A person can apply for a GST registration number to comply with the GST Act on mandatory GST registration requirements or to get the benefits of GST registration by voluntary GST registration under the CGST Act 2017.
In the process of GST registration, once the application is submitted the applicant may receive the query notice requiring the additional documents, explanation, etc. The department can send query notice only in case the application is assigned for manual approval by the GST officer. The question of query notice is not applicable in case of auto approval under Rule 14A or Rule 9A.
This article will be helpful for the applicant whose GST registration is subjected to manual approval, and also for the dealer whose GST registration is already approved in auto approval mode as per rule 14A and now the dealer had filed withdrawal from the scheme.
Why Show cause notice is issued in GST registration process.
Once the GST registration application is submitted and the Application Reference Number – ARN is generated, within 7 working days the concerned GST officer should approve or raise a query by issuing a” Notice for seeking Additional Information/ Clarification/ Documents relating to Application for Registration”.
If the query is raised, the applicant should respond to the queries raised by the officer by applying for clarification.
Application for filing clarification to queries shall be made by modification in the registration application filed or without modification in the registration application filed.
In most of the cases applications for filing clarification shall be filed without modification of registration application filed.
While sending show cause notice the officer may raise query relating to principal place of business, details of promoter or authorized signatory, pending defaults etc. We have summarized illustrative list of queries with required response or action.
What are the Common Queries raised in GST registration show cause notice, and how to reply GST registration notice ?
| Sl.No | Query raised by the officer in the show case notice for approval of GST registration. | Solution or response to GST registration query |
Queries Relating to Principal place of business |
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| 1 | Rental agreement is not clear. | Attach the legible and properly scanned PDF document using scanner of scanner app, Do not attaching photos of rental of rental agreement. |
| 2 | Rental agreement is not valid, attach registered rental agreement. | In the state of Tamil Nadu as per the the law all rental agreement should be registered if the period of agreement is 12 months and above, therefore if you are attaching unregistered rental agreement for GST registration, make sure it is for period of 11 months of lesser. |
| 3 | Name of the applicant and name in the rental agreement is different. | The rental agreement should be executed in the business name and represented by its proprietor or authorized signatory. |
| 4 | Rental agreement date is invalid, rental agreement time expired or lapsed. | This query will be raised when the validity date in the rental agreement is expired at the time of filing the application or at the time when the officer verifies the GST registration application. So it is suggested to upload rental agreement which have minimum 2 months. This extended period ensures that the validity will be there even if the GST number approval is delayed due to physical verification or other reasons. |
| 5 | Owner Details in the utility receipts (Electricity bill receipt, Property tax receipt) and rental agreement is not matching. | Rental agreement should be always executed by the person who legally owns the property or by the person who is authorized to sub let the property for rent. It is irrelevant who receives the rent.
There may the cases where the property is owned by the ancestor who had expired and partition is pending, in such case rental agreement can be executed only by the legal heirs, if there is more than one legal rental agreement should be executed by all of them or they should provide NOC in their favor of legal heir who is executing the rental agreement. Again it is irrelevant who receives the rent payment for the purpose of GST registration. File legally valid supporting documents to justify the difference along with the covering letter. |
| 6. | Proprietor/ promoter/ Authorized person details mismatch in rental agreement. | Ensure that the rental agreement has complete and correct details such as full father name, age, address, that match the details submitted in the GST registration application. If there is mismatch take corrective action in GST application if possible. |
| 7 | Witness details not proper. | Modify the rental agreement to include the complete name with father name, address of the witness, Aadhaar card number, and active mobile number. |
| 8 | Address mismatch in rental agreement and utility receipts (electricity receipts.). | There may be difference between address in electricity database and actual address provided in the rental agreement and GST REG – 01 application. The reasons may be re numbering of doo number, renaming the street address, modification in area pin code etc. In the above mentioned cases it is advised to update address with the electricity department. The major issues after the updating is the new address will be reflected in next month bill only, so it is advisable to attach the account summary which will have the updated address. |
| 9 | The activity mentioned is trading in goods and the details provided for principal place of business is not suitable for storing the goods etc. | In rare cases the department officers will raise queries relating to nature of business, For some business storage of goods will be a major factor in that case the officer may be of opinion that goods cannot be stored at the principal place of business as per the attached photos. In case where the goods are transported directly from the suppliers warehouse to customer place then it is recommended to attach the explanatory statement justifying the reason for such principal place of business. |
| 10 | The address provided as principal place of business is already registered with GST. | Case 1 : The address given for principal place of business will be same where multiple business functions from the same complex etc. This issue will arise in case of common EB is supplied for all the units in the complex. Provide the relevant documents and such as photos of the premises, complex, and a well drafted covering letter for justification of the same. Add details such as floor number or shop number for differentiating from other units in the complex by changing rental agreement, GST registration application filed.
