Directives on GST registration/ SOPs based on GST instructions 03/2025-GST dated 17.04.2025.

The Much Awaited GST Registration SOP instructions issued by CBIC-Instruction 03/2025 dated 17.04.2025

Key points-

1. Only documents listed in FORM GST REG-01 to be accepted.

2. No extra or presumptive queries by officers.

3. Clear timelines for approvals & verifications.

4. Focus on curbing fraudulent ITC claims.

5. No more asking of extra documents for rented premises.

6. No more clarificatory documents for spouses/relatives granting business space.

7. No more rejections for lack of rent agreements (affidavit allowed).

8. Officers can’t reject on assumptions or unsupported reasons.

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Instructions for processing of applications for GST registration.
 

This instruction enforces a uniform, legally sound, and applicant-friendly process for GST registration, minimizing discretion and maximizing procedural integrity. It ensures the proper facilitation of genuine taxpayers while maintaining vigilance against fraudulent registrations.

This instruction aims to streamline the GST registration process, prevent officer discretion abuse, and ensure timely and fair registration of genuine applicants.

It has been divided into Nine Directives below for easy understanding :
 

Key Directives

1. Standardisation of Documentation Requirements:

• Officers must strictly adhere to the indicative list of documents appended to FORM GST REG-01.

• No additional or unwarranted documents should be demanded unless explicitly authorised.

2. Principal Place of Business (PPOB)

• Owned Premises: Any one valid proof (e.g., property tax receipt, electricity/ water bill).

• Rented Premises:Upload Rent/Lease Agreement + any one ownership document of the lessor.

• For unregistered agreements: Add identity proof of the lessor.

• If utility bills are in the applicant’s name, these suffice without further proof.

• Other Situations (shared premises, relative’s property):Consent letter + identity proof + ownership proof of the consenter suffices.

• Premises by consent (e.g., relative/spouse): Consent letter, ID proof, and ownership document of the consenter.

• Shared Premises: Similar documentary norms apply.

• No Rent Agreement: Affidavit + possession proof acceptable (notarized or before magistrate).

• SEZ Premises: Upload GOI-issued SEZ approval documents.

3. Constitution of Business

Partnerships: Only the Partnership Deed is required.

Societies, Trusts, etc.: Certificate/Proof of Constitution only.

No requirement for trade license, MSME certificate, Udyam, etc.

 

4. Prohibition of Presumptive Queries:

Officers must not raise objections based on:

• Geographic mismatch of addresses.

• Nature of goods/services (e.g., banned items).

• Object based on prohibited goods or assumptions about business activities.

• Presumed unsuitability of premises for business activity.

• Question location mismatch of applicant’s personal and business address.

• Ask for clarifications beyond what's relevant or listed.

5. Application Processing Protocol:

Approval Timelines

•• Non-risky applications with complete documentation: Approve within 7 working days.

•• Risky applications (e.g., failed Aadhaar authentication): Approve within 30 days, subject to physical verification.

 

6. Physical Verification Guidelines

• Carried out per Rule 9 read with Rule 25 of CGST Rules.

• Upload GPS-enabled photographs and verification report in FORM GST REG-30 at least 5 days before the 30-day limit.

7. Seeking Clarification (FORM GST REG-03)

Permitted only when:

• Documents are incomplete/illegible.

• Address mismatch or lacks clarity.

• PAN linked to cancelled GSTIN.

• Any additional document not listed must be approved by a Deputy/ Assistant Commissioner

•• Clarifications not covered in prescribed grounds require prior approval from Deputy/Assistant Commissioner.

8. Disposition of Application Post Clarification:

• Satisfactory Reply (FORM GST REG-04): Approve within 7 working days.

• Unsatisfactory or No Reply: Reject via FORM GST REG-05, with written justification.

9. Administrative Measures for Enforcement-

Principal Chief Commissioners/Chief Commissioners are directed to:

• Monitor registration processing and physical verifications.

• Prevent deemed approvals caused by officer inaction.

• Ensure adequate manpower.

• Issue localized trade notices for acceptable documentation.

CA Jatin Minocha

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