GST Registration Simplified (Instruction No. 03/2025-GST)

GST Registration Process

Introduction

Applying for a GST registration in India has often been a frustrating experience for many genuine applicants. Frequent and arbitrary queries by officers, unpredictable document demands, and delays in approval have all contributed to inefficiencies in the process. The Central Board of Indirect Taxes and Customs (CBIC), through Instruction No. 03/2025-GST dated 17th April 2025, has now taken concrete steps to address these concerns and streamline the process.

In this blog, we break down the common issues faced by GST applicants and explain in detail the revised procedure and document requirements introduced by this instruction.

Problems Faced by GST Applicants

  1. Excessive Clarifications Sought by Officers:
    Officers were frequently seeking unnecessary clarifications unrelated to the documents submitted, such as questioning business feasibility based on location or type of goods.

  2. Demand for Additional Documents:
    Officers often demanded documents not listed in FORM GST REG-01, such as Aadhaar or photographs of the landlord, even when not required by law.

  3. Rejection on Presumptive Grounds:
    Applications were sometimes rejected on irrelevant presumptions—for instance, because the applicant’s residence wasn’t in the same state as the business, or the business type didn’t “seem suitable” for the given address.

  4. Inconsistent Practices Across States and Zones:
    There was no uniformity in processing registrations, leading to confusion and delays, especially for businesses operating in multiple states.

  5. Delays in Physical Verification:
    Risk-flagged applications often got delayed due to late or improperly conducted physical verifications.

CBIC’s New Instructions: A Simplified and Uniform Approach

CBIC’s Instruction No. 03/2025-GST supersedes the earlier guidelines and introduces a clear, structured, and uniform approach for processing GST registration applications. Here’s a summary of what it mandates:

1. Document Requirements for GST REG-01 Application

A. Principal Place of Business (PPOB)

  • Owned Premises: Any one of the following is sufficient:

    • Property tax receipt

    • Electricity bill

    • Water bill

    • Municipal Khata copy

  • Rented/Leased Premises:

    • Unregistered Rent Agreement + owner’s proof of identity + ownership document (as above)

    • Registered Rent Agreement + ownership document (no need for ID proof of lessor)

    • Electricity or water bill in applicant’s name + rent agreement is also acceptable

  • Consent from Relatives/Shared Premises:

    • Consent letter on plain paper + identity proof of consenter + any ownership document of consenter

  • No Agreement Available:

    • Affidavit on non-judicial stamp paper + document such as electricity bill in applicant’s name

  • SEZ Units:

    • Government-issued SEZ documents are mandatory

B. Constitution of Business

  • Partnership Firm: Upload Partnership Deed only

  • Society/Trust/Others: Submit Registration Certificate or similar valid proof

Note: Officers are directed not to ask for MSME certificate, trade license, Udyam registration, etc.

2. Guidelines for Officers: What They Can and Cannot Ask

  • Officers must only refer to the official document list.

  • No presumptive or irrelevant queries are allowed (e.g., questioning the feasibility of business at that location).

  • Officers cannot demand originals or extra photos of the property owner or applicant.

  • Additional documents beyond the prescribed list can only be requested with approval from Assistant Commissioner.

3. Timelines and Verification Process

  • Applications not flagged as risky:

    • Must be processed within 7 working days

    • If complete and in order, must be approved without delay

  • Risky applications / Aadhaar not authenticated / Physical verification needed:

    • Must be processed within 30 days

    • Physical verification must be done and report submitted at least 5 days before deadline

  • Officers must:

    • Upload GPS-enabled photos of business premises during verification

    • Clearly report existence or non-existence of premises

    • Record efforts made in case of non-traceability

4. Communication with Applicants

  • Officers must issue notice (FORM GST REG-03) within the above deadlines if documents are incomplete or unclear.

  • Applicant has 7 working days to respond via FORM GST REG-04.

  • If satisfied, officer approves application within another 7 working days.

  • If not satisfied or no reply is received, officer may reject the application using FORM GST REG-05.

5. Responsibility and Monitoring

  • Senior officers must periodically review the status of application processing.

  • Strict action will be taken against officers who fail to comply.

  • Adequate staff must be deployed to ensure timely disposal of applications.

Conclusion

The new instructions under 03/2025-GST are a welcome relief for genuine businesses and entrepreneurs in India. By eliminating unnecessary hurdles, CBIC aims to ensure that the GST registration process becomes transparent, time-bound, and harassment-free, while still being vigilant against fraud.

If you are planning to apply for GST registration, ensure your documents are in line with the official checklist and be aware of your rights under these new guidelines. For assistance or expert help with registration, feel free to reach out to our team.

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