CBIC Issued Instructions for Processing of GST Registration Application

In the last few months, to prevent fake firms from obtaining GST registrations, the process of granting GST registration has become far more complicated and time-consuming for genuine taxpayers as well. The CBIC has received complaints that GST officers are asking for additional documents that are not prescribed in the List of Documents appended to FORM GST REG-01. Officers are following varied practices for the verification of documents. However, certain avoidable clarification is also sought by the officers.

Therefore, there is a need to prevent registration of fraudulent firms, making sure that genuine applicants are not unduly harassed.

Guidelines for processing of application for GST registration were earlier issued vide instruction No. 03/2023-GST dated 14th June, 2023. However, post-increasing complaints, the CBIC issued comprehensive instructions vide Instruction No. 03/2025-GST dated 17th April, 2025, to take care of the latest developments and to provide clarity to the officers for processing of registration application.

CBIC has specified that an indicative list of documents has been prescribed in FORM GST REG-01. The officers should strictly refer to the prescribed list of documents and adhere to the following instructions in respect of the processing of registration application:

1. Documents to be sought from the Applicant while processing the Application:

1.1 Documents for Proof of Principal Place of Business (PPOB)

1. Owned premises: The Applicant should submit any one of the following documents:
   • Latest property tax receipt.
   • Municipal khata copy;
   • The latest electricity bill is in the name of the owner.
   • water bill;
   • any other document prescribed under the State or local laws that establishes the ownership of the premises. 

Any one of these documents will be sufficient, and no additional document should be requested from the applicant for proof of ownership. Further, while processing the application, the query should not be raised by the officer seeking the original physical copy of these documents.

Read Also: GST Registration Can’t Be Rejected to the Applicant from Other State

2. Rented premises: In case of rented premises, the applicant is required to upload the following documents:

Registered Rent Agreement:

• Valid Rent/Lease Agreement;
• Any one of the above-mentioned documents to establish the ownership of the landlord.

Unregistered Rent Agreement:

• Valid Rent/Lease Agreement;
• Any one of the above-mentioned documents to establish the ownership of the landlord.
• a copy of the identity proof of the lessor

If no rent agreement is available

• An affidavit executed on non-judicial stamp paper of minimum value in the presence of a First-Class Judicial Magistrate or Executive Magistrate or a Notary PublicValid Rent/Lease Agreement;
• Any one of the above-mentioned documents to establish the ownership of the landlord.

In some cases, the officer asks for certain additional documents of the lessor, such as PAN card, Aadhar Card, photograph of the lessor in front of/or inside the property, etc. CBIC has clarified that any one of the documents establishing the ownership of the premises by the lessor should be sufficient proof of the principal place of business.

If the electricity or water bill is in the name of the tenant, then such a document, along with the rent agreement, is sufficient.

3. Premises owned by the Relative: Where the property is named after the  spouse, father, etc. following documents are required:
   • a consent letter on plain paper by the concerned owner;
   • copy of the identity proof of the person granting consent;
   • Any one of the above-mentioned documents is required to establish the ownership of the landlord

4. Shared Premises: In case of shared premises, the following documents are required:
   • If the rent agreement is available:
     1. Rent Agreement, 
     2. Any document to establish the ownership of the landlord
     3. a copy of the identity proof of the lessor, if the rent agreement is unregistered.

• If no rent agreement is available:
  1. a consent letter on plain paper by the concerned owner;
  2. copy of the identity proof of the person granting consent;
  3. Any one of the above-mentioned documents is required to establish the ownership of the landlord

5. Unit located in Special Economic Zone (SEZ): Submit certificates issued by the Government of India.

1.2  Documents for the Constitution of Business

• Partnership Firm: Partnership Deed only. No other certificates like MSME, Udyam Registration, Shops & Establishment, trade licence, etc., are required.
• Societies, trusts, clubs, Government Department, AOP/ BOI, etc: Registration certificate or proof of constitution.

2. Officers can’t ask for presumptive Queries or documents:

CBIC has mentioned that while processing registration applications, Officers should not ask unrelated or “presumptive” questions, like:

1. Residential address of the Partner, Managing Director, Authorised Signatory, etc., is not in the same state where GST registration is required;
2. HSN Codes are about banned or prohibited items.
3. Activities for which GST registration is required can’t be carried out from the particular premises, etc.

