by Shakshi Bharti | Jun 10, 2025 | GST, Circulars
Important Keywords: Circular No. 235/29/2024 - GST, GST on extruded snack foods, GST on car seats, GST railway AC, GST rate classification 2024, Finodha GST expert, HS code GST rate,
Words:1777; Read time: 9 minutes
Circular No. 235/29/2024-GST
F. No. CBIC-190354/149/2024-TO(TRU-II)-CBEC
Government of India
Ministry of Finance
Department of Revenue
(Tax Research Unit)
*****
North Block, New Delhi
Dated the 11th October 2024
Circular No. 235/29/2024 - GST: Clarification regarding GST rates & classification (goods) based on the recommendations of the GST Council in its 54th meeting held on 9 th September 2024 at New Delhi
To,
The Principal Chief Commissioners/ Principal Directors General,
The Chief Commissioners/ Directors General,
The Principal Commissioners/ Commissioners of Central Excise & Central Tax
Subject: Clarification regarding GST rates & classification (goods) based on the recommendations of the GST Council in its 54th meeting held on 9th September, 2024, at New Delhi-reg.
Madam/Sir,
Based on the recommendations of the GST Council in its 54th meeting held on 9th September, 2024, at New Delhi, in exercise of the powers conferred under section 168(1) of the Central Goods and Services Tax Act, 2017, the Board hereby clarifies the following issues through this circular for the purpose of uniformity in their implementation:
1. Clarification regarding GST rate on Extruded/Expanded Savoury food products:
1.1 Representations were received seeking clarification regarding appropriate classification and whether savoury or salted extruded snack pellets are classifiable under HS 2106 as Namkeens due to disputes in the field. Based on the recommendations of GST Council, with effect from 10.10.2024, extruded or expanded products, savoury or salted (other than un-fried or un-cooked snack pellets,
by whatever name called, manufactured through process of extrusion), falling under HS 1905 90 30 attract GST at the rate of 12% vide entry 32C of Schedule II of notification 1/2017-Central Tax (Rate) dated the 28th June, 2017 at par with namkeens, bhujia, mixture, chabena (pre-packaged and labelled) and similar edible preparations in ready for consumption form which are classifiable under HS 2106 90 of entry 46 of Schedule II of Notification 1/2017-Central Tax(Rate) dated the 28th June, 2017. The GST rate of 5% continue on un-fried or un-cooked snack pellets, by whatever name called, manufactured through process of extrusion.
1.2 However, it is clarified that the reduced GST rate of 12% on extruded or expanded products, savoury or salted (other than un-fried or un-cooked snack pellets, by whatever name called, manufactured through process of extrusion) falling under HS 1905 90 30 shall apply prospectively from the date of effect of the said notification. For the past period, 18% GSTshall be payable.
2. Clarification regarding GST rate on Roof Mounted Package Unit (RMPU) Air Conditioning Machines for Railways:
2.1 Representations have been received regarding classification of Roof mounted air conditioners for Railways as to whether these goods are to be classified under HS 8415 with 28% GSTrate or HS 8607 with 18% GST.
2.2 In this regard Goods falling under heading 8415 (including air conditioning machines) attract a GST rate of 28% vide S. No. 119 of Schedule IV of notification No. 01/2017-CT (Rate) dated 28.06.2017 (as amended). The goods falling under heading 8607
(including parts of railways or tramway locomotives) attract a GST rate of 18% vide S. No. 398G of Schedule III of notification No. 01/2017-CT (Rate) dated 28.06.2017 (as amended).
Machines and apparatus of heading 8415, which include Air conditioning machines, are excluded from the ambit of ‘parts’ covered under heading 8607 as per Section note 2 of
Section XVII of Customs Tariff Act, 1975. From a conjoint reading of Note 2 and Note 3 of the Section notes for the Section XVII, it is clear that goods of heading 8401 to 8479 (including 8415– Air Conditioning Machines) are excluded from the ambit of ‘parts’ covered under Chapter 86.
2.3 Although there is no ambiguity in the classification, to make it explicitly clear, it is clarified that the Roof Mounted Package Unit (RMPU) Air Conditioning Machines for Railways are classified under HS 8415.
3. Clarification regarding GST rate on Car and Motor cycle seats:
3.1 Representations were received seeking clarification regarding classification of seats meant for four wheeled cars and two-wheelers and the consequent GST rate on seats meant for four wheeled cars and two-wheelers.
3.2 With regards to seats for two wheelers, it is pertinent to note that the Explanatory Note for HS 9401 has specifically excluded items under HS 8714 (includes parts and accessories of two wheelers). The explanatory note for HS 8714 has a list of inclusions, which has mention of Saddles (seats). Thus, for two wheelers (HS 8711), the seats would be classifiable under HS 8714 attracting GST rate of 28% vide S. No. 174 of Schedule IV of notification No. 1/2017-Central Tax (Rate) dated 28th June, 2017 (as amended).
3.3 As regards seats for 4 wheeled vehicles, HS 9401 covers ‘Seats, whether or not convertible into beds and parts thereof’ (Tariff Item 9401 20 00 specifically covers seats of a kind used for motor vehicle). The Explanatory Note for this heading has also mentioned that seats for vehicles are covered under the ambit of HS 9401. Further, the Explanatory Notes to Chapter 94 have a list of exclusions that are not to be classified under the said Chapter. This list of exclusions does not mention seats meant for vehicles. Thus, it is seen that car seat would fall under HS 9401.
3.4 Thus, the seat assembly for 4 wheelers are classifiable under HS 9401 while seats for 2-wheelers are classifiable under HS 8714. There is no ambiguity in the GST rates on the said goods- car seats which are classifiable under 9401 attract GST @ 18 % vide S. No. 435A of Schedule III of notification No. 1/2017-Central Tax (Rate) dated 28th June, 2017 (as amended) and seats meant for two wheelers are classifiable under HS 8714 which attract a GSTrate of 28%.
3.5 In order to bring parity with seats of motorcycles (classified under HS 8714) which already attract a GST rate of 28%, based on the recommendation of the Council, with effect from 10.10.2024 vide S. No. 210A of Schedule IV of notification No. 1/2017-Central Tax (Rate) dated 28th June, 2017 (as amended), car seats classifiable under HS 9401 attract GST at the rate of 28%. It is clarified that the 28% rate on car seats classifiable under HS 9401 is applicable prospectively, that is, from the date of effect of the said notification.
4. Field formations under your charge may be instructed accordingly.
5. Difficulty, if any, in the implementation of this circular may be brought to the notice of the Board.
Yours faithfully,
(Limatula Yaden)
Joint Secretary (TRU)
Tel: 011-2309 2687
📘 Frequently Asked Questions (FAQs) on Circular No. 235/29/2024 - GST
Q1: What is Circular No. 235/29/2024 - GST about?
