How to register for GST under CBIC's new guidelines: A step-by-step guide

“These FAQs are intended to minimise ambiguities and facilitate smooth compliance by taxpayers,” the circular said.

What has not changed is the route for GST registration.

“The process of registration in GST is totally online and faceless, without need for physical interface, except in respect of the process of physical verification of the premises,” CBIC said. It added that “all the communications with the applicant related to registration process ... has to be made through the common portal only.

Here is how the GST registration process runs as per the circular, step-by-step.

Step 1: Check whether you need to register, and in which form

Registration is triggered either by turnover or by category. The threshold is ₹40 lakh for suppliers dealing exclusively in goods, and ₹20 lakh for suppliers of services or of both goods and services. In the special category States, the limits are ₹20 lakh and ₹10 lakh respectively.

Registration is compulsory regardless of turnover for persons making inter-State taxable supplies, casual taxable persons, those paying tax under reverse charge, non-resident taxable persons, TDS deductors, input service distributors, agents supplying on behalf of others, e-commerce operators liable to collect tax at source and their suppliers, and Online Information and Database Access or Retrieval (OIDAR) services suppliers located outside India.

The GST form follows the taxpayer type. For instance,

• FORM GST REG-01 is for a normal taxpayer, input service distributor or casual taxable person

• FORM GST REG-07 is for a deductor or collector of tax at source

• FORM GST REG-09 for a non-resident taxable person

• FORM GST REG-10 for OIDAR and online money gaming suppliers from abroad

• FORM GST REG-13 for a unique ID for UN bodies and embassies (para 3.1.1, page 2; Q5, page 17).

Step 2: Fill Part A to generate the TRN

Please note that the GST Portal also provides a detailed manual for step-by-step guidance of the applicants for filing the registration application

As per the circular, the legal name should be the same as mentioned in PAN issued by Income Tax Department, and that mentioned in Incorporation Certificate issued by Ministry of Corporate Affairs in case of incorporated companies. For a proprietorship, the name of the proprietor should be mentioned against the Legal Name. The State and district of the principal place of business must be correct, and where the e-mail and mobile number are linked to the PAN, the same should be given. A successful submission leads to an acknowledgement of registration application in FORM GST REG-02.

Step 3: Complete Part B - constitution, reason and options

Part B requires key details capturing essential fields like business constitution, reason for registration, existing registration details, nature of premises and activity, promoters, bank particulars, principal place of business, state-specific information, HSN or SAC classification and authorised signatory details.

The constitution must be selected correctly and supported by documents such as the partnership deed for a firm, the registration certificate or proof of constitution for a society, trust, club or association, and the Karta document for an HUF.

The reason chosen from the drop-down is an important detail which should describe why you are seeking GST registration and it is required to be aligned with the Constitution of Business and other details provided in the application.

Applicants who want the composition scheme, casual taxable person status or simplified registration must positively tick “Yes” against the relevant field, and SEZ units or developers must quote the approval order number, its date and validity.

Step 4: Fill in the people - promoters, photographs, signatories

Details of the proprietor, all partners of a firm or LLP, the Karta of an HUF, the managing director and all whole-time directors of a company, and all members of the managing committee or board of trustees are required. A Director Identification Number is mandatory for company directors and designated partners of LLPs, validated through the MCA.

Each such person must upload a recent colour photograph showing the full front face, which should not be a copy of any identity document, such as PAN, Adhaar Number, Driving License, Passport.

CBIC cautions that “uploading of wrong photograph may lead to either a query being raised by the tax officer, or the rejection of the registration application”. Up to 10 authorised signatories may be named, each needing a photograph and an authorisation letter from the proprietor, partners, board or trust, and the Board advises naming at least two, “a primary and an alternate”, in case one is unavailable for e-sign or Aadhaar verification.

The primary signatory must sign the application digitally. Where a tax practitioner is named as authorised representative, his enrolment ID under Section 48 is to be given.

Step 5: Describe the principal place of business precisely

Wrong or vague premises details are “one of the major reasons for either rejection of the application for registration, or raising of queries”, the circular said.

