What Do You Do If Your GST Registration Is Rejected?

Form GST REG-03 is the notice a proper officer issues when a GST registration application is found deficient. The notice is a query on the application, not a refusal of it. Rule 9(2), CGST Rules 2017 requires the officer to issue it within 7 working days from the date of submission of the application. Where the application is on the physical-verification track, the proviso to Rule 9(2) allows the notice not later than 30 days. You then have 7 working days from the date of receipt of the notice to reply in Form GST REG-04. The portal shows your ARN as Pending for Clarification for as long as the notice is open, which is one of the GST registration status values the tracker returns.

The chain runs Rule 9(2) notice, Rule 9(2) reply, Rule 9(3) decision, Rule 9(4) rejection order, and Rule 9(5) deemed approval. Form GST REG-03 itself, as substituted by Notification No. 18/2025-Central Tax dated 31 October 2025, closes with this:

"If no response is received by the stipulated date or if proceedings under section 29 is initiated against you, your application is liable for rejection. Please note that no further notice / reminder will be issued in this matter."

The notice also carries a line directing the applicant to appear before the officer. On a new registration application that line does not apply: the form's own footnote reads "Not applicable for New Registration Application and Withdrawal." Your Form GST REG-04 is the whole of your case.

"Working day" is not defined anywhere. Not in the CGST Act, not in the CGST Rules, not in the IGST Act, not in the UTGST Act, and not in the General Clauses Act, 1897. No CBIC circular, instruction or notification defines it, no GSTN advisory defines it, and no court has decided the point for Rule 9. Section 2(27) of the CGST Act defines a different term, "common working days", meaning "such days in succession which are not declared as gazetted holidays by the Central Government or the concerned State or Union territory Government", and that defined term appears nowhere else in the Act. It is an orphan carried in from the Model GST Law. Note what the formula excludes: gazetted holidays, and not Saturdays and Sundays. Counting your seven days therefore rests on Rule 9's own wording and on the General Clauses Act, 1897, in four steps.

• The day the notice reaches you does not count. Rule 9(2) runs "from the date of the receipt of such notice", and section 9 of the General Clauses Act, 1897 excludes the first day of a period introduced by "from". Counting starts the next day.
• The 30-day periods are 30 calendar days, not 30 working days. The rule says "days", and GSTN's own functionality note on Notification No. 94/2020-Central Tax dated 22 December 2020 distinguishes "deemed approved in 7 working days" from "deemed approved after 30 calendar days".
• If the last day falls on a day the office is closed, section 10 of the General Clauses Act allows the act on the next open day. It is a saving and not a definition, it rescues the final day only, and it bites the 30-day periods rather than the working-day ones.
• Deemed approval is automatic. Rule 9(5), read with section 25(12) of the Act, deems the application approved if the officer takes no action; the portal applies it and generates the GSTIN. You do not apply for it.

Count both ways and act on the earlier date. Your own 7 working days to reply should be counted tightly, so file Form GST REG-04 well before the outer edge, because there is no relief for a late reply beyond section 10 and section 10 rescues only the final day. The officer's 7 working days should be counted generously; silence on day eight is not a breach.

The GST portal's Holiday List, at Services > User Services, shows the Central Government's and each State's working and non-working days. GSTN calls it provisional and not final, and no rule gives it legal effect, so plan with it and never argue from it.

Three official sources start your reply clock on three different days, and nothing reconciles them. Rule 9(2) runs it from "the date of the receipt of such notice". CBIC Instruction No. 03/2025-GST contradicts itself: paragraph 8(vii) runs it from receipt, paragraph 8(viii) from "the date of issuance of notice". GSTN's own user guide runs it from "generation of the Notice", stated twice on the same page. This is a prudent practice, not a statement of law: count from the date printed on the face of the Form GST REG-03, which is the earliest of the three, and file with days in hand. Counting from receipt is the orthodox reading of Rule 9(2), but it leaves you exposed if the officer counts from issuance.

