GST Registration REG-03 Notice: Clarify and Resubmit

Your new GST registration is sitting at "pending for clarification" and the portal shows a REG-03 GST notice against your ARN. Nothing has been rejected yet. The notice means the proper officer could not reconcile something in your application with the papers you uploaded, and wants an explanation. You reply in FORM GST REG-04, and under the CGST Rules that reply must go in within seven working days of the notice. Let the window close and the application is rejected in FORM GST REG-05, and you start again with a fresh ARN.

What a REG-03 notice does to a pending application

FORM GST REG-03 is the standard notice for seeking additional information, clarification or documents on an application for registration. The proper officer issues it under Rule 9 of the CGST Rules, 2017. It always names the specific point the officer is uncomfortable with, usually in one or two lines in the notice and again in the remarks column on the dashboard.

Three things follow from the notice. The application is paused, not refused, and no fee is payable to answer it. The clock runs from the date you receive the notice, which in practice is the date it is uploaded and the email or SMS alert goes out, so three days spent waiting for a postal copy can cost you the application. And the reply is a formal submission in FORM GST REG-04 with attachments, read by the same officer who raised the query.

If the reply is satisfactory, registration is granted in FORM GST REG-06. If no reply comes, or the reply is found insufficient, Rule 9 permits rejection in FORM GST REG-05 after giving you an opportunity of being heard. The form formats and the Rules are published on the CBIC GST portal, and the reply itself is filed on the GST portal.

The four queries behind most REG-03 GST notices

Address and premises proof

This is the most common one. The address typed into the application does not exactly match the address on the uploaded electricity bill, or the bill belongs to somebody else. "Shop No. 4, Ground Floor, Survey No. 122" in the application against "4, S. No. 122" on the bill is enough to trigger a query. Officers also ask when the document is years old, is a screenshot from a phone, or is partly cut off in the scan.

Rent deed and the owner's consent

For rented premises the officer wants a chain, not a single paper: the rent or lease deed, a no-objection certificate from the owner, and a document proving the owner's connection to the property, usually an electricity bill or property tax receipt in the owner's name. An eleven-month deed with no signature on the last page will be queried. So will a deed executed in a partner's personal name where the applicant is the firm. Where the deed is personal, add one covering line stating that the premises is used by the applicant entity.

Bank account proof

Acceptable proofs are the first page of the passbook, a bank statement, or a cancelled cheque carrying the applicant's name. Queries usually arise from a mismatch: the application says "Kavita Enterprises" while the cheque says "Kavita J. Joshi", or the account is joint with the applicant as second holder. A newly opened account with no transactions is fine. An unclear photocopy of a cheque is not.

Constitution and authorised signatory

Companies are queried on the certificate of incorporation, the MoA and AoA, and on whether the signatory is authorised by a board resolution. Firms are queried on a partnership deed signed by every partner, and on the registration certificate where the deed is registered. Proprietorships rarely attract this query, but a name mismatch between PAN and Aadhaar still will. Where Aadhaar authentication was not completed or failed, the officer may also order physical verification of the premises under Rule 25 before or alongside the notice.

Documents that answer a premises query

The portal's own guidance is to send the latest bill, not a bundle from earlier years. Assemble one clearly scanned file per point:

• The most recent electricity bill for the premises, in the owner's name.

• A municipal khata copy or property tax receipt where there is no separate electricity connection.

• The full rent or lease deed, every page, signed by both parties, with the term and monthly rent visible.

• A no-objection certificate on plain paper, signed by the owner, giving the owner's name, address and telephone number.

• A self-attested copy of the owner's PAN and Aadhaar.

• A photograph of the shop front showing the trade name board and the street.

Drafting the point-by-point clarification

Treat the reply as a letter with annexures, not as an essay. Open with one line identifying the ARN, the notice reference number and its date. Then mirror the officer's numbering exactly: if the notice has three points, the reply has three numbered paragraphs in the same order.

Each paragraph should do three things. State what was asked, state what you are now uploading with the annexure letter, and state the fact that resolves the doubt. For example: "Point 2. The notice states that the electricity bill is in the name of a person other than the applicant. The premises is taken on rent from the owner, Shri R. Deshmukh. A no-objection certificate from the owner, the owner's PAN and Aadhaar, and the December 2025 electricity bill in the owner's name are uploaded at Annexures B-1 to B-4."

Do not re-upload the document the officer has already rejected, and do not upload twenty papers that nobody asked for. Where you genuinely cannot produce a document, say so plainly and give the alternative you are relying on. Silence on a point reads as non-compliance.

A worked example

Kavita Joshi applies for a proprietorship, "Kavita Enterprises", trading in office stationery from a rented shop in Kothrud, Pune. The application is filed in FORM GST REG-01 on 12 January 2026 with an electricity bill from June 2024 and a rent deed signed only by her. A REG-03 notice is uploaded on 19 January 2026 with three points: the rent deed is not signed by the owner, the electricity bill is old and in the owner's name, and the cancelled cheque shows a joint account with her husband as first holder.

She replies in FORM GST REG-04 on 23 January 2026. Annexure A is the full four-page rent deed, signed by both parties, monthly rent ₹18,000, term 1 December 2025 to 31 October 2026. Annexure B is the owner's no-objection certificate, the owner's PAN and Aadhaar, and the electricity bill for December 2025. Annexure C is a fresh cancelled cheque for a sole proprietorship account opened in the trade name, with the bank's stamp. Registration is granted in FORM GST REG-06 on 28 January 2026. The whole detour cost her four working days, and it would have cost her nothing at all if the correct papers had gone in on 12 January.

Resubmission and what follows

After you upload the reply, the portal issues an acknowledgement and the file returns to the officer. The realistic outcomes are a grant in FORM GST REG-06, a rejection in FORM GST REG-05, or, less often, a second clarification notice. A second notice is not a rejection, and it should be answered in the same numbered style within the fresh window.

A rejection in FORM GST REG-05 is an appealable decision under Section 107 of the CGST Act, filed in FORM GST APL-01 within three months. In practice, for a rejected registration most applicants simply file a fresh application with corrected documents, which is usually faster unless the earlier date matters for a contract or a tender. The statutory text sits on CBIC's tax information portal.

Common mistakes that turn a query into a rejection

Applicants answer only the first point and leave the rest. They upload the same illegible scan again. They start a second application while the first is alive, which creates a duplicate-PAN problem on the portal. They upload a rent deed that had already expired before the application date. And they wait for an email that never comes, when the notice is sitting on the dashboard.

Keep one folder per ARN containing the notice, the reply, every annexure, the acknowledgement and the final order. If a tax officer asks later how the premises was proved, that folder is your answer.

• Download the REG-03 PDF and underline every separate point raised.

• File the reply in FORM GST REG-04 within seven working days of the notice date.

• Answer each point in the officer's own numbering, one annexure per point.

• Attach the owner's no-objection certificate and identity proof wherever the bill is not in your name.

• Check that every scan is legible, complete and within the portal's file limits.

• Log in daily until FORM GST REG-06 or REG-05 appears, rather than waiting for an alert.

• Save the notice, reply, annexures and order in one folder against the ARN.

Open your GST dashboard now, read the exact wording of every point in the notice, and draft the reply today rather than on the seventh working day. This article is for general information only and is not legal advice. Consult a qualified professional for your specific facts.