Board has received feedback regarding challenges faced by applicants in obtaining GST registration, primarily due to the nature of clarifications being sought by officers. These clarifications often pertain to information submitted in FORM GST REG-01 or requests for additional documents not listed in the FORM’s prescribed list. While preventing the registration of fraudulent firms is essential, it is equally important to avoid unnecessary delays or harassment of genuine applicants.

Issues Identified:

It has come to attention that inconsistent practices are being followed in the verification of documents, leading to unnecessary queries and delays in processing applications. These queries primarily concern proof of the principal place of business, business constitution details, and identification of authorized signatories or owners.

Previous Instructions:

Previously, guidelines for processing GST registration applications were issued under Instruction No. 03/2023-GST dated 14th June 2023. Due to several changes in back-office operations and an increase in complaints, Board have issued comprehensive new instructions to ensure clarity in processing registration applications.

Key Guidelines for Officers Processing Applications:

1. Documents for Principal Place of Business (PPOB):

• Owned Premises: Accept documents like the latest property tax receipt, municipal khata copy, or electricity bill. No additional documents should be requested.
• Rented Premises: Accept the rent/lease agreement along with one document proving the lessor’s ownership (e.g., electricity bill, property tax receipt). In the absence of a registered agreement, the agreement along with identity proof of the lessor will suffice.
• Premises Owned by Spouse/Relative: A consent letter from the owner, along with their identity proof and a document proving ownership, should be sufficient.
• Special Economic Zones: Documents from the Government of India are required.

2 Constitution of Business:

• For partnership businesses, a partnership deed is required.
• For entities like societies, trusts, or clubs, a registration certificate or proof of constitution is necessary.

3. Avoiding Unwarranted Queries:

Officers are guided to refrain from asking irrelevant questions, such as whether the applicant’s address matches their registration city, or if their business activities can be conducted from the declared premises. Queries should only be related to the documents submitted.

4. Processing the Application:

• Officers must ensure documents are legible, complete, and relevant.
• Applications should be approved within 7 working days if no risks are flagged.
• For flagged applications, registration must be granted within 30 days, with physical verification if required.

5. Physical Verification:

• If physical verification is required, it must be completed within the stipulated 30 days.
• Officers must submit reports (including GPS-enabled photos) at least 5 days before the 30-day deadline.

6. Queries & Clarifications:

• If required, clarifications or additional documents may be requested within 7 working days of the application submission (if not flagged as risky).
• Any additional documents should only be sought with the approval of the Deputy/Assistant Commissioner.

7.Final Steps:

• Applicants must respond to queries within 7 working days.
• If the response is satisfactory, registration should be approved within 7 working days.
• If the response is unsatisfactory, the application should be rejected with an explanation.

Instructions for Chief Commissioners:

• Supervise the processing of registration applications and address any deviations from these instructions.
• Take action against officers not adhering to these guidelines.
• Ensure adequate staffing to process applications in a timely manner.