Answer:
Issued on October 11, 2024, by the CBIC, this circular clarifies GST rates and HS code classification of specific goods, including extruded savoury snacks, Roof Mounted Package Units (RMPUs) for railways, and seats for two-wheelers and four-wheelers. It is based on decisions taken in the 54th GST Council Meeting.
—
Q2: What is the GST rate on extruded or expanded savoury food items?
Answer:
🍟 From October 10, 2024, extruded or expanded savoury or salted products (excluding un-fried or un-cooked snack pellets) classified under HS 1905 90 30 are taxed at 12%.
⚠️ Previously, these items were taxed at 18%. The new 12% rate is prospective only.
—
Q3: What about GST on un-fried or un-cooked snack pellets?
Answer:
Such products continue to attract GST at 5%, provided they are manufactured through the extrusion process. No change has been made to this classification.
—
Q4: What is the classification and GST rate for Roof Mounted Package Unit (RMPU) ACs used in Indian Railways?
Answer:
🛤️ RMPU ACs are classified under HS 8415 and attract 28% GST.
They are excluded from classification under HS 8607 (parts of railway locomotives), which attracts 18%, based on Customs Tariff Act exclusions.
—
Q5: Why are RMPU ACs not classified under HS 8607 at 18% GST?
Answer:
The Customs Tariff Act clearly excludes goods under headings 8401 to 8479—including 8415—from being considered as “parts” of railways under Chapter 86. Therefore, these air-conditioning machines are taxed at 28%.
—
Q6: What is the GST classification and rate for motorcycle seats?
Answer:
🏍️ Seats for two-wheelers fall under HS 8714 and attract 28% GST as per Schedule IV, Entry No. 174 of Notification No. 1/2017–Central Tax (Rate), dated June 28, 2017 (as amended).
—
Q7: What about car seats?
Answer:
🚗 Car seats are classified under HS 9401, and until recently, attracted 18% GST.
Effective from October 10, 2024, they are now taxed at 28% to bring parity with motorcycle seats, as per Schedule IV, Entry 210A of Notification 1/2017.
—
Q8: Is the change in GST rate on car seats retrospective?
Answer:
📅 No. The 28% GST rate on car seats is applicable prospectively from October 10, 2024. Past transactions will remain taxed at 18%.
—
Q9: Why was this circular issued?
Answer:
📊 To resolve confusion in field formations over GST classifications and ensure consistent application of GST rates on:
✅ Packaged savoury foods
✅ Air conditioners for railways
✅ Car and bike seats
This circular ensures uniform implementation across states.
—
Q10: How can Finodha help manufacturers or distributors affected by these changes?
✅ Conclusion:
Circular No. 235/29/2024-GST ensures clarity on product classification and GST rates affecting F&B companies, Indian Railways suppliers, and auto-part manufacturers. Timely compliance will avoid disputes and penalties.
📢 Stay GST rate-compliant and classify your goods correctly with Finodha’s expert GST guidance. Need help with audits or disputes? Visit: https://www.finodha.in
Read more interesting articles:
by Shakshi Bharti | Jun 10, 2025 | GST, Circulars
Important Keywords: Circular No. 234/28/2024 - GST, GST on hostel service, CSR GST applicability, Indian Railways service GST, GST on community kitchens, Finodha GST help,
Words:3102; Read time: 16 minutes
Circular No. 234/28/2024-GST
F. No. CBIC-190354/149/2024-TO(TRU-II) - CBEC
Government of India
Ministry of Finance
Department of Revenue
(Tax Research Unit)
*****
North Block, New Delhi
Dated the 11th October 2024
Circular No. 234/28/2024 - GST: Clarifications regarding applicability of GST on certain services
To,
The Principal Chief Commissioners/ Chief Commissioners/ Principal Commissioners/
Commissioners of Central Tax (All)/ The Principal Director Generals/ Director
Generals (All)
Madam/Sir,
Subject: Clarifications regarding applicability of GST on certain services– reg.
Based on the recommendations of the GST Council in its 54th meeting held on 9th September 2024, at New Delhi, in exercise of the powers conferred under section 168(1) of the Central Goods and Services Tax Act, 2017, clarifications on the following issues are being issued through this Circular as under:
2. Applicability of GST on the service of affiliation provided by universities to colleges:
2.1 Representations have been received seeking clarification on the applicability of GST on the service of affiliation provided by universities to colleges.
2.2 The activity of affiliation is to monitor and ensure whether the institution possesses the required infrastructure in terms of space, technical prowess, financial liquidity, faculty strength, etc. and is thereby eligible for the privileges to conduct the course/program of study for the degree/title extended by the University to the students enrolled in such institutions. The affiliation services provided by the universities to colleges are not by way of services related to the admission of students to such colleges or the conduct of examinations by such colleges.
2.3 Thus, as recommended by the 54th GST Council, it is hereby clarified that the affiliation services provided by universities to their constituent colleges are not covered within the ambit of exemptions provided to educational institutions in the notification No. 12/2017-CT(R) dated 28.06.2017 and GST at the rate of 18% is applicable on the affiliation services provided by the universities.
3. Applicability of GST on the service of affiliation provided by Central and State educational boards or Councils, or other similar bodies, to schools:
3.1 Representations have been received to clarify the applicability of GST on the service of affiliation provided by the Central and State educational boards or councils, or other similar bodies, to schools and to regularize the payment of tax on such services for the past period.
3.2 The activity of affiliation carried out by educational boards or councils, or other similar bodies, is to monitor and ensure whether the schools possess the required infrastructure, finances, faculty strength etc. and are thereby eligible for the privileges to operate under the aegis of said boards or councils. The services of affiliation provided to schools by educational boards or councils, or other similar bodies, are not by way of services related to the admission of students to such schools or the conduct of examinations by such schools..
3.3 The matter was placed before the GST Council in its 54th meeting held on 09th September 2024, and the GST Council recommended to clarify that such services of affiliation, provided to schools by Central or State educational boards or councils, or other similar bodies, by whatever name called, are taxable.
At the same time, the GST Council recommended exempting the supply of affiliation services provided by Central and State educational boards or Councils, or other similar bodies, by whatever name called to government schools i.e. schools established, owned or controlled by the Central Government, State Government, Union Territory, local authority, Governmental authority or Government entity. The same has been exempted w.e.f. 10.10.2024 vide notification No. 08/2024-Central Tax (Rate) dated 08.10.2024.
3.4 In its 54th meeting, the GST Council further recommended regularizing the GST liability on such services provided to all schools for the period from 01.07.2017 to 17.06.2021, i.e., the date of issuance of Circular No. 151/07/2021-GST wherein accreditation services of boards are clarified to be taxable at the rate of 18%.
