The Central Board of Indirect Taxes and Customs (CBIC) has recently issued Instruction No. 03/2025-GST dated 17th April 2025, aimed at streamlining the GST registration process and preventing unnecessary delays. This new instruction replaces the earlier guidelines issued in June 2023 and comes in response to mounting complaints about inconsistent practices and undue documentation demands during the registration process.

Let’s break down what these new directions mean for applicants and tax professionals.

Purpose of the New Guidelines

The CBIC has emphasized two core objectives:

1. Prevent fraudulent registrations designed to pass on fake Input Tax Credit (ITC).

2. Protect genuine applicants from being harassed or delayed by avoidable queries and excessive documentation.

Key Highlights of the Instruction

1. Follow the Document Checklist in FORM GST REG-01

Officers are instructed to strictly adhere to the indicative document list already mentioned in the GST registration form. No extra or irrelevant documents should be demanded.

2. Documents for Principal Place of Business (PPOB)

For Owned Premises:

• Upload any one: electricity bill, property tax receipt, or municipal records. No physical copy or additional proof required.

For Rented Premises:

• Rent/Lease agreement + ownership proof of the lessor.

• Lessor’s ID proof only if rent agreement is not registered.

Shared or Consent-Based Premises:

• Consent letter + ID proof of consenter + ownership proof (like electricity bill).

No Rent Agreement?

• Submit an affidavit + utility bill in applicant's name, duly notarized or executed before a magistrate.

SEZ Units:

• Upload official SEZ approval documents.

3. Proof of Constitution of Business

• For partnerships: Partnership Deed is enough.

• For societies, trusts, clubs, or AOPs: Registration Certificate suffices.

• No need for MSME certificate, Udyam, or trade licenses unless otherwise required by law.

4. Avoid Presumptive or Irrelevant Queries

Officers should not raise irrelevant objections like:

• “Applicant’s residential address is in a different state.”

• “HSN Code not allowed in this region.”

• “Business activity doesn’t match location type.”

5. Timelines for Processing Applications

• Low-risk applications: Must be processed within 7 working days.

• Risk-flagged or Aadhaar-unverified applications: Can take up to 30 days, after physical verification.

6. Physical Verification Rules

• Must be done per Rule 25 of CGST Rules.

• Photos with GPS, field notes, and documents to be uploaded in FORM GST REG-30 at least 5 days before the 30-day window ends.

• Officer must confirm existence or absence of business clearly in the report.

7. Clarifications & Rejections

• Any query must be specific, based on incomplete or unreadable documents, or address mismatches.

• Applicant must respond via FORM GST REG-04 within 7 working days.

• The officer has 7 more days to accept or reject via FORM GST REG-05, with reasons recorded in writing.

• No action within time = application should not be approved on deemed basis; officers will be held accountable.

Accountability & Oversight

Senior officers have been directed to:

• Monitor registration processing regularly.

• Take strict action against officers deviating from these rules.

• Ensure sufficient staff is deployed for timely registration.

Final Thoughts

This instruction is a welcome move towards transparent and applicant-friendly GST registration. It balances the need for verification with the applicant’s right to hassle-free registration. For businesses and consultants, knowing these rules helps avoid delays and strengthens your position when dealing with unjustified queries.

If you're facing issues with your GST registration or need expert help in submitting a complete and compliant application, feel free to reach out to S2S Biz Solutions for smooth, end-to-end support.

Contact us today for GST Registration Support