Revised Guidelines for Processing of GST Registration Applications-CBIC Instruction No. 03/2025-GST

Introduction

The Central Board of Indirect Taxes and Customs (CBIC) issued a comprehensive update on the GST registration process via Instruction No. 03/2025-GST dated 17th April 2025. This instruction supersedes the earlier guidelines (Instruction No. 03/2023-GST) and seeks to harmonize and simplify the procedures followed by tax officers across the country when processing new GST registration applications.

The revised framework emphasizes a balance between curbing fraudulent registrations and easing the burden on genuine applicants. Let us understand the key takeaways, procedural improvements, and compliance implications for taxpayers and professionals.

Background and Need for Revised Instructions

Despite earlier instructions, the CBIC received numerous complaints regarding delays and unjustified rejections in GST registration. Officers were found to be raising excessive and often presumptive queries. There were inconsistencies in the documents sought, many of which were outside the prescribed list under FORM GST REG-01.

To eliminate such discrepancies and ensure a uniform approach nationwide, the new guidelines under Instruction No. 03/2025-GST aim to bring clarity and reduce arbitrariness in the GST registration process.

Key Objectives of Instruction No. 03/2025-GST

• Prevent harassment of genuine taxpayers seeking registration.

• Eliminate inconsistent practices followed by field officers.

• Reduce time delays in granting GST registration.

• Ensure only legally prescribed documents are requested.

• Curb fraudulent GST registrations aimed at passing on fake input tax credits.

Documents for Principal Place of Business (PPOB)

Owned Premises

For owned properties, any one of the following is sufficient proof of ownership:

• Latest Property Tax Receipt

• Municipal Khata Copy

• Electricity Bill

• Water Bill or any equivalent document recognized by local laws

Only one valid proof is required. Tax officers are instructed not to demand physical copies or multiple proofs if one acceptable document is uploaded.

Rented Premises

If the business is operated from a rented location:

• A valid Rent or Lease Agreement must be uploaded.

• One proof of ownership from the landlord (as above) is required.

Tax officers must refrain from requesting unnecessary documents like the landlord’s Aadhaar, PAN, or photographs, unless specifically justified.

If the Rent Agreement is not registered:

• A copy of the agreement

• One proof of ownership from the landlord

• Landlord’s ID proof is required.

If the agreement is registered:

• Only the agreement and one ownership proof suffice. ID proof of the landlord is not required.

Where utility bills (electricity or water) are in the tenant’s name, the officer must accept this with the agreement and not request additional documents.

Shared or Relatives’ Premises

If using a property owned by a spouse or relative:

• A plain paper consent letter

• One valid ownership proof (as listed)

• ID proof of the consenter is sufficient.

For shared premises without an agreement:

• Consent letter

• ID proof of the consenter

• One document proving ownership by the consenter

No additional documentation should be sought.

No Agreement Available

Where no rent agreement exists:

• An affidavit (executed before a magistrate or notary on non-judicial stamp paper)

• Any utility bill or document in the name of the applicant as per GST REG-01

This affidavit route provides relief to small businesses or informal arrangements.

Special Economic Zone (SEZ)

Applicants located in SEZs must upload government-issued SEZ approval certificates.

Documents for Constitution of Business

Partnership Firms

• Upload the Partnership Deed only.

• Officers must not seek additional certificates like MSME registration, trade licenses, etc.

Other Entities

Societies, Trusts, Clubs, Government Departments, AOPs, Local Authorities, and Statutory Bodies must upload their Certificate of Registration or equivalent proof of constitution.

Restrictions on Presumptive and Irrelevant Queries

CBIC strictly prohibits officers from raising speculative or unrelated queries, such as:

• Asking why the residential address is outside the place of business.

• Questioning the type of goods sold based on local restrictions.

• Suggesting that the business cannot be conducted from the declared premises.

Only relevant and document-based queries are allowed, as per FORM GST REG-03.

Processing Timeline and Scrutiny Protocol

Standard Timeline

Where the application is complete and not flagged as risky:

• GST registration must be granted within 7 working days of submission.

Cases Requiring Physical Verification (30-Day Timeline)

Registration must be completed within 30 days if:

• Aadhaar authentication is not completed or the applicant opts out.

• Application is flagged as risky based on analytics.

• Officer finds reasons to conduct physical verification.

Such verification must comply with Rule 25 and be conducted promptly, with:

• Site photographs (GPS enabled)

• Detailed verification report

• Upload of findings in FORM GST REG-30

If the jurisdiction is mismatched, the application should be reassigned appropriately.

Clarifications via FORM GST REG-03

Clarifications can only be sought if:

• Uploaded documents are incomplete or illegible.

• The address does not match the supporting document.

• The address is vague or incomplete.

• Existing GSTINs under the PAN have been cancelled or suspended.

Requests for documents beyond those prescribed require approval from the Deputy or Assistant Commissioner.

Reply by Applicant – FORM GST REG-04

The applicant must respond to queries via FORM GST REG-04 within 7 working days. The officer must review the response and either:

• Approve the application within 7 working days, or

• Reject it (via FORM GST REG-05), recording valid reasons.

If no reply is received, the officer may reject the application after 7 working days from the expiry of the reply period.

Administrative Oversight and Compliance Measures

Principal Chief Commissioners and Chief Commissioners must:

• Monitor registrations, physical verifications, and nature of queries.

• Prevent deemed approvals due to officer inaction.

• Take disciplinary action against officers violating these instructions.

• Allocate adequate staff for registration processes.

• Issue local trade notices if local documentation customs need clarification.

Implications for Taxpayers and Professionals

The instruction brings much-needed consistency and clarity to GST registration. Professionals assisting clients with GST registration must ensure:

• Only the required documents are submitted.

• Responses to notices are timely and comprehensive.

• Applicants are aware of their rights if officers overreach.

This instruction also serves as a regulatory shield, allowing genuine businesses to challenge unjustified delays or demands.

Conclusion

CBIC Instruction No. 03/2025-GST is a crucial development aimed at ensuring a transparent, consistent, and efficient GST registration process. By focusing on core documentary compliance and preventing presumptive scrutiny, the new instructions streamline registration for legitimate applicants while safeguarding against fraudulent practices.

All GST practitioners, chartered accountants, and tax professionals must familiarize themselves with the revised requirements and help clients navigate the process confidently.