3.5 Therefore, as recommended by the GST Council, it is clarified that services of affiliation, provided to schools by Central or State educational boards or councils, or other similar bodies, by whatever name called, are taxable. Further, as recommended by the Council, the payment of GST on the services of affiliation provided by Central and State educational boards or Councils, or other similar bodies, to all schools is regularized on ‘as is where is’ basis for the period from 01.07.2017 to 17.06.2021.
4. Applicability of GST on the Directorate General of Civil Aviation (DGCA) approved flying training courses conducted by Flying Training Organizations approved by the DGCA:
4.1 Representations have been received regarding the applicability of GST on the DGCA-approved flying training courses conducted by Flying Training Organizations (FTOs) which are approved by the Directorate General of Civil Aviation (DGCA). The same has been examined.
4.2 Under GST Law, vide Sl. No. 66 of the notification No. 12/2017- Central Tax (Rate) dated 28.06.2017, services provided by educational institutions to its students, faculty and staff are exempt from levy of GST. In the above notification, “educational institution” has been defined to mean an institution providing services by way of education as a part of a curriculum for obtaining a qualification recognized by any law for the time being in force.
4.3 In exercise of the power vested by Section 5 of the Aircraft Act, 1934, the Central Government has made the Aircraft Rules, 1937, which, inter-alia, provide for ‘approved training’, i.e. training the curriculum of which has been approved by the DGCA, and ‘approved training organization’, i.e. a flying training organization which shall obtain the approval of DGCA before the students are enrolled to acquire flying experience.
The said rules further state that flying experience required for the issue of private pilot and commercial pilot licenses shall be acquired at the Flying Training Organization (FTO) approved/ recognized by the DGCA. The Civil Aviation Requirements (CAR) issued under the said rules also provide for a completion certificate to be issued by an approved FTO to each student who completes its approved course of training.
4.4 It is evident from the above that the DGCA not only approves FTOs but also flying training courses and mandates the requirement of course completion certificates to be issued to successful candidates in terms of the Aircraft Act, 1934 and the rules prescribed thereunder. Therefore, the approved flying training courses conducted by FTOs approved by DGCA, wherein the DGCA mandates the requirement of a completion certificate, are covered under Sl. No. 66 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017 and are hence, exempt.
5. Regularizing payment of GST on transport of passengers by helicopter:
5.1 54th GST Council has recommended that the GST rate on transportation of passengers, with or without accompanied baggage, by air, in a helicopter on seat share basis may be notified at 5%. Accordingly, notification No. 07/2024- Central Tax (Rate) dated 08.10.2024 effective from 10.10.2024 has been issued.
5.2 The Council further recommended to regularize payment of GST on transportation of passengers, with or without accompanied baggage, by air, in a helicopter on seat share basis on ‘as is where is’ basis.
5.3 In addition to above, the Council also recommended to clarify that charter of helicopter would continue to attract GST at the rate of 18%.
5.4 Thus, as recommended by the 54th GST Council, payment of GST on transportation of passengers, with or without accompanied baggage, by air, in a helicopter on seat share basis is hereby regularized on ‘as is where is’ basis for the period from 01.07.2017 to 09.10.2024.
5.5 Further, as recommended by the 54th GST Council, it is hereby clarified that transport of passengers by helicopter on other than seat share basis i.e., for charter operations will continue to attract GST at the rate of 18%.
6. Whether incidental/ ancillary services such as loading/ unloading, packing, unpacking, transshipment, temporary warehousing etc., provided in relation to transportation of goods by road is to be treated as part of Goods Transport Agency service, being composite supply, or these services are to be treated as separate independent supplies:
6.1 Representations have been received to clarify whether incidental/ ancillary services such as loading/ unloading, packing, unpacking, transshipment, temporary warehousing etc., provided in relation to transportation of goods by road is to be treated as part of Goods Transport Agency (GTA) service, being composite supply, or these services are to be treated as separate independent supplies.
6.2 It has been brought to notice that enforcement agencies are raising demands for such services holding them leviable to GST at the rate of 18% by interpreting last para of Question No. 6 of the FAQ issued by CBIC which states that “If such incidental services are provided as separate services and charged separately, whether in the same invoice or separate invoices, they shall be treated as separate supplies”, to mean that if a GTA shows packing charges, loading, unloading charges etc., separately in the invoice, the GTA becomes liable to pay GST at the rate of 18% on these services by treating them as cargo handling services.
6.3 After deliberations on the issue and based on recommendations of the 54th GST Council, it is hereby clarified that ancillary or incidental services provided by GTA in the course of transportation of goods by road, such as loading/unloading, packing/unpacking, transshipment, temporary warehousing etc. will be treated as composite supply of transport of goods. The method of invoicing used by GTAs will not generally alter the nature of the composite supply of service.
However, if such services are not provided in the course of transportation of goods and are invoiced separately, then these services will not be treated as composite supply of transport of goods.
7. Regularizing payment of GST on import of services by an establishment of a foreign airlines company from a related person or any of its establishment outside India, when made without consideration:
7.1 54th GST Council has recommended to exempt import of services by an establishment of a foreign airlines company from a related person or any of its establishment outside India, when made without consideration. Accordingly, notification No. 08/2024-Integarted Tax (Rate) dated 08.10.2024 effective from 10.10.2024 has been issued.
7.2 The Council further recommended to regularize payment of GST on import of services by an establishment of a foreign airlines company from a related person or any of its establishment outside India, when made without consideration for the past period on ‘as is where is’ basis.
7.3 Therefore, on recommendations of the 54th GST Council, the payment of GST on import of services by an establishment of a foreign airlines company from a related person or any of its establishment outside India, when made without consideration is hereby regularized for the period from 01.07.2017 to 09.10.2024 on ‘as is where is’ basis.
8. Applicability of GST on Preferential Location Charges (PLC) collected along with consideration for sale/ transfer of residential / commercial properties:
8.1 Allowing choice of location of apartment is integral part of supply of construction services and therefore, location charge is nothing but part of consideration charged for supply of construction services before issuance of completion certificate. Being charged along with supply of construction services for the apartment, the same attract GST at same rate as of construction services before issuance of completion certificate.
8.2 Therefore, based on the recommendations of the 54th GST Council, it is hereby clarified that location charges or Preferential Location Charges (PLC) paid along with the consideration for the construction services of residential /commercial/industrial complex forms part of composite supply where supply of construction services is the main service and
PLC is naturally bundled with it and are eligible for same tax treatment as the main supply of construction service.
