Based on CBIC Instructions - replaces earlier Instruction No. 03/2023-GST
Purpose of the Update
Applicants were facing delays and rejections due to unnecessary clarifications and demands for extra documents not listed in FORM GST REG-01.
Aim:
- Stop fraudulent registrations (created to pass fake ITC).
- Avoid harassment of genuine applicants.
This circular standardizes what documents officers can ask for and how applications must be processed.
Key Document Rules
1. Principal Place of Business (PPOB)
- Owned premises → Only one proof needed:Property tax receipt, municipal khata, electricity bill, or similar local law proof (e.g., water bill).➜ No physical originals or extra docs should be demanded.
- Rented premises →
- Rent/lease agreement + one ownership proof of landlord (as above).
- If registered agreement → No landlord ID needed.
- If unregistered → Landlord ID proof + ownership proof required.
- If utility bill is in applicant's name → Accept with rent agreement, no extra landlord docs.
- Premises owned by spouse/relative → Consent letter + owner's ID + one ownership proof.
- Shared premises → Same rules as rented premises; if no agreement, consent letter + owner's ID + one ownership proof.
- No agreement available → Affidavit on non-judicial stamp paper before Magistrate/Notary + proof of possession (e.g., electricity bill).
- Special Economic Zone (SEZ) → Upload Govt. SEZ certificate.
2. Constitution of Business
- Partnership → Only Partnership Deed needed. No MSME/Udhyam/shop licence etc.
- Society, Trust, Govt Dept, Club, Local Authority, etc. → Upload registration certificate/proof of constitution.
What Officers Cannot Ask
- No extra documents outside REG-01 list without higher officer's approval.
- No presumptive/unrelated queries (e.g., residential address mismatch, HSN ban in state, business activity "not possible" from location).
- No minor deficiency queries unrelated to proof of place/constitution.
Processing Rules & Timelines
- Officers must check documents for legibility, completeness, authenticity (can verify via public sources like electricity board, municipality).
- If not risky and complete → Approve within 7 working days.
- If risky / Aadhaar not done / physical verification needed → Complete within 30 days after site visit.
Physical Verification Rules
- Must be approved by Assistant Commissioner or above.
- Site verification report (FORM GST REG-30) with GPS-enabled photos must be uploaded at least 5 days before 30-day deadline.
- Report must confirm existence/non-existence of declared premises and record efforts made to locate it if absent.
Queries (FORM GST REG-03)
Only allowed for:
- Incomplete/illegible docs (ask for better copy).
- Address mismatch with proof.
- Incomplete address details.
- PAN-linked GSTIN cancelled/suspended (seek reason).
Timelines:
- Notice to applicant: within 7 working days (normal) or 30 days (risky cases).
- Applicant reply (FORM GST REG-04): within 7 working days.
- Officer decision: approve or reject within 7 working days of reply.
- No reply → Reject within 7 working days after deadline.
Accountability & Supervision
- Chief Commissioners to review applications, physical verification reports, and queries raised.
- Action against officers deviating from these rules.
- Adequate staff to be posted for timely application processing.
- Local trade notices to clarify acceptable proof in that area.
This 2025 instruction makes GST registration simpler, faster, and fairer for genuine applicants, while still keeping checks to prevent fake registrations. Only documents in the REG-01 list should be requested, and strict timelines are set for approvals and physical verifications.
The author is a founder of LegalDev.in who is Helping startups & small businesses with GST, ITR & legal compliance.
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