CBIC Instruction 03/2025-GST: How GST Registration Applications Must Be Processed (and What Applicants Should Prepare)
Learn how the latest CBIC guidelines streamline the GST registration process, ensuring efficiency and clarity for new entrepreneurs.
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Created: 11th August, 2025 12:26 AM, last update:11th August, 2025 12:32 AM
CBIC Instruction 03/2025-GST: How GST Registration Applications Must Be Processed (and What Applicants Should Prepare)
On 17 April 2025, the Central Board of Indirect Taxes & Customs (CBIC) issued Instruction No. 03/2025-GST to standardise how officers verify and decide GST registration applications. The Instruction aims to stop fraudulent registrations without harassing genuine applicants and replaces the earlier Instruction 03/2023-GST.
Why this Instruction matters
The Board noted uneven practices across field formations—avoidable queries, extra-statutory document demands, and delays—especially around proof of principal place of business (PPOB), constitution of business, and identity details. This Instruction clarifies what can (and cannot) be asked, and sets strict timelines for approval, verification, queries, and rejection.
What documents can officers ask for?
A. Principal Place of Business (PPOB)
Owned premises (PPOB in owner’s name) Any one document is sufficient—latest property tax receipt, municipal khata copy, electricity bill, or similar (e.g., water bill) that clearly shows ownership. Do not ask for originals.
Rented/leased premises (agreement available) Upload the valid rent/lease agreement plus any one ownership proof of the lessor (e.g., property tax, khata, electricity bill). Extra KYC of the lessor (PAN, Aadhaar, photos) should not be sought. If the agreement is registered, no identity proof of the lessor is to be asked. If the electricity/water connection is in the tenant’s name, that with the agreement is adequate.
Other situations (spouse/relative’s premises, shared premises, or no agreement)
- Consent letter: Plain-paper consent + ID of the consenter + one ownership proof (property tax/khata/electricity/water bill) suffices.
- Shared premises: Copy of rent/lease and one ownership proof is enough. If the agreement is registered, do not seek lessor’s ID.
- No rent/lease agreement: An affidavit (on minimum-value non-judicial stamp paper before a First-Class/Executive Magistrate/Notary) plus any document showing possession (e.g., electricity bill in applicant’s name).
SEZ units/developers must upload the necessary GOI certificates.
B. Constitution of business
- Partnerships: Upload the partnership deed; do not ask for Udyam/MSME/shop-establishment/trade licence etc.
- Society/Trust/Club/Government/AOP/BOI/Local Authority/Statutory Body/Others: Upload the registration certificate/proof of constitution.
Queries officers must not raise
“Presumptive” or irrelevant queries are barred—for example, questioning why the authorised signatory’s residence is in a different city/state, alleging a listed HSN is “banned” in that state, or claiming the business activity “cannot be conducted” from that premises. Only ask what relates to the application and listed documents.
How applications must be processed (step-by-step)
1) Scrutiny of the application and uploads
Officers must check legibility, completeness, and relevance of all uploads in REG-01, cross-verify details with documents, and—where possible—validate address proofs against public sources (land registry, utilities, municipalities, local bodies).
2) Timelines for approval or verification
- Non-risky applications (not flagged on the portal and complete): Approve within 7 working days of submission.
- Cases requiring physical verification – registration must be granted within 30 days of submission after PV, if: (a) Aadhaar-authenticated but flagged risky, or (b) Aadhaar authentication not done/not opted, or (c) Officer (with AC-level approval) deems PV fit.
3) Physical verification (PV): how to do it
- Start PV immediately; follow rule 9 read with rule 25.
- Upload REG-30 (with photographs) at least 5 days before the 30-day deadline runs out.
- Record whether the declared principal place exists; if not found, record efforts made to locate it.
- Upload GPS-enabled site photos.
- If ARN belongs to a different jurisdiction, reassign it immediately.
4) When can REG-03 (notice for clarification) be issued?
Only on limited grounds—e.g., illegible/incomplete documents, address mismatch/invalid proof, incomplete address, or where another GSTIN on the same PAN is cancelled/suspended.
Timelines:
- Issue REG-03 within 7 working days (non-risky) or within 30 days (risky) from application date.
- Any extra document beyond the prescribed list can be sought only with prior approval of the Deputy/Assistant Commissioner.
- Ensure no “deemed approvals” occur due to inaction. Avoid presumptive queries and minor, irrelevant deficiencies.