9. Regularizing payment of GST on certain support services provided by an electricity transmission or distribution utility:
9.1 GST Council in its 54th meeting held on 09th September, 2024 has recommended to exempt supply of services by way of providing metering equipment on rent, testing for meters/ transformers/capacitors etc., releasing electricity connection, shifting of meters/service lines, issuing duplicate bills etc., which are incidental or ancillary to the supply of transmission and distribution of electricity provided by transmission and distribution utilities to their consumers.
9.2 The same have been exempted vide notification No. 08/2024- Central Tax (Rate) dated 08.10.2024 effective from 10.10.2024.
9.3 The GST Council in its 54th meeting has also recommended to regularize the payment of GST for supply of such services for the period i.e., from 01.07.2017 to 09.10.2024 on ‘as is where is’ basis.
9.4 Therefore, as recommended by the 54th GST Council, the payment of GST on services provided by an electricity transmission or distribution utility which are incidental or ancillary to the supply of transmission and distribution of electricity by such utility, such as those listed in para 9.1 above is hereby regularized on ‘as is where is’ basis from 01.07.2017 to
09.10.2024.
10. Regularizing payment of GST on services of film distributors or sub-distributors who act on a principal basis to acquire and distribute films:
10.1 Representations have been received to clarify regarding the GST liability for the period from 01.07.2017 to 01.10.2021 on transaction between distributors and exhibitors wherein the distributors grant the theatrical rights to the exhibition centers. Field formations have viewed that such transaction are classifiable under SAC 9996 and attracts GST at the rate of 18%. 10.2 Prior to 1st October 2021, GST at the rate of 18% was leviable on “Motion Picture, videotape and television programme distribution services” under Heading 9996 whereas 12% rate of GST was leviable on “temporary or permanent transfer or permitting the use or enjoyment of intellectual property right in respect of goods other than IT technology
software” under Heading 9973.
It was observed that both entries apparently covered services by way of licensing of rights to broadcast or show films. This issue was discussed in the 45th GST Council meeting held on 17.09.2021 wherein, the Council recommended to keep a uniform rate of 18% on both these entries with effect from 01.10.2021.
10.3 The GST Council in its 54th meeting held on 09th September 2024 has recommended to regularize the payment of GST on transaction between distributors and exhibitors wherein the distributors grant the theatrical rights to the exhibition centers on ‘as is where is’ basis
from 01.07.2017 to 30.09.2021.
10.4 Therefore, as recommended by the GST Council, the payment of GST on transaction between distributors and exhibitors wherein the distributors grant the theatrical rights to the exhibition centers is regularized for the period from 01.07.2017 to 30.09.2021 on ‘as is where is’ basis.
11. Difficulties, if any, in the implementation of this circular may be brought to the notice of the Board.
Yours faithfully,
(Sachin Jain)
Joint Secretary, TRU-II
📘 Frequently Asked Questions (FAQs) on Circular No. 234/28/2024-GST
Q1: What is Circular No. 234/28/2024-GST about?
Answer:
This circular, issued on 30th December 2024, provides GST clarifications on specific services such as hostel accommodation, Indian Railways services, community kitchens under government schemes, CSR services, and advertising on railway platforms.
Q2: Is GST applicable on hostel accommodation provided by trusts?
Answer:
🏠 No, if certain conditions are met. Hostel services offered by trusts to students (including working women) for up to ₹20,000/month per person are exempt under Entry No. 12 of Notification No. 12/2017 – Central Tax (Rate), dated 28.06.2017. This includes basic amenities like food, housekeeping, etc.
—
Q3: Are community kitchen services under government schemes taxable?
Answer:
🍽️ No. Community kitchen services provided under Central or State government schemes (like PM POSHAN, ICDS, etc.) are exempt from GST. This ensures food aid programs remain affordable and accessible.
—
Q4: Do Indian Railways need to pay GST for services provided to PSUs?
Answer:
🚆 Yes. Services like licensing, renting, or leasing provided by Indian Railways to PSUs such as IRCTC are taxable under GST as these services do not qualify for exemption under the government-to-government exemption entries.
Q5: Are services provided for Corporate Social Responsibility (CSR) taxable?
Answer:
💼 Yes. Services like skill training, environmental initiatives, and similar CSR activities attract GST even when rendered free or at cost, as CSR is considered a legal obligation under Companies Act, 2013.
—
Q6: Is GST applicable to advertising space on Indian Railways property?
Answer:
📢 Yes. Advertising rights (such as on station platforms, coaches, etc.) granted by Indian Railways are taxable. Entities purchasing such rights must pay GST as applicable under the standard rate.
—
Q7: Who benefits from the hostel GST exemption?
Answer:
🎓 The exemption benefits students, job-seekers, and working women housed in dormitories or hostels run by trusts or charitable institutions, provided the rent is under ₹20,000/month and basic facilities are included.
—
Q8: Does GST apply even if CSR services are free?
Answer:
✅ Yes. Even if CSR activities are done without a profit motive or consideration, GST is applicable because such activities fall under “supply” as per GST law. Voluntariness or charitable nature does not provide immunity from tax.
Q9: Where can I find GST exemptions applicable to my business?
Answer:
Visit Finodha’s GST Compliance portal → https://finodha.in/gst-compliance/
You’ll find clear support on what services are exempt and how to structure your invoices accordingly.
Q10: How can Finodha help with GST classification and exemptions?
✅ Conclusion:
Circular No. 234/28/2024-GST gives much-needed clarity on GST applicability for public and private sector services. Whether you’re in education, social welfare, or transport, proper classification ensures legal compliance and tax savings.
📢 For personalized GST exemption mapping or to validate your GST taxability under this circular, talk to a Finodha GST expert today → https://www.finodha.in
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by Shakshi Bharti | Jun 10, 2025 | GST, Instructions / Guidelines
Important Keywords: Instruction No. 05/2025 ‑ GST, GST audit record provision, Timely GST audit compliance, CBIC GST instruction audit, GST audit readiness Finodha,
Words:1076; Read time: 6 minutes
Instruction No. 05/2025-GST
F. No. CBIC-20015/2/2025-GST
Government of India
Ministry of Finance
Department of Revenue
Central Board of Indirect Taxes and Customs
GST Policy Wing
*****
Room No. 159-A,
North Block, New Delhi.
Dated 2nd May, 2025
Instruction No. 05/2025 - GST: Timely production of records/information for audit
To,
All the Principal Chief Commissioners / Chief Commissioners of the Central Tax
All the Principal Director Generals/Director Generals
Madam/Sir,
Subject: Timely production of records/information for audit -reg.
