NOTIFICATION UPDATES
Instruction No. 03/2025-GST dated 17 April 2025
CBIC issues detailed guidelines for GST registration processing – safeguards for taxpayers clarified.
CBIC has issued Instruction No. 03/2025-GST superseding Instruction No. 03/2023- GST to streamline the processing of applications for GST registration filed in FORM GST REG-01. The move comes in light of multiple complaints regarding delays and arbitrary document demands by field formations, often resulting in the rejection of genuine applications. The instruction outlines uniform guidelines and imposes restrictions on the discretionary practices followed by officers.
Key highlights relevant to taxpayers:
Strict adherence to document list in FORM GST
REG-01
Officers are instructed to request only the documents prescribed in
FORM GST REG- 01. For proof of Principal Place of Business, only
one document from the indicative list (e.g., electricity bill,
property tax receipt) will suffice. No original physical copies are
to be demanded.
Clear conditions for rented/shared
premises
For rented premises, a valid rent/lease agreement along with any
one ownership proof document of the lessor is sufficient. If the
agreement is registered, no identity proof of the lessor is
required. For shared or consent-based premises, a consent letter
with the consenter's identity proof and one ownership document
is acceptable. In absence of lease agreements, an affidavit along
with possession proof (e.g., electricity bill in applicant's
name) is permissible.
No presumptive or irrelevant objections
Officers are directed not to raise presumptive queries such as
mismatched business and residential address, prohibited nature of
goods in a State, or impracticality of activities from the declared
premises. Only queries based on actual deficiencies in the
application are allowed.
Defined processing timelines
Applications not flagged as "risky" must be processed
within 7 working days. In cases requiring physical verification
(due to Aadhaar non-authentication or risk flags), registration is
to be granted within 30 days, and the verification report must be
uploaded at least 5 days prior to expiry.
Conditions for seeking clarifications (FORM GST
REG-03)
Clarification can be sought only for incomplete, illegible, or
mismatched documents, or if linked GSTINs have been
suspended/cancelled. Officers must obtain approval from a
Deputy/Assistant Commissioner before requesting documents not
specified in FORM GST REG-01.
Restrictions on application rejections
Applications can be rejected via FORM GST REG-05 only after due
examination of replies filed in FORM GST REG-04. Inaction by
officers shall not lead to deemed approvals. Grounds for rejection
must be recorded in writing.
Oversight and accountability
Supervisory officers are instructed to monitor application
processing, prevent deemed approvals, and take strict action
against non-compliance with these directions.
Taxpayers facing arbitrary document requests or procedural delays may now seek redressal and contest the same basis said Instruction.
TECHNICAL UPDATES
Gross and Net GST revenue collection report for the month of March 2025
The GSTN team has released Gross and Net GST revenue collections for the month of March 2025. Detailed report may be viewed here.
Advisory for Biometric-Based Aadhaar Authentication and Document Verification for GST Registration Applicants of Assam
In accordance with the amended Rule 8 of the CGST Rules, 2017, which provides that an applicant can be identified on the common portal, based on data analysis and risk parameters for Biometric-based Aadhaar Authentication and also provides for taking a photograph of the applicant along with the verification of the original copy of the documents uploaded with the application, the GSTN has developed said functionality . The said functionality has been rolled out in Assam on 1 April 2025. The advisory also outlines the detailed procedure for the document verification and appointment booking process.
Advisory on Case Insensitivity in IRN Generation
The Team GSTN has announced that with effect from 1 June 2025, the IRP (Invoice Reporting Portal) would treat invoice/document numbers as case-insensitive for the purpose of IRN generation. To ensure consistency and avoid duplication, invoice numbers reported in any format (e.g., "abc", "ABC", or "Abc") would be automatically converted to uppercase before IRN generation. This change aligns with the treatment of invoice numbers in GSTR-1, which already treats them as case- insensitive.
Advisory on reporting values in Table 3.2 of GSTR-3B
The Team GSTN has announced that with effect from the April 2025 tax period, Table 3.2 of GSTR-3B (inter-state supplies to unregistered persons, composition taxpayers, and UIN holders) will be auto-populated and non-editable. Any corrections must be made through GSTR-1, GSTR-1A (before filing GSTR-3B), or IFF in subsequent periods. Taxpayers are advised to ensure accurate reporting in these forms to avoid discrepancies in GSTR-3B.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
