CBIC’S REVISED GUIDELINES FOR GST REGISTRATION – April 2025

To boost the Ease of Doing Business, the CBIC-wide Instruction No. 03/2025-GST dated 17th April 2025, issued the latest instructions for processing of applications for GST registration. Applicants were facing difficulties in getting GST registrations, mainly due to the nature of clarification being sought by the officers, such as unnecessary documents outside the purview of the listed documents as prescribed in the GST registration form. To streamline the registration process, Physical verification, Nature of queries being raised, Deemed Registration, etc., for ensuring GST registrations without undue harassment to genuine applications, while preventing the fraudulent firms from getting the registration for bogus ITC claims, these instructions have been issued. Let’s dive deep into the Key changes this instruction aims to provide.

Why was there a need for Improvement?

It was leading to unnecessary delay and rejection mainly due to the following two reasons:

Avoidable Nature of Clarifications
Such as why the applicant/ Managing director/Authorized signatory’s residential address is not in the same city as the city in which registration is being applied for. or, why are there HS codes of Goods in registration that are banned/prohibited in the state for sale, etc.
Additional docs not Prescribed Anywhere
Mainly on account of proof of principal place of business, constitution of business, identity details of authorized signatory, owner etc. Documents such as UDHAYM (MSME) Certificate, Shop Establishment Certificate, trade license, etc., were being sought after.

What are the changes in documents to be sought after?

A. Documents in respect of Principal Place of Business (PPOB):

Status of Premise	Documents required	Important Change
Owned	Property Tax receipt/ Municipal Khata copy/Electricity Bill/ water bill or any other document prescribed under the State or the local laws, which clearly establishes the ownership of the premises (Hereinafter referred to as “Indicative List of Documents”)	Any one document uploaded on the portal will be sufficient, and no additional document should be requested from the applicant for proof of ownership of the premises of the applicant, and No query will be raised for asking the original physical copy of these documents from the Applicant
Rented (registered)	Rent/Lease agreement along with any one document in the indicative list of documents	PAN card, Aadhar Card, photograph of the lessor in front of/or inside the property are not required
Rented (Unregistered)	An agreement along with any one document in the indicative list and a Copy of the identity proof of the lessor	Where the Electricity or water bill is in the name of the applicant tenant, no additional documents pertaining to the lessor are required
Rented (Agreement Unavailable)	Affidavit to the effect, any one document from the indicative list	The affidavit should be executed on Non judicial stamp stamp paper of minimum value in presence of First-Class Judicial Magistrate or Executive Magistrate or Notary Public.
Ownership of Spouse/relative	Consent letter on plain paper, Identity proof of the person granting consent, and any one of the documents from the indicative list

Documents in respect of the Constitution of Business:

Nature of Business	Document required	Important Change
Partnership	Partnership Deed	Documents such as UDHYAM Certificate, MSME Certificate, Shop establishment certificate, trade license, etc., are not required.
Society, Trust, Club, Government Department, Association of Persons or Body of Individuals, Local Authority, Statutory Body, and Others etc.	Registration Certificate/Proof of Constitution is required

Updated Timelines

File Registration Application via FORM GST-REG01
Officer to check, Information and documents are Legible, Complete and Relevant, Cross Verify from publicly available resources such as land registry, electricity distribution companies, municipalities, and local bodies, etc.
Approve the application within 7 Days of receipt where details are found complete
Where the Applicant falls under the following conditions, grant the application within 30 days of submission after physical verification:
- The Applicant has been flagged as Risky
- The Applicant does not opt for Aadhaar authentication
- The officer may deem fit, after approval of the assistant commission or above rank
Where Physical verification is conducted, the officer is to upload the Physical verification report in accordance with provisions of rule 9 of CGST Rules, read with rule 25 thereof, at least 5 days prior to expiry of 30 days from the date of submission.
In case the application is found deficient, the officer may seek clarification or information, or document(s), as in the following cases:
- Document is incomplete or not legible
- Address Mismatch or the uploaded document does not appear to be valid proof
- Address is incomplete or vague
- Any GSTIN linked to PAN has been cancelled or suspended
The officer will issue a notice within 7 working days from the date of submission, 30 days (Where flagged risky). However, if any document apart from the listed documents in the indicative list is required to be sought, the officer shall seek the same only after the approval of the concerned Deputy/Assistant Commissioner
Applicant is required to furnish a reply within 7 working days from the date of receipt of notice
The officer, upon satisfaction with the reply, will approve registration within 7 working days from the date of receipt of the reply
Where the reply is unsatisfactory, the officer, after recording the reason in writing, will reject the application and inform the applicant electronically.

Summary

CBIC wide its latest instruction dated 17th April 2025 aims to ease GST registration by addressing delays and rejection due to unnecessary clarifications and additional documents being sought by the officers.

Key Changes include only one document from indicative list of documents (As listed above) is required to be furnished while filing refund application for proof of Principal place of business. Further, for the Business constitution certificates such as UDHYAM, MSME, trade license, etc., are not required.

Overall, this will reduce the processing time and help India improve its aim of Ease of doing business.

Disclaimer:
The contents of this article are intended solely for educational and informational purposes and do not constitute professional or legal advice. Readers are advised not to act upon the information provided without seeking guidance from a qualified professional. Every business or legal situation is unique, and professional consultation is recommended. Neither the author nor Growthinfy.com accepts any responsibility for any loss or damage incurred by relying on the information in this article.