Kind attention is invited to the Comptroller and Auditor General of India, Audit Report 7 of 2024, Department of Revenue (Indirect Taxes–Goods and Services Tax), wherein the C&AG has pointed out the non-production/ partial production of records to the C&AG Audit teams for carrying out their statutory duties. The issue of non-production o records/information by the field formations to C&AG Audit teams has been raised by the office of C&AG in various Exit Conference meetings held with the Ministry on GST-related
matters.
2. Attention is also drawn to Article 149 of the Constitution of India, which empowers the C&AG to conduct audit of government accounts, public sector undertakings, and other entities funded or controlled by the Central or State governments. Therefore, it becomes sine qua non for the field formations to provide the records/ information available with them and/ or required to be maintained by the field formations.
3. In view of the above, you are requested to ensure that the officers under your jurisdiction are suitably sensitized/ instructed to expeditiously provide the records/ information available with them/ required to be maintained by them, to the C&AG audit
team, as and when required.
4. The jurisdictional officers may also be directed that in cases where the documents sought by the audit team are available with the taxpayer, a letter may be sent to the concerned taxpayer requesting that they provide the documents expeditiously. Necessary follow-ups may also be done, as and when required, so that the data requested by the C&AG Audit team
is provided as soon as possible.
5. This issues with the approval of the Chairman, CBIC.
Yours faithfully,
(Gaurav Singh)
Commissioner (GST)
📘 Frequently Asked Questions (FAQs) on Instruction No. 05/2025‑GST
Q1: What is Instruction No. 05/2025‑GST?
Answer:
This CBIC directive requires GST audit officers to request records or information in a single, reasoned manner with clear timelines, avoiding multiple piecemeal summons. Taxpayers must now provide complete documentation promptly, adhering to outlined schedules—typically within 30 days unless extended. Early planning and proper organisation are key to avoiding compliance issues.
Q2: Who does this instruction apply to?
Answer:
It applies to all CGST officers conducting GST audits, investigations, or scrutiny, including the DGGI. It also affects all registered taxpayers who may need to furnish documents—such as books of accounts, invoices, ITC records, and reconciliation reports—during an audit or inquiry.
Q3: Why was this instruction issued now?
Answer:
The CBIC aims to enhance taxpayer convenience while maintaining audit effectiveness. By enforcing clear, consolidated requests for records, taxpayers avoid repeated interruptions. It also ensures GST audits are faster, fairer, and more structured—helping both taxpayers and authorities operate efficiently. This builds on earlier guidelines to streamline summons and investigation procedures taxmann.comptrlibrary.comfintaxblog.com.
Q4: What if documents can’t be produced within the timeline?
Answer:
If taxpayers genuinely cannot meet the deadline, they must formally request an extension, stating reasons through the proper officer. Extensions are discretionary and should include acceptable supporting reasons such as system delays, logistics, or third-party dependencies. Communication and documentation are essential to avoid audit complications.
Q5: What happens if records are not produced on time?
nswer:
Failure to comply may lead to:
Escalation to a show cause notice under Section 73 / 74 of the CGST Act mohansekhar.in+2klickongstworld.com+2blog.saginfotech.com+2
Possible penalties or disallowance of Input Tax Credit (ITC)
Escalation to formal audit or investigation by DGGI or CGST audit wings
Prompt response mitigates compliance risk.
Q6: What should taxpayers keep ready for a GST audit?
Answer:
Ensure you maintain well-organized, digitized records, including:
Sales & purchase ledgers, invoices, debit/credit notes
GSTR‑1, GSTR‑3B, GSTR‑9 reconciliations & GSTR‑2A/2B
Reconciliation reports, bank statements
ITC input/output, payment challans, refund/credit notes
Additional helpful records: MIS reports, stock registers, TDS/TCS certificates, and third-party reconciliations.
Q7: How can Finodha help you comply with this instruction?
Answer:
Finodha offers comprehensive support:
📂 Document readiness audits & checklist creation
🗓️ Compliance dashboards with deadline alerts
📑 Records reconciliation support (ITC, returns, bank, GSTR-2A)
🧾 Audit representation—submission, review meetings
🖥️ GST return filing and ITR support
🏢 Business setup services (Private Ltd, OPC)
👉 Explore Finodha’s GST Compliance Services
Q8: Does this affect Virtual Audit or Hearings?
Answer:
Yes. The instruction also aligns with earlier CBIC orders mandating virtual hearings, clear timelines, and prior approvals—ensuring transparency and reducing disruption. Officers must state reasons and timelines even in virtual audits.
Q9: Are there other relevant CBIC instructions to consider?
Q10: How can businesses stay ahead of GST audits?
Answer:
✅ Maintain well-organized documentation
✅ Reconcile GSTR‑2A/2B regularly
✅ Use digital accounting tools and Finodha dashboards
✅ Respond promptly to any CBIC or DGGI notice
✅ Engage experts early to offer professional representation
✅ Final Summary
Instruction No. 05/2025‑GST fosters more efficient, transparent GST audits. By consolidating document requests and enforcing clear timelines, CBIC seeks to minimize hassle for taxpayers while preserving audit discipline. Businesses should invest in audit preparedness—enlisting experts like Finodha can ensure timely compliance, reduce audit risk, and streamline GST management.
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by Shakshi Bharti | Jun 9, 2025 | GST, Instructions / Guidelines
Important Keywords: Instruction No. 04/2025-GST, GST registration grievance redressal, CBIC registration appeal, GSTREG-01 complaint, GST officer complaint process, Finodha GST support,
Words: 1116; Read time: 6 minutes.
Instruction No. 04/2025-GST
F. No. CBIC- 20016/24/2025-GST
Government of India
Ministry of Finance
Department of Revenue
Central Board Indirect Taxes & Customs,
GST Policy Wing
*****
New Delhi, dated 2nd May, 2025
Instruction No. 04/2025 - GST: Grievance Redressal Mechanism for processing of application for GST registration
To,
All the Principal Chief Commissioners / Chief Commissioners of Central Tax
Madam/Sir,
Subject: Grievance Redressal Mechanism for processing of application for GST registration -reg.
Reference is invited to instruction No. 03/2025 dated 17.04.2025 issued by Central Board of Indirect Taxes and Customs (“Board”) for processing of GST registration application. Any applicant whose Application Reference Number (ARN) has been assigned to Central jurisdiction and who has a grievance in respect of any query raised in contravention of the said instructions, regarding grounds of rejection of application etc. may approach the jurisdictional Zonal Principal Chief Commissioner/Chief Commissioner.
In order to provide a quick and effective grievance redressal mechanism to applicants, the following instructions are being issued:
- Principal Chief Commissioner/Chief Commissioner of CGST Zones may publicize an email address on which the applicants can raise their grievances. Wide publicity may be given to this email id.
- The applicants may send grievances containing ARN details, jurisdiction details (Centre/State) and issue in brief on that email address.
