Date: 17th April 2025
Issued by: GST Policy Wing, Central Board of Indirect Taxes and Customs (CBIC)
The Ministry of Finance has issued comprehensive new guidelines to streamline the Goods and Services Tax (GST) registration process, ensuring a balance between curbing fraudulent registrations and avoiding unnecessary difficulties for genuine businesses.
Background
Frequent complaints regarding inconsistent practices among officers, delays, and unwarranted document demands prompted the CBIC to issue Instruction No. 03/2025-GST. These instructions aim to bring uniformity, reduce processing time, and improve the experience for legitimate applicants.
Key Highlights of the Instructions
1. Simplification of Document Requirements
The guidelines stress adherence to the indicative list of documents already outlined in FORM GST REG-01. Officers are instructed not to demand any additional documents beyond what’s specified.
For Principal Place of Business (PPOB):
- Owned premises: Any one document like property tax receipt, electricity bill, water bill, or municipal record is sufficient.
- Rented premises: A valid rent/lease agreement plus any one ownership document of the lessor is enough. No PAN, Aadhaar, or photographs of the lessor should be asked.
- Consent-based use: A plain-paper consent letter from the owner, their ID proof, and one ownership document is sufficient.
- Special Economic Zone (SEZ): Relevant government-issued documents are mandatory.
In Absence of a Rent Agreement:
An affidavit and an electricity bill in the name of the applicant can be submitted, with the affidavit to be notarized or attested by a magistrate.
2. Clarifications on Business Constitution
- Partnership firms: Only the partnership deed is required.
- Other entities (Trusts, Societies, AOPs): Their respective registration certificates are enough.
- No need to submit additional documents like Udyam/MSME/Trade licenses unless specified.
3. Avoiding Presumptive and Irrelevant Queries
Officers are advised not to raise irrelevant concerns, such as:
- Applicant’s residential address being in a different city/state,
- Nature of goods/services being unsuitable for location,
- Suspicion without factual basis.
4. Application Processing Timelines
| Type of Application | Timeline | Condition |
|---|---|---|
| Non-risky, complete application | Within 7 working days | No Aadhaar flag and all documents in order |
| Risky application or Aadhaar not authenticated | Within 30 days | Physical verification mandatory |
5. Physical Verification Protocol
If required, officers must:
- Upload verification report and photos in FORM GST REG-30 at least 5 days before the 30-day deadline.
- Clearly mention whether the business exists.
- Provide GPS-enabled photographs.
- Reassign applications to correct jurisdictions if needed.
6. Seeking Clarifications (FORM GST REG-03)
Clarifications can only be sought for:
- Illegible or incomplete documents,
- Mismatch in address documents,
- Vague address details,
- Suspicious PAN-linked GSTIN history.
All requests for unlisted documents must be approved by a Deputy/Assistant Commissioner.
7. Decision After Clarification
- If satisfied with applicant’s reply (FORM GST REG-04), approve within 7 days.
- If not satisfied, reject within 7 days via FORM GST REG-05.
- If no reply is received in time, reject based on written reasoning.
Administrative Measures for Implementation
Principal Chief Commissioners and Chief Commissioners have been instructed to:
- Monitor registration processing closely,
- Take disciplinary action for deviations,
- Ensure sufficient staffing,
- Issue local trade notices where needed.
✅ Summary of Key GST Registration Guidelines (Instruction No. 03/2025-GST)
📋 Document Categories & Clarifications
| S. No. | Subject | What You Need to Know (Instructions) | Standards / Clarifications |
|---|---|---|---|
| 1 | General Objective | Officers must follow uniform guidelines; no extra documents unless justified. | |
| 2 | Proof of PPOB (Principal Place of Business) | Documents must be from FORM GST REG-01 list only. Physical documents not needed if digitally uploaded. | PAN, Aadhaar, other photos not required unless specified. |
| 3 | Owned Premises | Any 1 of the following is sufficient: Property tax receipt / Water bill / Electricity bill / Municipal record. | One document is enough. |
| 4 | Rented Premises | If registered agreement is there, ownership proof not needed. If unregistered: affidavit + utility bill in applicant’s name. | PAN of owner not required. |
| 5 | Consent Letter Cases (Relatives/Spouse) | Consent letter + ID of owner + ownership proof. | Utility bill or tax receipt is enough. |
| 6 | Shared Premises | Treated like rented premises. | Rent agreement + utility bill + Aadhaar of applicant is sufficient. |
| 7 | No Agreement (Relatives/Spouse) | Submit affidavit on ₹10 paper + utility bill in applicant’s name. | If no rent agreement: utility bill + affidavit. |
| 8 | SEZ Location | Must upload SEZ approval certificate. | SEZ authority-issued document required. |
| 9 | Constitution of Business | Only primary documents like Partnership Deed or Trust Certificate needed. | No Udyam/MSME registration or Trade License needed unless specified. |
| 10 | Prohibited Queries | Officers must avoid irrelevant queries like location mismatch, goods suitability, etc. | Unwarranted assumptions are to be avoided. |
🛠️ Application Processing & Timelines
| Section | Details |
|---|---|
| Application Processing | Officer must verify uploaded documents only. |
| Timelines – Non-Risky | Approve within 7 working days if Aadhaar verified. |
| Timelines – Risky | Approve within 30 days after physical verification. |
| Clarifications (REG-03) | Officers can only raise issues for: illegible documents, vague addresses, mismatches, or risk history. |
| Timelines for Queries & Decisions | – REG-04 (clarification reply) must be reviewed within 7 working days. – REG-05 (rejection) to be issued if not satisfied. |
| Responsibility of Senior Officers | JC/ADC to approve exceptional requests; Zonal officers to ensure discipline; Trade notices to be issued. |
🔑 Key Takeaways for Taxpayers
- 📌 Stick to documents listed in FORM REG-01.
- ❌ Officers cannot ask for additional documents unless justified.
- 🧾 For rented/shared premises: ownership proof of lessor is sufficient.
- ✅ PAN/Aadhaar/Photos of owner are not mandatory.
- 📤 Upload only clear, complete, and relevant documents.
- ⏳ Timely replies to REG-03 will prevent rejections.
- 🏷️ Local GST zones may issue Trade Notices for accepted formats.
These updated SOPs mark a significant step toward improving the GST registration experience by emphasizing clarity, reducing bureaucratic delays, and curbing misuse of the system. The circular aims to build a fair and efficient registration framework that supports genuine business growth while safeguarding revenue.
Visit www.cagurujiclasses.com for practical courses
