind of advertisement or solicitation of work by a professional.

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