Nine reasons account for almost every Form GST REG-03 query and Form GST REG-05 rejection on a GST registration application. Four of them are the only grounds an officer may lawfully use, under CBIC Instruction No. 03/2025-GST paragraph 8(v). The other five are practical failures the portal or the officer will not overlook. Two of the nine cannot be cured in Form GST REG-04 at all: a PAN mismatch, and a failed Aadhaar authentication. The Explanation to Rule 9(2) excludes exactly four particulars from what a clarification may modify, namely Permanent Account Number, State, mobile number and email address declared in Part A. Legal name is not one of them, so a legal-name mismatch can be corrected in the clarification once the CBDT record itself is right. Read your notice against the table below before drafting anything.

About 47% of the GST registration applications granted during 2023–24 followed a clarification query. Answering Lok Sabha Unstarred Question No. 1059 on 29 July 2024, the Ministry of Finance gave the figures for 2023-24: 9,04,598 applications were granted after a clarification was sought and 10,27,718 were granted without one, about 19.3 lakh grants in the year, with roughly 47% of them requiring a clarification first. The average time to approval was 12.82 calendar days: 8.61 days where no clarification was needed, 17.69 days where one was. Asked directly about registration processing, the Ministry gave grants and turnaround times, and it did not give rejections. The Comptroller and Auditor General has counted what the Ministry did not. CAG Report No. 3 of 2023, at paragraphs 3.1.1.3 and 3.1.1.4, records 7,67,328 applications that were neither approved nor rejected, in contravention of Rule 9.

Two of the nine reasons end the application rather than pause it. A PAN mismatch and a failed Aadhaar authentication are outside what Form GST REG-04 can change, so the fastest route on both is a corrected fresh Form GST REG-01, not a reply.

A Form GST REG-04 reply to a new registration query is filed without logging in. A pending applicant has no GST portal credentials yet, only a Temporary Reference Number (TRN). Open gst.gov.in, click REGISTER, select the Temporary Reference Number (TRN) option, enter the TRN and your registered email address, and complete the OTP. The Application for Filing Clarifications page then opens. Search by the Reference No. of Notice printed on the Form GST REG-03, or by your Application Reference Number (ARN). Answer Yes or No at Modification in the Registration Application filed, then submit with DSC or EVC.

• Choose Yes at Modification in the Registration Application filed only if a field in the application is actually wrong. Selecting Yes reopens the original application in editable mode; a warning then offers OPEN FIELDS WITH QUERIES RAISED THROUGH REG-03, which unlocks only the queried fields, and OPEN ALL ALLOWED FIELDS, which unlocks everything editable. Take the first unless a second error needs fixing. GSTN notes the option applies to Regular, Casual, Composition, ISD, SEZ Developer and SEZ Unit applications only.
• Choose No when the documents were right and only an explanation is wanted. The screen then gives you a Query Response field, a Remarks field, an Additional Information field and a Choose File upload. The tax officer's own remark is displayed in the Remarks field, so read it before you write anything.
• The Aadhaar Authentication tab cannot be edited while filing clarification. GSTN's user guide states this in terms, which is why a failed authentication is a fresh-application problem and not a reply problem.
• Sign with SUBMIT WITH DSC or SUBMIT WITH EVC. EVC sends an OTP to the email address and mobile number of the Authorised Signatory registered on the portal; then click VALIDATE OTP. A company or LLP signing with DSC must have the signatory's certificate registered before the deadline, not on the day.

Read the notice itself before drafting. The Form GST REG-03 sits at Services > User Services > View Notices and Orders, reached with the same TRN login, and it is the only document that tells you what the officer actually objected to.

A Form GST REG-04 reply has ten items, and only three of them require drafting. Items 1 to 6 are copied from the Form GST REG-03 notice and from your own application. Item 7 is the Yes or No modification choice. Item 8 carries your answer to each query, item 9 lists what you have uploaded, and item 10 is the statutory verification. Answer every numbered query in the notice separately, in the officer's own words, and name the document that proves each answer. The template below is written against the form substituted by Notification No. 18/2025-Central Tax dated 31 October 2025.

