Guidelines for Processing GST Registration Applications – Key Instructions and Procedures

Streamlining GST Registrations: CBIC’s New Guidelines to Reduce Harassment & Delays.

In a welcome move to strike a balance between curbing tax evasion and facilitating ease of doing business, the Central Board of Indirect Taxes and Customs (CBIC) has issued fresh, comprehensive instructions for processing GST registration applications. These guidelines supersede the earlier Instruction No. 03/2023-GST dated 14th June 2023 and aim to address practical issues faced by genuine taxpayers.

The Background

References received by the Board highlighted the growing concerns of applicants regarding:

• Inconsistent practices adopted by officers across jurisdictions.
• Excessive and irrelevant queries raised during verification.
• Unjustified demand for documents beyond the prescribed list in FORM GST REG-01.

While preventing fake firms from claiming fraudulent input tax credit (ITC) is crucial, the process must not harass genuine applicants.

📋 Key Takeaways from the New Instructions

1. Principal Place of Business (PPOB):

• Owned Premises: Any one document such as property tax receipt, electricity/water bill, or municipal khata copy is sufficient.
• Rented Premises:
  • Valid Rent/Lease Agreement + one ownership document of the lessor suffices.
  • Additional documents like PAN, Aadhaar, or photographs of the lessor should not be demanded.
  • Unregistered Agreement: Requires the agreement + ownership proof + lessor’s ID.
  • Registered Agreement: Lessor’s ID is not required.
  • Utility bills in tenant’s name are also acceptable with agreement.
• Shared Premises or Consent Arrangements: Consent letter + consenter’s ID + one ownership document.
• No Rent Agreement? Affidavit + proof like electricity bill in applicant’s name is acceptable. The affidavit must be notarized or attested by a magistrate.
• SEZ Units: Relevant SEZ approval documents are mandatory.

2. Constitution of Business:

• Partnership Firms: Only the Partnership Deed is needed.
• Societies, Trusts, AOPs: Their Registration Certificates are required.
• No MSME, Udyam, Trade License, or similar documents should be demanded unnecessarily.

3. Unwarranted Queries to Be Avoided
   1. CBIC has observed queries based on presumptions such as:

• Residential address not matching business location.
• Business activity cannot be conducted from a specific address.
• Use of HSN codes for restricted goods.

  2. Officers are now instructed NOT to raise queries unrelated to the submitted documents.

4. Processing Timeline & Verification

• Applications Not Flagged as Risky:
  • Must be processed within 7 working days if complete.
• Flagged Applications or Aadhaar Not Authenticated:
  • Must be processed within 30 days, with mandatory physical verification.
  • Physical verification reports (FORM GST REG-30) must be uploaded at least 5 days before expiry of the 30-day period.

5. Clarifications, Rejections & Timelines

• Notice in FORM GST REG-03 can be issued only if:
  • Documents are incomplete or illegible.
  • Address mismatches.
  • Prior GSTIN is cancelled/suspended.
• Reply to notice must be furnished in FORM GST REG-04 within 7 working days.
• Officer Response:
  • If satisfied → Approve registration within 7 working days.
  • If not satisfied → Reject using FORM GST REG-05 (reasons must be recorded).
• No Reply? Application may be rejected post the expiry of reply timeline.

6. Administrative Oversight & Compliance
   Principal Chief Commissioners are advised to:

• Regularly monitor application status, physical verifications, and officer compliance.
• Take strict action against officers deviating from instructions.
• Ensure adequate staffing for registration processing.
• Issue local trade notices for region-specific document clarifications.

✅ The Takeaway

These revised instructions promise a more transparent and uniform approach to GST registrations. By limiting discretion and standardizing acceptable documents, CBIC seeks to:

• Ease the burden on genuine businesses.
• Curb malpractices effectively.
• Promote accountability among tax officers.

Taxpayers are encouraged to ensure that applications are complete and that documents are legible and as per the prescribed list in FORM GST REG-01.

 Notification Reference: GST
Instruction No. 03/2025-GST
 17/04/2025