“Upload Site with Sign Board and Adjacent Shop”: GST Applicant Condemns Dept’s Photo Demand for Business Proof

The GST (Goods and Services Tax) applicant has strongly condemned the GST notice (Form GST REG-03) seeking additional documents or clarifications related to the registration of the business.

The GST applicant received the notice from the GST department seeking additional documents with regards to the application on 1st July 2025, where he was directed to submit the reply by 10th July 2025.

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The officer has directed to upload “the photographs of the proposed site along-with the inner & outside (covering complete area of office & godown (if any) of the site along-with signboard of the firm & adjacent shops of the site”. This is found to be excessive.

As per the CBIC Instruction dated 17th April 2025, the Board has clearly directed field officers not to seek excessive or unwarranted documentation from GST applicants. The Instruction provides a comprehensive list of acceptable documents under various scenarios, and notably, there is no requirement for uploading photographs showing the firm’s signboard or adjacent shops. Such verification, if necessary, is expected to be carried out by the officer during physical verification of the premises prior to registration approval.

CLARIFICATIONS/ ADDITIONAL DOCUMENTS SOUGHT IN FORM GST REG -03

In the notice, after stating that the department was not satisfied with the application, it sought the following clarifications:

“1. Principal Place of Business - Address - Others (Please specify) - Upload the photographs of the proposed site along-with the inner & outside (covering complete area of office & godown (if any) of the site along-with signboard of the firm & adjacent shops of the site.

Declaration stating that at the time of applying for registration under GST Act no other firm/company/office, etc is functioning at the same Principal Place of Business.

2. Principal Place of Business - Nature of Possession - Others (Please specify) - You are advised to upload the proof of ownership of the principal place of business i.e. latest property tax recipient, municipal khata copy, copy of registry or allotment letter. NOC if shared property.

If GPA is executed then provided registered GPA along with declaration on stamp paper duly notarized that original allottee is still alive as GPA become invalid in the eyes of law after death of original allottee. Submit identity proof of owner.

3. Principal Place of Business - Nature of Business Activity - Nature of Business Activity - Submit the NOC from the Estate office/Chandigarh Housing Board/Competent Authority for conducting commercial business at a residential address.

4. Principal Place of Business - Document Upload - Others (Please specify) - The Sr. No. is not mentioned in the notarized document.

Witness signatures & details i.e. complete name, adhaar number, address of witnesses not appended on rent agreement.

5. Goods and Services - Details of Services - Details of Services - Submit affidavit that in-case grant of GST registration, no amendment shall be done for converting supply of services to supply of goods/trading of goods etc and if any changes in services to supply of goods, I will inform the Department physically as well as change the non-core fields.”

GST APPLICANT’S RESPONSE

The GST applicant said that “This notice has been received on 01 July 2025 after applying for registration, even after Instruction No. 03/2025-GST issued by CBIC dated 17/04/2025, your officers are harassing small businessmen. Take actions.”

The applicant strongly condemned the demand, terming it as harassment of small businesses. He pointed out that the CBIC, in its Instruction No. 03/2025-GST dated 17th April 2025, issued detailed guidelines on physical verification of business premises, mandating photographs of the inside or outside of the premises, signboards, or adjacent shops.

CBIC INSTRUCTION - IMPORTANT CONTENTS

Situations where Proper Officer can Seek Clarification in Form GST REG -03

The proper officer may seek clarification or information or document(s) in FORM GST REG-03 in the following cases:

• Where any document is incomplete or not legible, the proper officer may seek complete or legible copy of the same.
• 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.
• 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.
• 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.

Para 6 of Instruction on Documents

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.

1. Owned Premises

● Upload any one of the following:

○ Latest Property Tax Receipt

○ Municipal Khata Copy

○ Electricity Bill

○ Similar documents such as Water Bill or any other local/state-authorized proof of ownership

No additional documents or physical originals should be requested.

2. Rented/Leased Premises

● Upload:

○ Valid Rent/Lease Agreement

○ Any one ownership document of the lessor (from above list)

No need to seek lessor’s PAN, Aadhaar, or photograph.

Premises Owned by Spouse/Relative (Consent-Based Use)

● Upload:

○ Consent Letter (on plain paper)

○ Identity Proof of consenter

○ Any one ownership document (as listed above)

4. Shared Premises

a) With Rent/Lease Agreement (Registered or Not)

● Upload:

○ Rent/Lease Agreement

○ Any one ownership document

○ If unregistered, also attach identity proof of the lessor

○ If registered, identity proof not required

b) Without Rent/Lease Agreement

● Upload:

○ Consent Letter (plain paper)

○ Identity Proof of consenter

○ Any one ownership document of consenter

5. Rented/Leased Premises without Agreement

● Upload:

○ Affidavit (on non-judicial stamp paper, notarized or before Magistrate)

○ Electricity Bill in name of applicant or other possession document

6. SEZ Units / SEZ Developers

● Upload:

○ Relevant Government-issued SEZ documents/certificates

The board has clearly said that in the cases of rented premises, “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.

The imposition of excessive and unwarranted requirements by GST proper officers during the registration process amounts to harassment of genuine businessmen. Far from facilitating ease of doing business, such practices create unnecessary hurdles and discourage compliance among applicants seeking registration

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