Summary of GST Instruction No 03/2025 dated 17-04-2025
GST Instruction No. 03/2025, issued on 17-04-2025, gives updated guidelines for getting GST registration. It replaces the earlier Instruction No. 03/2023-GST dated 14-06-2023. As per the new instructions, officers must follow only the list of documents mentioned in FORM GST REG-01 and should not ask for any extra or unnecessary documents.
As per Instruction No. 03/2025, there are mainly three common issues found during the GST registration application.
- Proof of principal place of business
- Type or constitution of the business
- Identity proof of the owner or authorized signatory.
Documents to be sought from applicants while processing applications:
For Principal Place of Business (PPOB):
| Scenario | Required Documents | Important Notes |
| If the Premises is owned by the applicants | Any one of the following:
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| If the premises are rented/leased | Both of the following: 1. Valid Rent/Lease Agreement 2. Any one document proving ownership by the landlord: —> Property Tax Receipt | Do not ask for: · Landlord’s PAN Card · Aadhaar Card · Photograph of the landlord with the building |
Additional Clarification on Principal Place of Business (PPOB) Documents:
| Scenario | Documents Required |
| Rent /Lease Agreement is NOT registered | – Unregistered Rent/Lease Agreement – Any one ownership document (e.g., electricity bill, property tax receipt, etc.) – Identity proof of landlord |
| Rent /Lease Agreement is registered | – Registered Rent/Lease Agreement – Any one ownership document (e.g., electricity bill, property tax receipt, etc.) |
| Utility bill (electricity /water) in tenant’s name | – Utility bill in applicant’s name – Rent agreement |
| Premises owned by Spouse/relative | Consent letter on plain paper from owner – Owner’s ID proof – Any one ownership document (e.g., electricity bill, property tax receipt, etc.) |
| Shared premises | – If Rent/Lease Agreement is available: • Agreement + any one ownership proof – If agreement is NOT registered: • Agreement + ownership proof + lessor’s ID – If agreement is registered: • Agreement + ownership proof only |
Additional Scenarios for PPOB Proof:
| Scenario | Documents to upload |
| No Rent /Lease Agreement, but someone else (owner) provides premises | – Consent letter from the owner (on plain paper) – ID proof of the consenter (owner) – Any one ownership document (e.g., electricity bill, property tax receipt, etc.) |
| No Rent/Lease Agreement, but applicant is using the premises | – Affidavit stating rent/lease agreement is not available • On non-judicial stamp paper (minimum value) • Executed before Judicial Magistrate, Executive Magistrate, or Notary Public – Any document showing possession (e.g., electricity bill in applicant’s name) |
| Business located in Special Economic Zone | – Required SEZ documents/certificates issued by the Government of India |
Constitution of Business— Required Documents:
| Type of Applicant | Documents to upload | Notes |
| Partnership Firm | Partnership Deed | Only a Partnership deed is sufficient. Do not ask for: · Udhyam Certificate · MSME Certificate · Shop & Establishment Certificate · Trade License |
| Society/Trust/Club/Government Department /Local Authority etc | Registration Certificate or Proof of Constitution | This one Document is Sufficient & No additional documents are required |
Unwarranted or Presumptive Queries to Avoid:
| Presumptive Query raised by Officer | Why it should be avoided |
Asking why applicant’s/MD’s/Signatory’s residential address is in a different city or state | Not relevant to GST registration eligibility |
Objection to HSN code of goods/services being banned or restricted in that state | Officer’s role is not to verify legality of products; only document validation |
Questioning if business activity can be carried out from declared premises (e.g., factory in residential area) | Officers should not make assumptions; focus on submitted documents only |
Processing GST Registration Applications-
| Steps | Details | Action Required /Notes | |
| Scrutiny of Documents | Officer must verify documents uploaded in FORM GST REG-01 (photo, PPOB, constitution, bank details, etc.) | – Ensure documents are clear, complete, and relevant – Cross-verify info with uploaded docs – Verify address from public sources (e.g., electricity board, municipality) | |
| Approval Without Risk Flags | If application is not flagged as risky and is complete and correct | Must be approved within 7 working days | |
| Approval with Physical Verification | Physical verification required if: 1. Aadhaar authenticated but flagged as risky 2. Aadhaar not authenticated 3. Officer wants verification (with AC/DC approval) | The application must be approved within 30 days, after verification | |
| Guidelines for Physical verification | Officer Must: – Start verification immediately | – Upload at least 5 days before 30-day deadline – Report must confirm existence or efforts made – Upload GPS-tagged photos – Reassign ARN if in wrong jurisdiction | |
| When to Seek Clarifications ( Form GST REG-03) | Officer may issue REG-03 only if: 1. Documents are unclear or incomplete 2. Address mismatch or invalid 3. Address vague/incomplete 4. GSTIN on PAN is cancelled/suspended | Queries should be limited to above reasons only | |
| Issuing REG-03 & Extra Documents Requests | REG-03 notice timelines: – Within 7 days if not risky – Within 30 days if flagged as risky | – If an extra doc (not in REG-01) is needed → get approval from DC/AC -Do not approve on deemed basis -Do not ask presumptive queries -Do not raise irrelevant objections. | |
| Applicant’s Reply (FORM GST REG-04) | Reply must be given within 7 working days of REG-03 |
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| No Reply from Applicant | No reply received within 7 working days of REG-03 | Officer can reject in REG-05 within 7 days from reply to due date, with recorded reasons |