Therefore, the address must run down to the building, flat, shop or plot number, with khasra or khata number where applicable, road, locality, village or town, taluka, district, PIN code and a nearby landmark, and as far as possible, latitude and longitude of the PPoB may also be provided by dragging the marker on the portal’s map.

An address that stops at the road or colony level may result in issuance of queries by the tax officers or negative report in physical verification report.

The applicant must also pick the correct State and Centre jurisdiction from the drop-down menu shown on the portal as per the PIN Code details. One should also specify the nature of business from the portal menu.

Additional places of business in the same State may be declared. However, telecom towers and bank ATMs “which are unmanned installations are not required to be declared”.

In Maharashtra, Rajasthan, Odisha, Andhra Pradesh, Assam and Madhya Pradesh, the electricity consumer number and board details for the premises are mandatory.

Step 6: Attach the right proof of premises

Ownership, consent, tenancy and co-working arrangements each require different papers. For owned premises, any one of a latest property tax receipt, municipal khata, property identification document, latest electricity bill or latest water bill in the applicant’s name will do, with the address matching the application.

Where the premises belongs to a deceased ancestor, an affidavit in the Annexure-IV format, the death certificate and one such document are needed.

A registered rent or lease agreement suffices where State law mandates registration; otherwise the agreement plus one ownership document in the landlord’s name is required. And where no agreement exists at all, an undertaking in Annexure-V with a utility bill in the tenant’s name is accepted.

Premises used on consent (a parent’s or spouse’s property, for instance) need a consent letter in the Annexure-VI format on plain paper, with the owner’s document and, where the property is co-owned, the consent of every co-owner.

Co-working users must upload the membership agreement identifying the desk, cabin or suite allotted, plus proof that the provider owns or validly leases the premises.

Documents must be “clear, complete and fully legible”. You cannot give a post office box as address as GST registration requires a verifiable physical address. Also, photographs of the premises cannot be given as a substitute.

Step 7: List your goods or services, and your bank account

Applicants should describe all goods and services they supply or intend to supply, using specific descriptions, and at least the most prominent ones if the list is long. These can be amended later through FORM GST REG-14.

Bank details are not compulsory at the time of filing, but rule 10A requires them to be furnished “within a period of 30 days from the date of grant of registration, or before furnishing of details of outward supplies in FORM GSTR-1 ... whichever is earlier”, in the applicant’s own name and on his PAN, with a cancelled cheque, passbook or statement uploaded as proof.

Details of up to 10 accounts may be given.

Step 8: Authenticate Aadhaar and wait out the clock

This is the step that decides the timeline. Where the applicant opts for Aadhaar authentication and clears it, the application is required to be processed by the proper officer within a period of seven working days. Where he does not, or where the system flags the application on risk parameters for physical verification, the outer limit is 30 days. Some applicants may be then called for biometric authentication, a photograph and verification of original documents at a Facilitation Centre. This step must be completed within 15 days of the TRN reaching the registered mobile number and e-mail, failing which the application will not be processed further.

Small businesses passing on input tax credit of no more than ₹2.5 lakh a month to registered buyers can instead opt for simplified registration under Rule 14A, where registration is granted automatically by the system within 3 working days, subject to Aadhaar authentication and a single such registration per State on a PAN.

Step 9: If a query or rejection comes, respond within seven days

A notice in FORM GST REG-03 can be issued within seven working days from the date of submission of application only:

• where a document is incomplete or illegible

• where the address does not match the uploaded proof, or

• where the address is vague

The reply goes in FORM GST REG-04 within seven working days, and the officer must decide within seven working days of receiving it, failing which he may reject the application in FORM GST REG-05 for reasons to be recorded in writing.

If the officer takes no action at all, “the registration shall be deemed to have been approved”, and the certificate in FORM GST REG-06 appears on the portal automatically.

A rejected applicant may apply afresh after correcting the deficiencies set out in the order. Anyone facing delay or an unwarranted query can complain to the jurisdictional Chief Commissioner of Central Tax or Commissioner of State Tax on the special e-mail identified for the purpose.

Officers processing these applications have been told to stay within the prescribed document list and to refrain from personal or subjective assessments, such as classifying electricity connections as domestic or commercial, scrutinizing bill amounts, or deeming residential premises unfit for business.