5) Applicant’s reply and officer’s decision
- Applicant must reply in REG-04 within 7 working days of REG-03.
- If satisfied, officer must approve within 7 working days of receiving REG-04.
- If not satisfied, reject in REG-05 within 7 working days, with recorded reasons.
- If no reply to REG-03 within 7 working days, reject in REG-05 within 7 working days after the reply window expires.
Accountability and oversight
Zonal leadership must: (i) periodically review registrations, PVs, query patterns, and deemed approvals; (ii) take strict action for deviations; (iii) staff adequately for timely disposals; and (iv) issue trade notices to clarify acceptable local documents.
Practical checklists
For applicants (what to upload)
- PPOB: One clear ownership/occupancy proof as per your situation (owned/rented/consent/shared/no agreement), plus rent/lease (if applicable). Don’t over-upload—one valid proof is enough.
- Constitution: Partnership deed (for firms) or registration/constitution certificate (for society/trust/club/LA/statutory body/others).
- Avoid delays: Ensure all files are legible, address fields complete, and details match the documents you upload.
For officers (what to follow)
- Stick to the indicative list in REG-01; don’t demand extra KYC of landlords or originals.
- No presumptive queries unrelated to the application/documents.
- Meet timelines: 7 working days for non-risky approvals; PV-based grants within 30 days; REG-03/REG-04/REG-05 windows as specified.
- Seek AC/DC approval before asking anything beyond the prescribed list.
Bottom line
Instruction 03/2025-GST tightens controls against bogus registrations while protecting genuine applicants from over-reach. If both sides follow the precise document list and timelines, registrations should be faster, cleaner, and more consistent across India.
For implementation issues, CBIC has asked that difficulties be emailed to the Board (gst-cbec@gov.in).
If you want, I can also turn this into a printable 1-page SOP (officer checklist + applicant checklist), or a website explainer targeted at new GST registrants.
Frequently Asked Questions
What is CBIC Instruction 03/2025-GST and why is it important?
CBIC Instruction 03/2025-GST, issued on April 17, 2025, standardizes the processing of Goods and Services Tax (GST) registration applications in India. Its importance lies in mitigating fraudulent registrations while ensuring legitimate applicants aren't subjected to unnecessary scrutiny. This instruction replaces the previous 03/2023-GST and addresses inconsistencies in GST registration across various field formations. By clarifying permissible inquiries and setting strict timelines for processing, it aims to streamline the registration process, offering new entrepreneurs a clearer pathway to compliance.
What documentation is required for GST registration under this instruction?
For GST registration, applicants need to prepare specific documents, including proof of the Principal Place of Business (PPOB), identity proof, and constitution of the business. Form REG-01 is the primary application form to be filled out. Understanding the exact requirements based on your business type is crucial. By having all required documents ready and legible, you can avoid delays in the registration process, as this instruction emphasizes the need for clarity and completeness in submissions.
How does Instruction 03/2025-GST help reduce fraudulent registrations?
Instruction 03/2025-GST introduces stricter verification processes aimed at reducing instances of fraudulent registrations. By standardizing the inquiry process and limiting arbitrary requests for additional documentation, it minimizes the opportunities for fraud. The instruction mandates a timeline for approval and verification, ensuring that applications are processed efficiently without unnecessary delays. This structured approach not only protects tax revenue but also fosters a more reliable GST registration environment for legitimate businesses.
What should new entrepreneurs do to prepare for GST registration?
New entrepreneurs should take a proactive approach to prepare for GST registration by ensuring all necessary documentation is in order. Start by gathering proof of your Principal Place of Business (PPOB), identity documents, and any other required information specific to your business structure. Familiarizing yourself with the application process, particularly Form REG-01, is essential. Additionally, it’s advisable to respond promptly to any queries or notices from tax officers, as timely communication is emphasized in the guidelines to adhere to set timelines.
What are the challenges in implementing Instruction 03/2025-GST?
Implementing CBIC Instruction 03/2025-GST comes with challenges, primarily related to training tax officers on the new guidelines. Some officers may be resistant to change, preferring established practices over the new standardized procedures. Ensuring that all officers are well-versed in the updated instructions is crucial for effective implementation. Moreover, monitoring compliance and addressing any discrepancies in application processing can be a workload challenge, potentially impacting the intended benefits of streamlined GST registration.
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