Case 2 : Additional GST registration application can be applied by the same person for the same address, but it should be for the different nature of business. Provide proper explanation that the additional GST registration number is for different business. Case 3 : Additional GST registration application can be applied by the different person but for the same unit in the complex building, this situation arises where there is an understanding between the existing occupant and the application for sharing the same space for his business. The rental agreement should allow sub let by the existing tenant or else the owner should provide the separate rental agreement along with No objection certificate by the existing dealer in the premises. |
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| 10 | The address of the proprietor or director or partner is out of the state, provide local proof of address. | For approval of GST registration application the address of the authorized signatory should be authorized signatory would be within the state in which the application for GST registration is made. Therefore if any of the promotors having the permanent address is cannot be added as authorized signatory in that case it is mandatory to appoint the persons who is having local address in the state. The GST department officers are bound to verify this to avoid fake GST registration. It is enough if the authorized signatory has local proof of address, if it is unable to appoint partner of the partnership firm, or director of the company or the proprietor of the proprietorship firm as authorized signatory, then we can also appoint any other person as authorized person. |
| 11. | The list of partners or directors is different in the documents and the registration application filed. | If there is any change in the list of partners in the partnership firm after registration of partnership firm, necessary amendment deed for admission of partners or removal of partners should be attached along with the initial partnership deed. Similarly for removal and appointment of director applicable resolution and MCA forms should be attached. |
| 11. | The promoter or director or partner is already having a GST registration number. GST returns are pending for cancelled GST registration number. | Situation 1 : All existing partners, directors, authorized signatory, proprietor should not have any pending defaults relating to cancelled GST registration. Where the query is raised regarding the same it is mandatory to clear the pending defaults by filing pending periodic returns and GSTR-10 final return.
Situation 2 : There may be a active GST registration for different nature of business, in that case provide proper justification that the nature of business is different with explanation of difference between the products or services of the two business. |
We have tried to summarize the most frequently raised queries and suitable action with our practical expertise as GST registration consultant. With the increasing number of complaints from the stake holders and applications about GST officers issuing notices asking multiple documents or unnecessary documents for GST registration approval the Ministry of finance had issued Instructions for processing of applications for GST registration vide no 03/2025-GST dated 17 th April 2025. The officers should mandatorily comply with the instructions and approve the GST registration, this instruction had given a relaxation from few unnecessary queries and enabled peace of mind.
How can ChennaiRegistration.in help in solving GST registration queries raised by the GST department ?
We can help you to find the exact reason that led to issue of show cause notice by the GST department, suggest you corrective actions for approval, prepare additional documents such as NOC, explanation and reply statement to the query. Revalidating all the components and documents of GST registration application for re-submission. We will assess the eligibility and practical convivence to submit new GST registration application in fast track GST registration auto approval scheme as per recently introduced rule 14A fast track GST registration scheme by the Ministry of Finance. Application under Quick GST registration auto approval scheme will be a better solution and quick relief from cumbersome and stressful task of responding to GST registration queries.
