Physical Verification of Business Premises Know Your GST Rights
Under GST law, the physical verification of business premises is a critical part of the registration process—especially when Aadhaar authentication fails or is skipped. But can GST officers conduct this verification arbitrarily or without your presence? Absolutely not.
CBIC has issued clear guidelines that protect taxpayers. Let’s break them down for clarity.
When Does Physical Verification Happen?
Physical verification may be triggered under these conditions:
- Aadhaar authentication not opted or failed
- Doubtful documents or high-risk profile flagged by GST system
- Field officer recommends physical check during scrutiny
- Post-registration checks in case of suspicious activity
Legal Backing: Rule 9 and CBIC Clarification
As per Rule 9(1) and Rule 9(2)(b) of the CGST Rules, 2017:
- If Aadhaar authentication is not done, physical verification becomes mandatory.
- CBIC Instruction No. 03/2023-GST dated 14.06.2023 further mandates that: Verification must be conducted in the presence of the applicant or an authorized representative.
This means: GST officers cannot do a surprise visit or verification behind your back.
What Must Be Verified?
During the physical verification, the GST officer will:
- Confirm the existence and activity at the declared premises
- Check for a name board and business infrastructure
- Take geo-tagged photographs
- Record statements, if needed
📸 Photographic evidence must be attached to the GST REG-30 verification report.
Your Rights: What If Officer Violates Process?
If the officer:
- Conducts verification without informing you
- Skips the presence of your representative
- Submits a false or one-sided report
👉 You can raise a grievance via the GST Portal or escalate it to the jurisdictional Joint Commissioner.
📌 Case Insight: In multiple High Court cases, GST demands were struck down due to violations in registration and verification procedure.
Expert Tip
“Always authorize a staff or tax consultant to represent you during verification. If you’re unavailable, your authorized signatory must sign the REG-30 verification record on-site. This protects your legal standing.”
— GST Consultant, Efiletax Team
Summary Table: GST Physical Verification Rules
| Criteria | Requirement |
|---|---|
| Trigger | No Aadhaar auth / Risk flagged |
| Rule | Rule 9(1), Rule 9(2)(b) CGST Rules |
| Mandate | In-person presence of taxpayer or authorized representative |
| Report Format | REG-30 with photos and officer’s remarks |
| CBIC Instruction | No. 03/2023-GST dated 14.06.2023 |
| Grievance Route | GST Portal or jurisdictional officer |
| Legal Protection | High Court rulings favouring due process in verification |
FAQs
Q1. Can GST officer do verification without my knowledge?
No. Presence of taxpayer or their authorized person is mandatory during verification.
Q2. What if officer visits but I’m unavailable?
You can authorize another person in writing. Their signature will be valid.
Q3. What if wrong verification is reported?
You can file a representation and grievance on the GST portal with documentary proof.
Final Note
The physical verification of business premises is not just a procedural step—it’s a legal safeguard. When done improperly, it can delay your GST registration or lead to wrongful cancellation.
✔️ To stay compliant and protected, partner with experts who know the law.
👉 Reach out to Efiletax for guided GST registration & verification support
Snippet
GST physical verification must be done in person or via authorized rep. Rule 9 and CBIC’s Instruction No. 03/2023 ensure the taxpayer’s presence is mandatory. Learn how to protect your rights.