Introduction
The Central Board of Indirect Taxes and Customs (CBIC) has issued Instruction No. 03/2025-GST on 17th April 2025, simplifying the process for GST registration. This comes as a much-needed relief for genuine applicants who often face hurdles and unnecessary queries during the registration process.
In this article, we break down the key highlights, documentation requirements, officer responsibilities, and processing timelines, all in an easy-to-understand format.
Objective of the Instruction
The instruction addresses a dual challenge:
- Prevent fake registrations used to fraudulently avail input tax credit (ITC).
- Ensure smooth registration for genuine applicants without undue delays or harassment.
Common Issues Identified
| Issue | Impact |
| Officers asking for extra, non-listed documents | Delays and confusion |
| Raising irrelevant queries | Unnecessary rejections |
| Inconsistent document scrutiny across jurisdictions | Lack of uniformity |
Clarified Document Requirements for GST REG-01
1️. Principal Place of Business (PPOB)
| Type of Premises | Required Documents | Clarifications |
| Owned | Any ONE of: Electricity Bill, Property Tax Receipt, Water Bill, Municipal Khata | No original or extra documents should be demanded |
| Rented/Leased (Unregistered Agreement) | Rent Agreement + One ownership proof of lessor + Lessor’s ID | Only ONE ownership doc needed |
| Rented/Leased (Registered Agreement) | Registered Agreement + One ownership proof of lessor | No ID proof of lessor required |
| Spouse/Relative Owned | Consent Letter + Owner’s ID + Ownership proof | Consent letter can be on plain paper |
| Shared Premises | Rent/Lease Agreement + Ownership proof | If no agreement, then consent letter + ID + ownership proof |
| No Rent Agreement | Affidavit (on stamp paper before Notary or Magistrate) + Electricity Bill in applicant’s name | Valid in absence of rent agreement |
| SEZ Applicant | SEZ Certificate issued by competent authority | Mandatory for SEZs |
2️. Constitution of Business
| Entity Type | Required Document | No Longer Required |
| Partnership Firm | Partnership Deed | Udyam/MSME/Trade License |
| Society/Trust/Club/Others | Registration Certificate or proof of constitution | No other local licenses needed |
What Officers Should Not Ask
Officers are instructed not to raise presumptive or irrelevant queries, such as:
- Why is the authorized signatory’s residence in another city/state?
- The HSN code mentioned is not allowed in the state.
- The business activity doesn’t match the location.
Such queries are outside the scope of registration and cause unnecessary delays.
Timelines for GST Registration
| Application Type | Time Limit | Condition |
| Not flagged as risky | 7 working days | No physical verification needed |
| Flagged as risky / Aadhaar not authenticated | 30 days | With mandatory physical verification |
If physical verification is needed, the report (with photos) must be uploaded at least 5 days before the 30-day deadline.
Clarification Process (REG-03 & REG-04)
| Step | Form | Time Limit |
| Notice for clarification | REG-03 | Within 7/30 days |
| Applicant’s reply | REG-04 | Within 7 working days |
| The officer’s decision | REG-05 or Approval | Within 7 working days from REG-04 reply |
Officers must not reject without valid, written reasons and should not ask for documents not listed unless approved by a Deputy/Assistant Commissioner.
Supervision & Accountability
CBIC instructs senior officers to:
- Supervise registrations, including physical verifications and queries raised.
- Avoid “deemed registrations” due to officer inaction.
- Take disciplinary action for guideline violations.
- Issue local trade notices to recognize regional documentation norms.
Final Word
- These streamlined guidelines are a big step forward in simplifying GST compliance for honest taxpayers and startups. It reduces red tape, promotes uniformity, and ensures faster registrations.
- If you’re applying for GST registration, make sure to submit only the documents listed in REG-01—nothing more, nothing less.
- For official guidance or difficulties, you can contact CBIC at gst-cbec@gov.in.
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