FORM GST REG-04
[See rules 9(2), 19(3) and 14A]
Clarification / additional information / document for Registration

 1.  Notice details              Reference No.: <reference number printed on the Form GST REG-03>
                                 Date: <DD/MM/YYYY as printed on the notice>
 2.  Application details         Reference No. (ARN): <your ARN>
                                 Date: <DD/MM/YYYY of submission>
 3.  GSTIN / GSTP ID, if applicable
                                 Not applicable, new registration application
 4.  Name of Business (Legal)    <legal name exactly as it appears in the PAN database>
 5.  Trade name, if any          <trade name exactly as declared in Form GST REG-01>
 6.  Address                     <principal place of business exactly as declared>
 7.  Whether any modification in the application for registration or fields is required
                                 [ ] Yes    [ ] No     (tick one)
 8.  Additional Information      <the reply text set out below>
 9.  List of Documents uploaded  <numbered list, one line per file>
10.  Verification
     I, <full name of the authorised signatory>, hereby solemnly affirm and declare that
     the information given hereinabove is true and correct to the best of my knowledge and
     belief and nothing has been concealed therefrom.

     Signature of Authorised Signatory: ______________________
     Name: <full name>
     Designation / Status: <Proprietor / Partner / Director / Authorised Signatory>
     Place: <place>                      Date: <DD/MM/YYYY>

The reply text for item 8 goes in the Additional Information field, or in Query Response where you have answered No at item 7. Repeat the block once per numbered query in the notice.

Query 1: <reproduce the officer's first query word for word from the Form GST REG-03>

Reply to Query 1
The <document name> uploaded at serial 1 of the list below establishes <the exact fact the
officer asked about>. <One further factual sentence: what the document shows, and where on
it, whether page, line or field.> <Where a field has been corrected:> The field <field name>
in the application has been corrected under item 7 of this Form and now reads <corrected
value>, which matches that document.

Query 2: <reproduce the officer's second query word for word>

Reply to Query 2
<same shape: one sentence naming the document, one sentence naming what it shows, one
sentence naming any field corrected.>

General submission
The documents furnished with this reply are those listed for the purpose in FORM GST REG-01
and in CBIC Instruction No. 03/2025-GST dated 17 April 2025. Paragraph 6 of that Instruction
records that any one of the listed documents is sufficient proof of the principal place of
business and that no additional document should be requested. Paragraph 8(vi) records that
a document outside the listed documents may be sought only after the approval of the
concerned Deputy or Assistant Commissioner. If any further document is required, we shall
furnish it promptly on being informed of the ground on which it is sought.

List of documents uploaded
 1. <document name> - establishes <what> - <n> page(s)
 2. <document name> - establishes <what> - <n> page(s)
 3. <document name> - establishes <what> - <n> page(s)

• Answer each numbered query separately, under the officer's own words. A single running paragraph answering three queries at once is the commonest reason a satisfied officer still rejects, because nothing on the file shows which query was met.
• Name a document for every answer, and upload it. An assertion without a document is not a clarification. Where the officer asked for a legible copy, say which serial number of the list is the replacement.
• Cite the Instruction once, in the general submission, and never in the individual replies. One measured reference to paragraph 6 and paragraph 8(vi) reads as a professional reply. The same point repeated under every query reads as an argument, and the officer still holds the discretion in Rule 9(4).
• Do not ask for more time and do not ask for a hearing. Rule 9(2) prescribes no extension, and Form GST REG-03's own footnote records that the hearing line is "Not applicable for New Registration Application and Withdrawal."

An officer processing a GST registration application may seek only the documents listed in Form GST REG-01. CBIC Instruction No. 03/2025-GST dated 17 April 2025 says so, and paragraph 8(vi) requires the approval of the concerned Deputy or Assistant Commissioner before any document outside that list is sought. Paragraph 8(v) limits the grounds for a Form GST REG-03 notice to four. Paragraph 7 bars presumptive queries. Officers are also told not to raise queries "for minor deficiencies which are not relevant for establishing Proof of Place of Business or Constitution of Business". The Instruction supersedes Instruction No. 03/2023-GST dated 14 June 2023.