- In case where grievance received pertains to State Jurisdiction, the office of Principal Chief Commissioner/Chief Commissioner shall forward the same to the concerned State jurisdiction and a copy endorsed to the GST Council Secretariat.
- Principal Chief Commissioner/Chief Commissioner may ensure timely resolution of grievances received by them and intimate the applicants regarding the same. In case where queries raised by the officer are found to be proper, the applicants may be suitably advised.
- Principal Chief Commissioner/Chief Commissioner may submit a monthly report on the status of grievance redressal to DGGST who would compile the same and put up for perusal of the Board.
3. Difficulties, if any, in implementation of these instructions may be brought to the notice of the Board.
Yours faithfully,
Gaurav Singh
Commissioner (GST)
Copy to:
- Principal Director General of Goods and Services Tax, 5th Floor, MTNL Building, Bhikaji Cama Place, Delhi, 110066 w.r.t. para 2 (v) above.
- Director General of Taxpayers Services, Central Revenue Building, Indraprastha Estate, New Delhi-110109 with a request to assist the Zones in giving publicity to the grievance redressal mechanism.
- The Additional Secretary, GST Council Secretariat, Jeevan Bharti Building, Tower 2, 5th Floor New Delhi, 110001 for circulating the same to all States/ Union Territories with a request to consider creating a similar grievance redressal mechanism at their end.
📘 Frequently Asked Questions (FAQs) on Instruction No. 04/2025-GST
Q1: What is Instruction No. 04/2025-GST?
Answer:
It is an official circular from CBIC dated 17 April 2025, which mandates that every GST Zone establish a Grievance Redressal Committee (GRC) to handle complaints related to the processing of GST registration applications filed via FORM GST REG-01.
—
Q2: Why was this grievance redressal mechanism introduced?
Answer:
The mechanism was introduced in response to growing complaints from taxpayers and trade bodies regarding arbitrary rejections, repeated clarifications, and harassment during the GST registration process despite valid documents being provided.
—
Q3: What kind of grievances can be raised?
Answer:
You can raise a grievance if:
🚫 Your GST registration was rejected despite valid documentation
📋 Repeated clarifications were asked on the same documents
🕒 There was undue delay or negligence by officers
📑 Discriminatory or inconsistent verification procedures were followed
—
Q4: Who will handle the complaints?
Answer:
Every GST Zone must constitute a Grievance Redressal Committee (GRC) comprising:
👤 Principal Commissioner/Commissioner
🔍 Deputy/Assistant Commissioner (Registration)
📢 An officer nominated by the Chief Commissioner
The GRC will review the grievance and suggest corrective action.
—
Q5: How can a taxpayer file a GST registration grievance?
Answer:
✅ Write an application/email to the jurisdictional GST office mentioning your ARN, GSTIN (if allotted), and issue details
✅ Attach all relevant documents, including rejection order, REG-03/REG-05, and screenshots if available
✅ Follow up as per local GRC process, which may also be made available online in future
Need help preparing your complaint? Finodha can assist: https://finodha.in/gst-compliance/
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Q6: Will the grievance redressal committee overturn registration decisions?
Answer:
No, the GRC is not a legal appellate body. However, it will:
📌 Review the issue
📋 Provide feedback and reports to the Chief Commissioner
⚖️ Recommend re-training, reassessment, or disciplinary steps if misuse of power is found
📨 Inform the applicant of the outcome and next steps
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Q7: Is this linked to Instruction No. 03/2025 - GST?
Answer:
Yes. While Instruction 03/2025-GST lays down the correct registration procedure, Instruction 04/2025-GST provides a support mechanism for cases where those procedures are not followed or where genuine applicants face harassment.
—
Q8: Will the grievance delay the registration further?
Answer:
🚫 No. Filing a grievance does not interfere with your application timeline.
✅ It helps escalate systemic failures and encourages better governance.
⚠️ If urgent business setup is at stake, a grievance might fast-track reconsideration.
Start your GST registration the right way → https://finodha.in/online-gst-registration/
—
Q9: Can Finodha represent a grievance on behalf of a client?
Answer:
Absolutely. Finodha assists with:
📨 Drafting grievance applications
📁 Submitting all documentary evidence
🧾 Interacting with the jurisdictional GST officer
💼 ROC & GST setup formalities: https://finodha.in/setup-business/
—
Q10: Where can I follow up on the status of my grievance?
Answer:
As of now, follow-ups can be made through:
📧 Email communication with the jurisdictional GST Commissionerate
📞 Contact with the office of the Zonal Chief Commissioner
Finodha also tracks such grievances for you with updates.
—
✅ Conclusion:
Instruction No. 04/2025-GST empowers applicants to challenge unfair rejections and delays in GST registration. By setting up local redressal committees, CBIC ensures transparency and accountability in GST administration.
📢 If your GST application is unfairly delayed or rejected — Finodha can help you file a grievance, reapply successfully, and secure your business future.
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by Shakshi Bharti | Jun 9, 2025 | GST, Instructions / Guidelines
Important Keywords: Instruction No. 03/2025-GST, GST registration procedure 2025, GST REG-01 documents, CBIC GST registration rules, FORM GST REG-03 REG-05, Finodha GST help,
Words: 3441; Read time: 18 minutes.
Instruction No. 03/2025 - GST
F. No. CBIC- 20016/24/2025-GST
Government of India
Ministry of Finance
Department of Revenue
Central Board Indirect Taxes & Customs,
GST Policy Wing
*****
New Delhi, dated 17th April, 2025
Instruction No. 03/2025 - GST: Instructions for processing of applications for GST registration
To,
All the Principal Chief Commissioners / Chief Commissioners
Madam/Sir,
Subject: Instructions for processing of applications for GST registration regarding.
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.
2. 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.
3. 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.
4. Guidelines for processing of application for registration were earlier issued vide instruction No. 03/2023-GST dated 14th June, 2023. However, as there have been a number of changes in the back office and due to increasing number of registration related complaints, a comprehensive instruction is being issued to take care of the latest developments and to provide
clarity to the officers for processing of registration application. Accordingly, in supersession of the aforesaid instruction, the following instructions are being issued.
5. An indicative list of documents has been prescribed in FORM GST REG-01, for submission along with the registration application. The officers handling registration applications should go through the documents list referred to above and should strictly adhere to the following instructions in respect of processing of registration application:
6. Documents to be sought from applicant while processing applications:
A. Documents in respect of Principal Place of Business (PPOB): An indicative list of documents is prescribed in FORM GST REG-01 for proof of Principal Place of Business.
