Table of Contents
Introduction
In response to the rising volume of complaints regarding unjustified rejections and delays in GST registration, the Central Board of Indirect Taxes and Customs (CBIC) issued Instruction No. 03/2025-GST, dated 17th April 2025. This advisory revamps the registration verification process under FORM GST REG-01, ensuring uniformity, transparency, and protection for genuine applicants, while strengthening the guardrails against fraudulent ITC claims.
The instruction supersedes the earlier Instruction No. 03/2023-GST dated 14th June 2023 and comes amid increasing scrutiny of GST back-office practices.
Let’s break down this important advisory point-by-point, keeping in line with legal provisions, rules, clauses, and statutory interpretation wherever necessary.
Why Was This Advisory Issued?
The Board received frequent representations highlighting inconsistencies and unjust practices in the verification of GST registration applications, such as:
- Non-uniform practices by officers in different jurisdictions.
- Unwarranted demands for documents not listed in FORM GST REG-01.
- Delays in registration due to avoidable clarifications and unnecessary rejections.
- Harassment of genuine applicants, causing business disruptions.
The advisory seeks to strike a balance between preventing fake entities (used for ITC fraud) and ensuring ease of doing business for legitimate taxpayers.
Core Legal Framework Involved
- Section 25 of the CGST Act, 2017 – Deals with registration procedure.
- Rule 8 and Rule 9 of the CGST Rules, 2017 – Outline application processing and verification timelines.
- FORM GST REG-01 – Standard application form for registration.
- FORM GST REG-03 – Used to issue notices seeking clarification from applicants.
Document Verification: New Guidelines for GST Officers
CBIC clarified that the officers must strictly adhere to the document list mentioned in FORM GST REG-01. The focus is on ensuring no extra documents are sought that are not mandated by law.
A. Principal Place of Business (PPOB)
- Only one document among the following is required:
- Latest Property Tax Receipt
- Municipal Khata Copy
- Electricity Bill
- Water Bill or any other similar document as per State/local laws
- No physical/original copies to be requested.
- No additional verification documents to be demanded.
- Mandatory: Valid Rent/Lease Agreement
- Plus, any one document proving lessor’s ownership (from the REG-01 list).
- Additional documents like PAN, Aadhaar, photo of lessor, etc., should not be sought.
- If Rent Agreement is registered, identity proof of lessor need not be provided.
- Require:
- Consent Letter on plain paper from the consenter
- Consenter’s identity proof
- Any one ownership proof document (e.g., electricity bill or tax receipt)
- Acceptable if:
- Applicant submits affidavit (on stamp paper) before a Notary/Executive Magistrate
- Document showing possession, e.g., electricity bill in applicant’s name
- Required to upload specific SEZ documents issued by competent Government authority.
B. Constitution of Business
- Only Partnership Deed is mandatory.
- No requirement for:
- Udyam Certificate
- MSME Certificate
- Shop Act License
- Trade License
- Clarified that only constitution-related document, such as:
- Trust Deed / Registration Certificate
- Memorandum and Rules
- Government Notification for Govt. departments
- No extra licenses, permits, or certificates to be asked.
C. Authorized Signatory & Ownership Verification
- Officers must not raise queries regarding identity or ownership proof if the documents uploaded match the official list.
- Verification under Rule 9 must be objective, not discretionary.
Instructions to Field Officers and GSTN Back Office
- GST officers must follow uniform practices across States/UTs.
- Avoid frivolous clarifications in FORM GST REG-03.
- GSTN to update backend software workflows in line with this advisory.
- Proper training and compliance monitoring must be enforced at field level
Expected Impact of the Advisory
Objective | Impact |
Prevent Harassment | Genuine applicants to face fewer queries and delays |
Reduce Registration Rejections | By eliminating requests for irrelevant documents |
Enhance Process Uniformity | Standard procedure across States and Union Territories |
Safeguard Against Fake Registrants | No dilution in verification where fraud risk is suspected |
Ease of Doing Business | Supports startup ecosystem and MSME sector |
Additional Considerations for Applicants and Professionals
Tips to Avoid Delays in GST Registration
- Upload only legally required documents – Refer to CBIC advisory.
- Double-check clarity of scanned copies to avoid queries.
- Don’t provide extra documents voluntarily — they may cause confusion.
- Review REG-01 guidelines thoroughly before submission.
- Respond promptly and accurately to any REG-03 clarification, if raised.
Common Mistakes That Lead to Rejection
- Uploading illegible or outdated documents
- Failure to provide proof of possession for business premises
- Submitting inconsistent business details (PAN mismatch, wrong business type)
Not attaching necessary affidavits in special cases (like unregistered rental premises)
Conclusion
The Instruction No. 03/2025-GST is a welcome move towards procedural rationalization and regulatory fairness. It reflects the Government’s intent to prevent GST fraud without impeding genuine business registrations. The emphasis on documentary sufficiency and avoidance of arbitrary discretion by field officers aligns with Section 25 of the CGST Act and improves the ease of compliance.
Going forward, applicants and professionals handling GST registrations should closely align their documentation with the updated instructions to avoid unnecessary clarifications or rejections.
The move will benefit startups, MSMEs, and tax professionals across India, bringing clarity and reducing unnecessary bureaucratic hurdles. It’s now more important than ever to stay updated and compliant with the latest CBIC advisories and legal procedures.
For more such important GST law updates, follow TaxGroww – your trusted source for in-depth legal insights.