1. A document is incomplete or not legible. The officer may seek a complete or legible copy of that document.
2. The address does not match the document uploaded, or that document is not valid proof of the address. The officer may seek additional documents from the paragraph 6 list.
3. The address is incomplete or vague. The officer may seek complete, unambiguous address details with documentary proof.
4. A GSTIN linked to the applicant's PAN is cancelled or suspended. The officer may seek clarification or reasons for that.

The Instruction is addressed to officers, not to you, which is exactly why quoting its paragraph number back to one works.

Missing the reply window does not reject the application automatically. Rule 9(4) says the proper officer "may" reject where no reply is furnished, the word having been substituted from "shall" by Notification No. 62/2020-Central Tax dated 20 August 2020, and any rejection must be "for reasons to be recorded in writing". CBIC Instruction No. 03/2025-GST paragraph 8(viii) gives the officer 7 working days from the expiry of your window to pass that order. File the reply inside those days if you can, and write to the jurisdictional officer at the same time. Once Form GST REG-05 issues, the reply window is gone.

The discretion in Rule 9(4) is real and the order takes days to issue, so a complete late reply plus an email to the jurisdictional officer is worth filing, though it is a request rather than a right. While it is outstanding the portal sets the application to Clarification not filed - Pending for order, which means the officer has the file and has not yet passed the order.

Section 25(12) makes deemed approval a statutory entitlement. Section 25(12) of the CGST Act provides that a registration shall be deemed to have been granted after the expiry of the prescribed period if no deficiency has been communicated to the applicant within it. Rule 9(5) sets the three periods: 7 working days from the date of submission of the application in ordinary cases, 30 days from the date of submission of the application where the proviso to Rule 9(1) applies, and 7 working days from the date of receipt of the clarification after a Form GST REG-04 reply. Where registration is granted that way, Rule 10(5) requires the certificate in Form GST REG-06 to be made available within three days after the expiry of the period.

No period on this page is 21 working days. The 21-day figure and the 3-working-day deemed approval still printed in 2026 coverage were both replaced on 22 December 2020 by Notification No. 94/2020-Central Tax, which substituted 7 working days and 30 days into Rule 9. There is a genuine three-working-day route since 1 November 2025, but it is the Rule 9A and Rule 14A auto-grant, not a Rule 9 deemed approval, and it never applies to an application already under a Form GST REG-03 notice.

Do not plan around deemed approval. Instruction No. 03/2025-GST paragraph 8(vi) directs officers that "no application for grant of registration is approved on deemed basis for want of timely action", which is precisely why a Form GST REG-03 notice tends to arrive on day six or seven.

Both routes are open, and reapplying is almost always faster. An order in Form GST REG-05 is appealable to the Appellate Authority under section 107(1) of the CGST Act, in Form GST APL-01, within three months from the date the order is communicated. Section 107(4) allows one further month on sufficient cause. Section 107(13) asks the Appellate Authority to decide within one year "where it is possible to do so". A fresh Form GST REG-01 is decided in 7 working days under Rule 9(1). Appeal only when the effective date of registration matters more than the delay.

Rule 109A fixes which Appellate Authority hears the appeal, and you never pick. Rule 109A(1) routes the appeal by the rank of the officer who passed the order: to the Commissioner (Appeals) where it was passed by an Additional or Joint Commissioner, and to any officer not below the rank of Joint Commissioner (Appeals) where it was passed by a Deputy or Assistant Commissioner or a Superintendent, in each case "within three months from the date on which the said decision or order is communicated to such person". A registration rejection is ordinarily passed at the Superintendent or Assistant or Deputy Commissioner level, so clause (b) is the usual route. Rule 109A applies by its own words to orders under the CGST Act, the State GST Act and the UTGST Act alike, so a State-jurisdiction rejection follows the same ladder, and the portal pulls the order and routes the appeal into the First Appellate Authority's queue from the order's own jurisdiction.