(i) In case of owned premises, the applicant has to upload the document as listed in the above-mentioned list. The list includes latest Property Tax receipt or Municipal Khata copy or copy of Electricity Bill of the owner. In this regard, it is to be noted that any one of the documents mentioned in the said list or any similar document such as water bill or any other document prescribed under the State or the local laws which clearly establishes the ownership of the premises submitted by the applicant should suffice.
Any one document uploaded on the portal will be sufficient and no additional document should be requested from the applicant for proof of ownership of the premises of the applicant. While processing registration application, query should not be raised by the officer seeking original physical copy of these documents.
(iia) In cases where premises is rented, the applicant is required to upload the valid Rent/Lease agreement alongwith any one of the documents, mentioned in the indicative list of documents in FORM GST REG-01 to establish the ownership of the premise by the lessor. The list includes latest Property Tax receipt or Municipal Khata copy or copy of Electricity Bill.
However, it has been observed that additional documents of the lessor are being sought by the field formations such as his PAN card, Aadhar Card, photograph of the lessor in front of/or inside the property, etc. It is hereby advised that any one of the documents mentioned in the said list or similar documents such as water bill or any document prescribed under the State or the local laws which clearly establishes the ownership of the premises by the lessor should be sufficient proof of the principal place of business.
(iib) It is further advised that in case where Rent/Lease Agreement is not registered, then agreement along with any one of the documents mentioned in the above list and a copy of the identity proof of the lessor should be sufficient. In case where Rent/Lease Agreement is registered, agreement along with any one of the documents mentioned in the above list should suffice and no identity proof of the lessor should be sought.
However, in case the electricity or water connection is in the name of the applicant tenant, the document evidencing the same along with the rent agreement should be accepted as a valid proof and no additional documents pertaining to the lessor should be sought.
(iii) For premises not covered under (i) and (ii) above, such as where the ownership of premises is with spouse, relative etc., a consent letter in plain paper by the concerned owner of the premises along with a copy of the identity proof of the person granting consent along with any one of the documents as mentioned in list of documents appended to FORM GST REG-01 in support of ownership of the premises of the consenter should suffice.
The list includes latest Property Tax receipt or Municipal Khata copy or copy of Electricity Bill. Any one of these documents or similar documents such as water bill or any document prescribed under the State or the local laws which clearly establishes the ownership of the premises by the consenter should suffice and no additional documents from the applicant should be sought.
(iva) In respect of shared premises, where Rent/Lease agreement is available, the applicant may upload copy of the agreement along with any one of the documents in the said list relating to the ownership of the premises which includes latest Property Tax receipt or Municipal Khata copy or copy of Electricity Bill.
In cases where Rent/Lease Agreement is not registered, then agreement along with any one of the documents mentioned in the above list and a copy of the identity proof of the lessor should be sufficient. In case where Rent/Lease Agreement is registered, agreement along with any one of the documents mentioned in the above list should suffice and no identity proof of the lessor should be sought.
(ivb) In cases where Rent/Lease agreement is not available, the applicant may upload a consent letter in plain paper from the consenter along with his identity proof of the consenter and any of the said documents in support of ownership
of the premises of the consenter. In such cases, any one of the documents mentioned in the said list or similar document prescribed under the State or the local laws which clearly establishes the ownership of the premises by the consenter should suffice and no additional document should be sought from the applicant for proof of ownership of the premises by the consenter.
(v) In case of rented/leased premises, where rent or lease agreement is not available, an affidavit to that effect along with any document prescribed in the FORM GST REG-01 in support of the possession of the premises of the applicant such as copy of Electricity Bill in the name of the applicant should suffice. It may be noted that in such cases, the said affidavit is to be executed on non-judicial stamp paper of minimum value in the presence of First-Class Judicial Magistrate or Executive Magistrate or Notary Public.
(vi) If the principal place of business is located in the Special Economic Zone or the applicant is a Special Economic Zone developer, necessary documents/certificates issued by the Government of India are required to be uploaded.
B. Issues in respect of Constitution of Business:
(i) In respect of constitution of business, where the applicant is one of the partners, Partnership Deed for the proof of constit to be upload certificate, MSME certificate, shop establishment certificate, trade license etc. should be sought from the applicant.
(ii) In cases, where the applicant is Society, Trust, Club, Government Department, Association of Persons or Body of Individuals, Local Authority, Statutory Body and Others etc., Registration Certificate/Proof of Constitution is
required to be uploaded by the applicant.
7. 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.
8. Processing of registration application:
(i) As mentioned above, FORM GST REG-01 prescribes a list of documents to be uploaded by the applicant in respect of photograph, constitution of business, principal place of business, bank account, etc. The proper officer shall carefully scrutinize the said documents to ensure that the documents are legible, complete and relevant. Further, the details or information furnished by the applicant in the application should also be carefully examined by the proper officer to check completeness of the same, to correlate and cross-verify the same with the uploaded documents and to check the authenticity of the applicant.
The details of the address of principal and additional places of business and the corresponding documents uploaded with the application as proof of address may be closely scrutinized to verify completeness and correctness of
address of such places of business. Further, to the extent possible, the authenticity of the documents furnished as proof of address may be cross-verified from the publicly available sources, such as websites of the concerned authorities such as land registry, electricity distribution companies, municipalities, and local bodies, etc.
(ii) Where applications have not been flagged as risky on the common portal based on data analysis and risk parameters, and the same are found to be complete and without any deficiency, the officers should approve the application within 07 working days of submission of application.
(iii) Where applications fall under the following conditions, the registration shall be granted within thirty days of submission of application after physical verification of the place of business:
a. The applicant has undergone authentication of Aadhaar number and is flagged as risky on the common portal based on the data analysis and risk parameters, or
b. The applicant fails to undergo authentication of Aadhar number, or does not opt for Aadhar authentication, or
c. The officer deems it fit to carry out physical verification of place of business, with the approval of the officer not below the rank of Assistant Commissioner.
(iv) In cases mentioned above, where physical verification is to be carried out, the proper officer shall immediately initiate the process for physical verification of the place of business in accordance with provisions of rule 9 of CGST Rules read with rule
25 thereof. In this regard, the concerned officer must ensure that the physical verification report along with the other documents, including photographs, is uploaded on the system in FORM GST REG-30 at least 05 days prior to the expiry of the time period 30 days from the date of submission of application. The officer carrying out physical verification shall ensure the following:
a. Give a specific report regarding existence/non-existence of principal place of business declared by the applicant.
b. In case entity is found non-existing, efforts made in respect of locating the said premises, need to be recorded in the physical verification report.
c. Upload on the portal, GPS enabled site photograph and other documents, if any, during physical verification visit.
d. In case the ARN assigned for physical verification belongs to a different jurisdiction, the same should immediately be reassigned by the concerned officer to its correct jurisdiction through the portal.