CBIC has clarified that Officers should not ask any presumptive queries which is not related to the documents or information submitted by the applicant.

3. Processing of GST registration application

3.1 Check Authenticity and Genuineness of the Documents:

The GST officer shall:

1. Carefully scrutinize the documents to ensure that they documents are legible, complete, and relevant.
2. The address of PPOB and APOB and the corresponding documents may be closely scrutinised to verify the completeness and correctness of the address.
3. The authenticity of the documents may be cross-verified from the publicly available sources, such as websites of the concerned authorities, such as land registry, electricity distribution companies, municipalities, and local bodies etc. 

3.2 Timeline for Approval

1. Standard applications: Where an application is not flagged risky by the Common portal, then such an application should be approved within 7 working days.

2. Specified Applications: In the following cases, the GST registration shall be granted within 30 days of submission of the application after physical verification of the place of business:
   1. Post Aadhaar Authentication, the application is flagged as risky on the common portal based on the data analysis and risk parameters, or
   2. The applicant fails to undergo authentication of the Aadhar number, or does not opt for Aadhar authentication, or
   3. The officer deems fit to carry out physical verification of the place of business, with the approval of the officer not below the rank of Assistant Commissioner.

3. Physical Verification: In cases where physical verification is required, the proper officer shall immediately initiate the process for physical verification. The officer must ensure that the physical verification report, along with photographs, is uploaded on the system at least 05 days before the expiry of the period 30 days from the date of submission of the application. 

The officer carrying out physical verification shall ensure the following:

1. Give a specific report regarding the existence/non-existence of PPOB.
2. In case of a non-existent firm, efforts made in respect of locating the said premises need to be recorded in the physical verification report.
3. Upload GPS GPS-enabled site photograph and other documents
4. If the ARN assigned for physical verification belongs to a different jurisdiction, the same should be immediately reassigned to the correct jurisdiction.

3.3 Cases where the officer can ask for additional documents or information:

The officer can ask for additional documents or information in the following cases:

• Where any document is incomplete or not legible;
• Where the address of the place of business does not match the document uploaded;
• The uploaded document does not appear to be a valid proof.
• The address of the place of business is incomplete or vague.
• Where any GSTIN linked to the PAN of the applicant is found cancelled or suspended

3.4 Manner of processing of application:

• The officer shall issue the notice asking for additional documents or information in Form GST REG-03 within 7 working days from the date of submission of the application. (30 days for applications flagged as risky);
• Any documents apart from the listed documents can be sought only after the approval of the concerned Deputy/Assistant Commissioner.
• The officer must ensure that no application for a grant is approved on a deemed basis.
• No documents or information, or clarification shall be sought on presumptive grounds;
• Queries are not raised for minor deficiencies that are not relevant for establishing PPOB or the Constitution of Business, etc.

3.5 Time limit for processing of application

• The applicant must furnish a response within 7 working days (in Form GST REG-04) from the date of receipt of notice (Form GST REG-03);
• The officer shall carefully examine the response furnished.
• If the officer is satisfied with the response, then the application shall be approved within 7 working days from the date of receipt of the reply. 
• However, if the proper officer is not satisfied with the response, then he shall reject the application for reasons to be recorded in writing within 7 working days (in FORM GST REG-05).
• Where no reply is furnished, the application shall be rejected after recording the reasons for the same in writing within 7 working days from the date of expiry of the time limit for filing a reply.

4. Supervisions:

Principal Chief Commissioners/ Chief Commissioners are advised to:

• Closely supervise the status of processing of the GST registration application.
• Strict action may be taken against the officer who deviates from these instructions.
• Post sufficient staff to ensure the timely disposal of registration applications;
• Issue trade notices to provide for acceptable documentary evidence to be submitted with the application.

5. Conclusion

These guidelines were most awaited, considering the hardship faced by the genuine taxpayers in obtaining GST registration. By limiting document requirements, reducing unnecessary queries, and setting clear timelines, the government ensures that genuine businesses can start operations without hassle. At the same time, measures like physical verification and risk checks help prevent fraud. If you’re planning to register for GST, make sure to submit the listed documents clearly and respond to any clarifications on time to get your registration approved quickly. 
In case of any problem, the issue may be reported to CBIC by writing an email to [email protected].