A rejection can cost you the date your registration takes effect. Rule 10(2) makes registration effective from the date you became liable, where the application was submitted within thirty days of that date. Rule 10(3) makes it effective from the date of grant where the application came later. A fresh application filed after a rejection is a new application on a new date, so a registration that would have run from the day the liability arose may instead run from the day the GSTIN is issued. Where that date carries money, an appeal against the Form GST REG-05 order is the route that preserves it.

No pre-deposit falls due on an appeal against a Form GST REG-05 refusal, on the arithmetic of the section itself. Section 107(6)(a) requires the admitted amount of tax, interest, fine, fee and penalty to be paid in full. Section 107(6)(b) requires ten per cent of "the remaining amount of tax in dispute". Both clauses are keyed to monetary amounts, and an order refusing a registration application determines none: there is no tax, no interest, no fine, no fee and no penalty in it. The proviso substituted with effect from 1 October 2025 addresses orders that impose a penalty alone, and it too computes to nil where no penalty is imposed.

No judgment of any court holds that a pre-deposit is payable on a section 107 appeal against a Form GST REG-05 refusal, and none holds in terms that it is not. The question appears never to have been litigated. The position above is the statutory arithmetic, supported on principle by the decisions named, and not a decided point.

The appellate authority cannot waive or reduce a pre-deposit, which the Delhi High Court held in Gaurav Jain at paragraphs 70 and 71. So if a pre-deposit is demanded on an appeal against a refusal order, there is no application to make for relief from it. Record on Form GST APL-01 that the order under appeal determines no amount of tax, interest, fine, fee or penalty, and that both clauses of section 107(6) therefore compute to nil. If the appeal is returned as defective for want of a pre-deposit, the remedy is a writ petition, not a waiver application.

CBIC Instruction No. 03/2025-GST is a departmental instruction and not case law, and no court has endorsed it. Aggarwal Dyeing and B.C. Mohankumar are what you quote back at an unreasoned Form GST REG-05; the Instruction is what you quote back at an officer who asks for a document outside the list.

A rejected application creates no bar and no waiting period. Nothing in section 25, Rule 9 or Form GST REG-05 prevents a fresh Form GST REG-01 the same day, and no fee or penalty attaches to the rejection. What does follow you is a cancelled or suspended GSTIN on the same PAN. Instruction No. 03/2025-GST paragraph 8(v)(d) makes that a permitted ground for a fresh query, and Circular No. 95/14/2019-GST dated 28 March 2019 directs officers to compare the new application against every registration held on that PAN. Clear the old GSTIN before you refile, not after. The fresh application runs through the ten steps from the beginning.

M/s Maharaj Ji Enterprises v. Union of India, Patna High Court (Division Bench), 16 July 2025, CWJC 15175/2024, holds that a fresh application is not barred after a rejection, sets aside an unreasoned rejection, and holds that the department cannot rely on a ground never put in the Form GST REG-03 notice.

• Fix the ground the order names, not the ground you assume. The Form GST REG-05 order states the reasons, in the same numbered shape as the notice. Read it at Services > User Services > View Notices and Orders before touching a new application.
• Clear any cancelled GSTIN on the same PAN first. Where a registration was cancelled for failure to furnish returns, apply for revocation in Form GST REG-21 within 90 days of service of the cancellation order under Rule 23(1), extendable on sufficient cause shown and for reasons to be recorded in writing by the Commissioner or an officer authorised by him in this behalf, not below the rank of Additional Commissioner or Joint Commissioner, for a further period not exceeding 180 days. Circular No. 95/14/2019-GST treats not doing so, while the default continues, as a "deficiency" under Rule 9(2).
• Re-scan every document before you re-upload it. The two grounds in Instruction No. 03/2025-GST paragraph 8(v)(a) and (b), illegible documents and address mismatch, are the two most common, and both are eliminated at the desk in twenty minutes.
• Do not change the address to something easier. A principal place of business you cannot prove possession of at a physical verification is a worse problem than the one you started with, and the verification report in Form GST REG-30 carries a GPS-enabled site photograph.