(v) The proper officer may seek clarification or information or document(s) in FORM GST REG-03 in the following cases:
a. Where any document is incomplete or not legible, the proper officer may seek complete or legible copy of the same.
b. Where the address of place of business does not match with the document uploaded by the applicant, or where such uploaded document does not appear to be a valid proof of the address of the said place of business, the proper officer may seek additional documents as mentioned in para 6 above to confirm the address details.
c. Where the address of place of business is incomplete or vague, the proper officer may seek complete and unambiguous details of the address along with the corresponding documentary proof.
d. Where any GSTIN linked to the PAN of the applicant is found cancelled or suspended, the proper officer may seek clarification or reasons for the same from the applicant, if required.
(vi) The proper officer shall issue a notice to the applicant electronically in FORM GST REG-03 only on the basis of above mentioned grounds, within 07 working days from the date of submission of application in cases where the applications have not been flagged as risky as mentioned in para 8(ii) above or within 30 days from the date of submission of application in cases where the applications have been flagged as risky as mentioned in para 8(v) above.
However, while processing the applications for registration, if any document apart from the listed documents is required to be sought, the officer shall seek the same only after the approval of the concerned Deputy/Assistant Commissioner. It must be ensured that no application for grant of registration is approved on deemed basis for want of timely action on the part of tax officers.
The officer shall also ensure that no documents in addition to those as mentioned above and no clarification/ information/documents on the basis of presumptive grounds shall be sought from the applicant. Further, the officer shall also ensure that queries are not raised for minor deficiencies which are not relevant for establishing Proof of Place of Business or Constitution of Business etc.
(vii) The applicant is required to furnish reply in FORM GST REG-04 within 07 working days from the date of receipt of notice issued in FORM GST REG-03. The proper officer shall carefully examine the clarification, information or documents furnished by the applicant in FORM GST REG-04. Where the proper officer is satisfied with the reply furnished by the applicant in FORM GST REG-04, he shall approve the application for registration within 07 working days from the date of receipt of such reply.
However, where the proper officer is not satisfied with the clarification, information or documents furnished by the applicant the may, for reasons to be recorded in writing, reject such application and inform the applicant electronically in FORM GST REG-05 within 07 working days from the date of receipt of reply.
(viii) In cases where no reply to the notice is furnished by the applicant within 07 working days from the date of issuance of notice in FORM GST REG-03, the officer may, for reasons to be recorded in writing, reject such application and inform the applicant electronically in FORM GST REG-05 within 07 working days from the date of expiry of time limit of filing reply.
10. Principal Chief Commissioners/ Chief Commissioners are hereby advised to:
i. Closely supervise the status of processing of the applications of registration, including physical verifications, nature of queries being raised, deemed registrations etc. through periodic review within their Zones;
ii. Strict action may be taken against the officer deviating from these instructions;
iii. Post sufficient staff for handling registration applications to ensure timely disposal of registration applications;
iv. Issue trade notices to address unique local systems to provide for acceptable documentary evidence to be submitted with the application.
Difficulties, if any, in implementation of these instructions may be informed to the Board on the email id gst-cbec@gov.in.
Your faithfully,
Shrun khala Kangale
Deputy Secretary
Government of India
Copy to:
1. Principal Director General, Goods and Services Tax, 5th Floor, MTNL Building, Bhikaji
Cama Place, Delhi, 110066
2.The Joint Secretary, GST Council Secretariat, Jeevan Bharti Building, Tower 2, 5th Floor
New Delhi, 110001 for circulating the same to all States/ UTs for information and necessary
action at their end.
📘 Frequently Asked Questions (FAQs) on Instruction No. 03/2025-GST
Q1: What is Instruction No. 03/2025-GST all about?
Answer:
This CBIC instruction provides detailed guidance to GST officers on handling new GST registration applications. It emphasizes standardized procedures, avoids unwarranted queries, and balances fraud prevention with taxpayer convenience. It supersedes the earlier Instruction No. 03/2023-GST.
—
Q2: Why was this instruction issued?
Answer:
Due to complaints from applicants about unnecessary document requests and delays. It also addresses inconsistencies across jurisdictions and aims to prevent harassment of genuine businesses while still checking fraudulent GST registrations.
—
Q3: What are the acceptable documents for the Principal Place of Business?
Answer:
🧾 Acceptable documents include:
• Electricity bill
• Property tax receipt
• Water bill
• Municipal Khata copy
📌 For rented premises: valid rent agreement + one ownership proof of the lessor
📌 Consent letters are allowed in special cases (e.g., family-owned property)
No officer should ask for Aadhaar, PAN, or photographs of the lessor if already sufficient documents are provided.
—
Q4: What is the processing timeline for registration?
Answer:
⏳ If application is not risky:
✔ 7 working days from date of application
⏳ If flagged as risky or Aadhaar authentication skipped:
✔ Within 30 days, with mandatory physical verification.
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Q5: What documents should not be asked from applicants?
Answer:
🚫 Officers must not ask for:
• PAN/Aadhaar of lessor
• Photos of person in the property
• MSME, Udyam, Trade license if not required
• Proof of MD’s address matching place of registration
• HSN product-based bans (unless legally applicable)
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Q6: What are the responsibilities of GST officers in processing applications?
Answer:
✅ Validate document legibility
✅ Cross-check documents using public portals
✅ Upload physical verification reports with GPS photos if applicable
✅ Raise queries only on genuine documentary discrepancies
✅ Approve valid applications on time—no deemed approvals from inaction
—
Q7: What is the process if clarification is sought by the officer?
Answer:
📨 Officer issues FORM GST REG-03
📄 Applicant must reply in FORM GST REG-04 within 7 working days
✅ If reply is satisfactory, officer approves within 7 days
❌ If not, application is rejected with reasoned order in FORM GST REG-05
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Q8: How does this help genuine businesses and startups?
Answer:
This simplifies the registration process for honest taxpayers by:
✔ Reducing document burden
✔ Curbing arbitrary delays
✔ Preventing harassment from unwarranted queries
✔ Establishing a uniform procedure nationwide
Set up your GST-registered business today: https://finodha.in/setup-business/
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Q9: What are the key responsibilities of GST Zones as per this instruction?
Answer:
📌 Closely monitor registration trends
📌 Review delays or deviations by officers
📌 Reassign staff if necessary
📌 Issue trade notices for local document rules
—
Q10: How can Finodha help with GST registration?
✅ Conclusion:
Instruction No. 03/2025-GST streamlines GST registration with clear timelines, document rules, and enforcement safeguards. Applicants should comply smartly—while officers are held accountable for timely and lawful actions.
💡 For effortless GST registration and expert handling of FORM REG-01 to REG-05, trust Finodha.
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