On April 17, 2025, the Central Board of Indirect Taxes and Customs (CBIC) issued Instruction No. 03/2025-GST, offering a comprehensive set of guidelines aimed at resolving common hurdles faced during GST registration. The instruction comes as a much-needed reform to standardize the verification process and eliminate unnecessary documentation demands that often delay or derail genuine registrations.

Why Was This Instruction Issued and Key Highlights of the Instruction

Why Was This Instruction Issued?

Officers were often found seeking unprescribed documents and clarifications not mentioned in the GST registration form (FORM GST REG-01). While ensuring that fraudulent entities don’t misuse GST registration, the CBIC emphasizes that legitimate applicants should not be subjected to unwarranted scrutiny.

Key Highlights of the Instruction

1. Standardization of Documents for Proof of Business Premises

Applicants need only one valid document to establish ownership or tenancy of their business premises. This could include:

·         Property tax receipt

·         Municipal Khata copy

·         Electricity or water bill

·         Registered lease or rent agreement

Unnecessary demands like the lessor’s PAN, Aadhaar, or personal photographs are now explicitly discouraged.

Special Situations:

·         Shared premises or rented property without a formal agreement can be supported by a simple affidavit.

·         Spouse/relative-owned premises require a consent letter and proof of ownership from the consenter.

·         SEZ applicants must upload relevant government-issued certificates.

2. Documents for Constitution of Business

For different types of business structures:

·         Partnership firms need only their partnership deed.

·         Trusts, Societies, Clubs, AOPs, and Government entities must submit their registration certificates.

·         No additional documents like Udyam Registration or trade licenses are to be requested unless explicitly required.

Key Highlights of the Instruction

3. Discouragement of Presumptive Queries

CBIC has strictly instructed officers to avoid queries based on assumptions—like questioning why a director resides in a different state or challenging the business activity based on location. Officers must base their clarifications strictly on documents submitted.

4. Timeline for Application Processing

a. Normal Applications (Not Flagged as Risky):

·         Must be approved within 7 working days if all documents are in order.

b. Risk-Flagged Applications or Aadhaar Not Authenticated:

·         Require physical verification and must be processed within 30 days.

In such cases, the officer must upload a detailed physical verification report—including GPS-enabled photos and findings—at least 5 days before the 30-day deadline.

5. Raising Queries and Rejecting Applications

If clarifications are needed, they must be sought via FORM GST REG-03 and replied to within 7 working days using FORM GST REG-04. Applications can be approved or rejected (using FORM GST REG-05) based on the adequacy of the response.

The officer must document reasons for rejections and cannot delay action, ensuring no application is deemed approved due to inaction.

6. Responsibility of Senior Officers

Senior GST officials are required to:

·         Supervise application processing timelines and accuracy

·         Prevent deviations from prescribed procedures

·         Ensure sufficient staffing for registration processing

·         Issue local trade notices clarifying accepted local documents

Conclusion

The updated CBIC instruction is a welcome move for entrepreneurs and businesses navigating the GST registration maze. By curbing officer discretion and enforcing document standardization, it strengthens both compliance and transparency.

If you're applying for a new GST registration, ensure that your documents align with these guidelines. This will help avoid delays and speed up the approval process.