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Dear Professional Colleagues,

Greetings of the Day !

The Central Board of Indirect taxes and Customs(GST Policy Wing ) had issued Instruction No. 03/2023-GST dated June 14, 2023, regarding Guidelines for processing of applications for registration.

Background

Instances have come to notice regarding unscrupulous elements obtaining fake/ bogus registration under GST and defrauding the Government exchequer. Such fake/ non-genuine registrations are being used to fraudulently pass on input tax credit to unscrupulous recipients by issuing invoices without any underlying supply of goods or services or both. This menace of fake registrations and issuance of bogus invoices for passing of fake ITC has become a serious problem, wherein fraudulent people engage in dubious and complex transactions, causing revenue loss to the government.

To address this problem, it is further felt that verification of applications for registration by the proper officers is one of the most crucial steps to prevent the menace of fake or bogus registrations.

Highlights of these guidelines:

- Directorate General of Analytics and Risk Management (DGARM), in coordination with GSTN, is conducting risk rating of the applications for registration in the form of High, Medium and Low-risk ratings for each application for registration. Proper officers would pay special attention to the cases where “High” risk rating has been assigned to an ARN.

- Proper officer may also give due consideration and special attention to the cases involving inter-alia the following circumstances:

(i) where any registration obtained on the PAN of the applicant has been cancelled previously;
(ii) where any registration obtained on the PAN of the applicant is suspended;
(iii) whether any application for registration on the PAN of the applicant has been rejected previously;
(iv) whether the place of business of the applicant appears to be risky based on local risk parameters;
(v) whether the proof of address of place(s) of business prima facie appear to be suspicious/ doubtful on the basis of scrutiny of the application and the documents.

- Proper officer may seek clarification or information or document(s) inter alia in the following cases:

(i) where any document is incomplete or not legible.
(ii) where the address of the place of business does not match the document uploaded by the applicant.
(iii) where the address of the place of business is incomplete or vague.
(iv) where any GSTIN linked to the PAN of the applicant is found cancelled or suspended.

- Where the applicant has either failed to undergo authentication of Aadhaar number or has not opted for authentication of Aadhaar number, the proper officer shall immediately initiate the process for physical verification of the place of business.

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Hope you find it interesting and useful to read.

For any clarification/ feedback, feel free to write us at amrg@amrg.in.

Best regards,

AMRG Team

About Us

AMRG & Associates is an established Chartered Accountants firm. It came into existence in 1984 and since then has grown its branches across major Indian cities such as Delhi, Mumbai and Chandigarh. Since its inception, it has become one of the leading chartered accountants’ firms in North India. AMRG & Associates offers its clients a wide range of exceptional services through the expertise of its highly motivated group of trained professionals. The firm provides expertise in financial and business advisory, tax and regulatory, audit and assurance and risk advisory services.

AMRG & Associates has a client base of 200+ companies & individuals. The firm's approach to service delivery helps to provide value-added services to its wide clientele. Our differentiation is derived from a rapid performance based, industry-tailored and technology-enabled business advisory services delivered by talented professionals in the country.

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© -2023 AMRG & Associates All Rights Reserved. This document has been written for the general interest of our clients and professional colleagues and is subject to change. This document is not to be construed as any form of solicitation. It is not intended to be exhaustive or a substitute for legal advice. We cannot assume legal liability for any errors or omissions. Specific advice must be sought before taking any action pursuant to this document.

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