Rejection happens before a GSTIN exists; suspension and cancellation happen after. A rejection is an order in Form GST REG-05 under Rule 9(4), refusing an application. A suspension is a pause on a live registration under Rule 21A, intimated in Form GST REG-31, with 30 days to explain. A cancellation "suo moto" is the proper officer cancelling a live registration on his own motion under section 29(2), which is what the portal's wording means. Cancellation is undone by applying for revocation in Form GST REG-21 within 90 days under Rule 23(1). A rejection is not.

Cancellation and revocation are worked out under sections 29 and 30, which is where the rest of that chain belongs.

Two escalation routes exist and they are not interchangeable. A portal or processing failure, such as an ARN that will not move or a notice that never appeared, goes to GSTN's Self Service Portal at selfservice.gstsystem.in as a ticket. An officer who has raised a query the instructions forbid, or rejected on a ground never put to you, goes to your jurisdictional CGST Zone: CBIC Instruction No. 04/2025-GST dated 2 May 2025 requires each Zone to publicise a grievance email address for exactly that. A State-jurisdiction ARN has no national route and goes to that State's own channel.

Route 1, for a technical or processing problem

Go to selfservice.gstsystem.in, choose Report Issue, pick the category Registration - New Registration, then the sub-category that matches your problem. The portal serves an FAQ first; click "No, I want to lodge my complaint" to raise the ticket, and note the ticket number it returns. Track it at selfservice.gstsystem.in/IssueStatus.aspx. The gst.gov.in footer separately carries Log/Track Your Issue: Grievance Redressal Portal for GST, and, under Help and Taxpayer Facilities, a Grievance Nodal Officers link, which is a published list of nodal officers. All three are Route 1 channels and all three handle portal and technical grievances.

Route 2, for an officer who has departed from the instructions

CBIC Instruction No. 04/2025-GST dated 2 May 2025 (F. No. CBIC-20016/24/2025-GST) gives an applicant holding a Central-jurisdiction ARN a right to approach the jurisdictional Zonal Principal Chief Commissioner or Chief Commissioner by email, where a query has been raised in contravention of Instruction No. 03/2025-GST or where the grounds of rejection are objectionable. The Instruction publishes no address of its own, because each Zone publicises its own, so find the address your Zone has notified. Two worked examples: the CGST and CX Delhi Zone gives grievance.cgstdelhi@gov.in, publicised by its Trade Notice No. 01/2025 and published at gstdelhizone.gov.in/new-pdfs/grievance-redressal.pdf, and the CGST Bengaluru Zone notified its address in Public Notice No. 01/2025.

The two routes are different remedies for different subject matter, and sending an objectionable-grounds complaint to the technical portal uses a channel that cannot give the relief sought.

If your ARN is with the State, there is no national route. Instruction No. 04/2025-GST only requests the GST Council Secretariat to ask States to consider a similar mechanism, and the models States have built differ structurally: some run a true ticketed grievance system, some a service ticket with a registration category, some only a helpdesk or a named officer. Use your State commercial tax department's own channel. CPGRAMS at pgportal.gov.in is the universal fallback for either jurisdiction. A State grievance sent to a CGST Zone anyway must be forwarded on, under paragraph 2(iii) of the Instruction.

The Department of Trade and Taxes, GNCTD, at delhitradetax.delhi.gov.in, has no registration grievance cell, no nodal officer and no equivalent of CBIC Instruction No. 04/2025-GST. What exists is a GST Facilitation Centre at 1st Floor, Vyapar Bhawan, IP Estate, New Delhi 110002, and the departmental email ctt.delhi@nic.in. Escalation inside the department runs to the Special Commissioner and the Commissioner (Trade and Taxes), and CPGRAMS remains open alongside.

Send the ARN, the jurisdiction and a plain description of the issue, and nothing else. A grievance email with attachments is a grievance email that is not read.