All About Form GST REG 03 with Issuance Reason & Time Limit

The GST registration system is another big part of ensuring compliance and transparency under all the processes of Goods and Services Tax (GST). Among the processes, the use of Form GST REG-03 is an important step in the scrutiny or verification during GST registration.

After the filing of an application for GST registration through Form GST Reg-01, the appropriate officer of the GST examines and scrutinizes the said application.

Whenever this proper officer requires any further clarifications or information, he sends a Form GST Reg-03 to the applicant. Knowing the purpose, issuance timeline, and how to respond to Form GST REG-03 is vital for businesses to avoid delays or rejection of their GST registration application.

This blog teaches you about the various introductory provisions related to form GST Reg-03. 

Reason for the Issuance of Form GST REG 03

Any person liable to acquire GST registration upon commencement of business should file a formal application by drawing GST Reg-01 online. 

Once the form is submitted, a Proper officer checks it. If the information provided seems valid to the officer, they will approve it immediately. 

On the other hand, if the details submitted are found to be incomplete or inaccurate, the Proper officer has the power to issue a notice through form GST Reg-03. This notification is generated through the system. 

Generally, a Proper officer will issue a form GST Reg-03 if they face the following problems:

• Incomplete or Inadequate Documentation: Applicants often fail to submit essential documents like proof of principal place of business (e.g., electricity bills or property papers), valid PAN, accurate bank account details, or an authorized signatory letter. In such cases, the officer raises a REG-03 notice requesting the missing or corrected documents.
• Mismatch in Provided Information: Discrepancies in PAN details, address, ownership structure, or business constitution can trigger a REG-03. Since the GST system cross-verifies data with PAN and Aadhaar databases, any mismatch requires clarification.
• Suspected Fraudulent Registration: If the officer suspects a bogus registration aimed at tax evasion or input tax credit fraud, they may demand proof of genuine business operations. This includes financial statements, business premises proof, and details of directors or partners.
• Unclear Business Activities: When business activity details in the application are vague or insufficient, the officer may seek a clearer description to determine the necessity of registration.
• Voluntary Registration Without Threshold: If a business applies voluntarily without meeting the turnover threshold, the officer may request justification, such as engagement in inter-state trade or e-commerce.
• Technical Mistakes or Omissions: Typographical errors, wrong document uploads, or missing Aadhaar authentication can also result in the issuance of REG-03.

Time Limit of Issuance of Form GST REG-03

As per the Central Goods and Service Tax Rule 9(2) of the CGST Act of 2017, a proper officer must address any issues via form GST Reg-03 upon verifying the registration form submitted by an applicant within three working days of its filing.

Certain provisions of the rule were introduced into Rule 9(2) through Notification No. 62/2020-Central Tax, dated August 20, 2020. According to this notification, an executive officer can generate a GST Reg-03 within 21 days from the date of application submission when:

• The applicant fails to complete Aadhaar verification while filing their registration application.
• Or, while filing the GST registration form, the applicant does not opt for Aadhaar authentication.

Time Limit of Issuance of a Notice in GST REG-03 Form

You can go through the table below to get an idea of the estimated time frames the proper officer requires to issue form GST REG-03.

Action Post Receipt of Form GST REG-03

Receiving Form GST REG-03 may seem like a hurdle, but it is a common and manageable part of the GST provisional registration process. To handle it effectively, read the notice for rejection carefully to understand what clarifications or documents the officer has requested. The notice usually outlines the exact issues and the required information or documents.

Next, gather and prepare the necessary supporting documents. For instance, provide updated utility bills for address proof, a cancelled cheque for bank verification, or a detailed write-up to clarify business activities.

Respond to the notice by submitting Form GST REG-04 online through the GST portal. Make sure your documents are clearly scanned, in PDF format, and within the 100MB upload limit. Submitting this response within seven working days of receiving REG-03 is crucial.

After submission, monitor your application status on the GST portal and be prepared to provide further information if requested. If your response is satisfactory, the officer will approve the registration by issuing Form GST REG-06.

Avoid ignoring the notice, submitting incorrect documents, or waiting until the last minute. Timely, accurate, and complete action is the key to avoiding rejection of application for registration and ensuring smooth processing.

Conclusion

Making mistakes while submitting a GST registration application is not very uncommon. Some may mistakenly provide incorrect jurisdictional inputs, while others may try to register with a PAN that has already been revoked. Thus, errors are bound to happen as the whole registration process involves a lot of human intervention. In these cases, the competent authority will issue a form GST Reg-03 directly addressing the applicant. 

So, if you encounter any of the issues mentioned here, consider following the instructions to complete your business registration successfully under GST law.

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