GST Registration Rejected After a Field Visit? A Step-by-Step Guide to Getting Approved
Overview : You have successfully incorporated your company, prepared your business plan, and meticulously filed your application for a Goods and Services Tax Identification Number (GSTIN). You are ready for business, but then an official email arrives: “Order of Rejection of Application for Registration” in Form GST REG-05. This is a frustrating setback, but it’s a common and often fixable issue, mainly when the rejection stems from the physical verification or “field visit” conducted by a GST officer under Rule 25 of the Central Goods and Services Tax (CGST) Rules, 2017. This comprehensive guide will help you understand the officer’s concerns, rectify the common issues, and navigate the following steps to get your GST registration approved.
Why Does GST Registration Get Rejected After a Field Visit? π
The primary purpose of a field visit is to verify the genuineness of your business and the accuracy of the details provided in your application. As per Rule 25 of the CGST Rules, 2017 (as amended by Notification No. 38/2023-CT dated 04.08.2023), a proper officer can conduct physical verification of the ‘principal place of business’ in two scenarios:
| Verification Timing | Legal Provision | Documentation Required |
|---|---|---|
| Before Registration (Post Aadhaar Non-Authentication) | Rule 9(1) Proviso read with Rule 25 | Form GST REG-30 uploaded within 15 working days of verification |
| After Registration (Reason to believe) | Rule 25(1) | Form GST REG-30 uploaded within 15 working days of verification |
The verification report, along with other documents, including photographs, must be uploaded in Form GST REG-30 on the common portal within fifteen working days following the date of verification. If the officer finds discrepancies during this visit, it can lead to a notice and subsequent rejection. Understanding the reasons behind the rejection is the first step toward resolving it effectively.
Case Study: Decoding a Real Rejection Notice π
A typical rejection order might state: “During a field visit, the directors were not available. It was also found that another firm with a different GSTIN is already operating from the same address and door number. No documents were available at the premises for verification. Hence, the application is rejected.” This notice highlights three critical problems that require immediate attention.
Problem #1: “The directors were not available during the visit”
The presence of the applicant or an authorised representative is crucial during the field visit. As per Rule 25, the verification of the place of business must be done in the presence of the said person. An empty office or the absence of key personnel raises doubts about the legitimacy of the company. The officer needs to verify the identity of the promoters and confirm that the address is not just a “paper address” used for registration purposes only.
Solution: Ensure that at least one director or a designated representative, who is well-informed about the business and the GST application, is present at the principal place of business during all working hours after you apply.
Problem #2: “Another firm exists at the same address”
This is a major concern, particularly for businesses operating from co-working spaces, shared commercial properties, or residential addresses where another business is also registered. The GST law requires every registered entity to have a distinct “Principal Place of Business,” as defined under Section 2(89) of the CGST Act, 2017. When two firms share an address without clear legal and physical demarcation, it signals a potential risk of shell companies or improper claims of Input Tax Credit (ITC).
Documents Required for Shared Premises:
| No | Document Type | Purpose | Legal Requirement |
|---|---|---|---|
| 1 | No-Objection Certificate (NOC) | Confirms owner’s consent | Mandatory from the property owner |
| 2 | Consent Letter | Permission from the existing business | Required for shared spaces |
| 3 | Proof of Demarcation | Shows a specific allocated area | Critical for verification |
| 4 | Sub-lease Agreement | Legal right to occupy | Establishes legitimate occupancy |
| 5 | Utility Bills | Validates premises | Recent bill (within 3 months) |
Problem #3: “No documents were available for verification”
The absence of physical documents at the business premises often confirms an officer’s suspicions. An online application must be supported by physical records available for inspection at any time. This demonstrates preparedness and proves that your business operations are genuine and organised.
Essential Documents for GST Registration File:
- Company PAN Card
- Certificate of Incorporation
- Directors’ KYC documents (Aadhaar, PAN)
- Proof of address (utility bill within 3 months)
- Sale Deed/Rent Agreement/NOC/Consent Letter
- Demarcation documents for shared premises
Latest GST Compliance Updates for 2025 π
- Biometric Authentication Requirements: GSTN’s new advisory relates to verification for GST registration via Biometric-Based Aadhaar Authentication and document verification in multiple states, including Tamil Nadu, Himachal Pradesh, Rajasthan, and others. After submission of the application in Form GST REG-01, the applicant will receive an email either for OTP-based authentication or to book a GSK appointment for biometric verification.
- Multi-Factor Authentication (MFA): Starting April 1, 2025, mandatory multi-factor authentication (MFA) for GST portal access has been implemented to curb fraudulent practices. This includes Time-Based One-Time Passwords (TOTPs) through a dedicated mobile app.
- Deemed Approval Provision: As per Rule 9(5) of the CGST Rules, if the proper officer fails to take any action on the application within thirty days from the application submission date (where physical verification is required), the application for registration is deemed to have been approved. This provision protects applicants from undue delays in the registration process.
What Are Your Options After a Rejection Order? πΌ
Once you receive the rejection order (Form GST REG-05), you have two primary courses of action. It is crucial to act promptly and strategically to avoid further delays.
Option 1: File an Appeal Against the Rejection (Recommended) βοΈ
If you believe the rejection was unjust and you now have all the necessary documents to prove your case, filing an appeal is the best option. As per Section 107 of the CGST Act, 2017, you can file an appeal with the designated Appellate Authority using Form GST APL-01 within three months from the date the rejection order was communicated.
Appeal Process Timeline:
| Stage | Timeline | Action Required |
|---|---|---|
| Filing Appeal | Within 3 months of rejection | Submit Form GST APL-01 electronically |
| Document Submission | Within 7 days of filing | Provide a certified copy of the rejection order |
| Condonation of Delay | Maximum 1-month extension | Show sufficient cause for delay |
| Authority Decision | As expeditiously as possible | Order passed after hearing and verification of documents |
The appellate authority may condone delay for a maximum period of 1 month if satisfied that the taxpayer was prevented by sufficient cause. Your appeal should systematically counter each reason for rejection with comprehensive documentary evidence.
Option 2: File a Fresh Application for GST Registration
Alternatively, you can file a completely new application for GST registration. However, this is not a shortcut. You must not reapply without first rectifying all the issues pointed out in the rejection order. The GST portal links all applications to your PAN, and re-applying with the same flawed information will lead to another rejection.
Pre-requisites for Fresh Application:
- Rectify all issues mentioned in the ejection order
- Ensure documentation is complete and updated
- Display the business signboard at the premises
- Guarantee the authorised person’s availability during working hours
Conclusion
Receiving a GST registration rejection notice after a field visit can feel like a major roadblock, but it is not the end of the road. By understanding the verification process from the officer’s perspective and proactively preparing meticulous documentation, you can successfully address their concerns. Treat the GST registration process as the first formal audit of your business. Keep your documents organised, ensure your place of business is clearly defined and legally sound, and be prepared for scrutiny. When in doubt, consulting with a qualified Chartered Accountant or a GST practitioner can help you navigate the complexities and ensure a smooth approval process.