CBIC issues fresh guidelines to curb GST registration harassment, ensure faster grievance redressal

The Central Board of Indirect Taxes and Customs (CBIC) has issued a key circular clarifying the rules to be followed by GST proper officers during the registration process. The circular comes in response to a rising number of complaints from taxpayers about alleged harassment during the registration stage.

CBIC specifically highlighted that the issue lies with the registration process, stressing that officers must refrain from raising presumptive or irrelevant queries that go beyond the scope of the documents and information submitted by applicants. The board directed that only queries directly related to the application should be raised to avoid unnecessary delays and inconvenience.

"Officers have been instructed to strictly adhere to the prescribed list of documents provided in registration application form. Requisite documents in specific cases to be uploaded with registration application form have also been delineated in the instructions. Officers have been directed not to issue notices based on presumptive grounds, minor discrepancies, or for additional documents that are not essential for processing applications. Officers have been also directed to seek approval of the concerned Deputy/Assistant Commissioner in cases where document apart from the listed documents is required to be sought," CBIC said in the circular.

Top points mentioned in the CBIC circular

> It is noted that varied practices are being followed by the officers in respect of verification of documents and details provided in FORM GST REG-01. It has also been observed that while processing the application, avoidable clarifications are being sought by the officers leading to delay in getting registration as well as rejection of applications.

> References have been received in the Board regarding difficulties being faced by the applicants in getting a GST registration, mainly on account of nature of clarifications being sought by the officers with respect to information submitted in the application FORM GST REG-01 and seeking of additional documents which are not prescribed in the List of Documents appended to FORM GST REG-01.

> While on one hand, there is a need to prevent registration of fraudulent firms created for passing on input tax credit (ITC) without any underlying supply, on the other hand, there is a need to ensure that genuine applicants seeking registration are not unduly harassed.

> An analysis of the information/clarifications/documents sought in FORM GST REG-03 reveals that these were mainly on account of proof of principal place of business, constitution of business, identity details of authorized signatory, owner etc.

"In practice, seeking GST registration has been a cumbersome process for many taxpayers as the registration process is not standardised and there were many ambiguities on procedural aspects (including on address verification for genuine businesses operating from co-working spaces among others). Different GST officers would often ask for different documentation and it was at their discretion as to which documentation is to be accepted or not. This often delayed the registration process and was a reason of frustration amongst the taxpayers as without a GST registration, it was difficult to claim input tax credit (ITC) or even issue a sales invoice. The CBIC issuing a circular listing specific process to follow and checklist of documentation to be submitted, is a welcome step, and further it also talks about strict actions against erring officials. The real test now is how soon and effectively the standardised process is implemented at the ground level," said CA Darshika Thacker, Partner, Thacker & Associates.

Documents required 

> For owned premises, applicants need to upload any one valid ownership document—such as a property tax receipt, municipal khata, electricity bill, water bill, or any similar document recognized under state or local laws. A single uploaded document is sufficient; officers must not request additional or original physical copies during the registration process.

> For rented premises, applicants must upload a valid rent/lease agreement along with any one ownership document of the lessor—such as a property tax receipt, khata copy, electricity bill, or similar document under state or local laws. CBIC clarified that seeking extra documents like the lessor’s PAN, Aadhaar, or photograph is unnecessary. One valid document is sufficient to establish ownership.

> For premises owned by a spouse, relative, or others, a consent letter on plain paper, the consenter’s ID proof, and any one ownership document—like a property tax receipt, khata copy, electricity bill, or similar document under local laws—will suffice. No additional documents should be demanded from the applicant.

> If a rent/lease agreement is unavailable, an affidavit on non-judicial stamp paper (executed before a magistrate or notary) and any valid possession proof, like an electricity bill in the applicant’s name, will suffice. Relevant government-issued documents must be uploaded for SEZ units or developers.

"The CBIC’s latest guidelines are a welcome step towards ensuring that GST registration does not become an unnecessary bureaucratic hurdle for genuine businesses. The directive to curb presumptive and irrelevant queries will bring much-needed consistency and transparency to the registration process. The move to restrict officers from demanding documents beyond the prescribed list will significantly reduce harassment and delays faced by applicants. This is a clear signal from the CBIC to prioritize ease of doing business without compromising on due diligence," said Dinkar Sharma, Company Secretary & Partner, Jotwani Associates.

He added: "The emphasis on faster grievance redressal and defined documentation norms shows that CBIC is taking cognizance of ground realities. This will help curb arbitrary rejections and foster trust in the GST registration system. By mandating officer accountability and limiting discretion, CBIC has struck a balance between weeding out fraudulent registrations and facilitating genuine ones. It’s a timely reform aligned with India’s startup and MSME ecosystem needs."

Grievances

CBIC said: “It has been observed that various unwarranted documents are being sought by raising presumptive queries. Some of the common queries raised are that residential address of the applicant/Managing Director/Authorized Signatory is not in the same city or the State where the registration has been sought; HSN code of goods mentioned by the applicant in Registration application is banned or prohibited for sale in the State where the applicant wishes to conduct business; the kind of activities mentioned in the registration application can not be conducted from the particular premises etc. Officers handling registration applications should not ask any presumptive query which is not related to the documents or information submitted by the applicant.”

"In practice, seeking GST registration has been a cumbersome process for many taxpayers as the registration process is not standardised and there were many ambiguities on procedural aspects (including on address verification for genuine businesses operating from co-working spaces among others). Different GST officers would often ask for different documentation and it was at their discretion as to which documentation is to be accepted or not. This often delayed the registration process and was a reason of frustration amongst the taxpayers as without a GST registration, it was difficult to claim input tax credit (ITC) or even issue a sales invoice. The CBIC issuing a circular listing specific process to follow and checklist of documentation to be submitted, is a welcome step, and further it also talks about strict actions against erring officials. The real test now is how soon and effectively the standardised process is implemented at the ground level," said CA Darshika Thacker, Partner, Thacker & Associates.