“GST Physical Verification: Is Written Authorization Mandatory or Is an ID Card Enough?

A GST officer in formal attire is holding a document with the word 'AUTHORIZATION' while interacting with another man in casual clothing, questioning whether written authorization is necessary during physical verification.

Issue

Whether GST officers must carry and present written authorization during physical verification in cases other than registration, and even during registration-related verification under Rule 25, or whether showing an ID card alone is sufficient.

Rule

  1. Section 67 – Inspection, search and seizure
    • Sub-section (1) authorises inspection only if the proper officer, with prior written authorisation from an officer not below the rank of Joint Commissioner, has “reasons to believe” that:
      • a taxable person has suppressed transactions, or
      • an unregistered person is engaged in taxable supply, or
      • any person is keeping goods/documents to evade tax.
    • The written authorisation must be issued in the prescribed form (e.g., FORM GST INS-01) and produced on-site.
  2. Rule 139 of CGST Rules
    • Specifically prescribes that such inspection must be authorised by issuing FORM GST INS-01.
  3. Rule 25 – Physical verification of business premises in certain cases
    • Allows the proper officer to physically verify the business premises before grant of registration, or after grant of registration in certain circumstances.
    • The officer must record verification report in FORM GST REG-30 within 15 working days.
    • However, the rule itself does not expressly require prior written authorisation, but the principles of natural justice and CBIC instructions expect verification to be based on an order or written approval by a superior officer.
  4. Section 71 – Access to business premises
    • Allows access for inspection, audit, or verification as per provisions of the Act and Rules — again subject to proper authorisation.
  5. Scrutiny of Returns / Assessment (Sections 61, 65, 66, 73, 74)
    • These provisions do not themselves grant inspection powers — if officers want to physically visit the premises in connection with scrutiny or assessment, they must act under Section 67 with written authorisation.

Application

  • Refund-related verification:
    If it involves physical inspection of premises, it would amount to “inspection” under Section 67, requiring written authorisation (FORM GST INS-01). An ID card alone is insufficient.
  • Unregistered persons:
    Visiting such premises for verification of taxable activity is covered under Section 67(1)(b) — again requiring written authorisation from Joint Commissioner rank or above.
  • Scrutiny/assessment-related visits:
    Any on-site inspection also falls under Section 67 — requiring written authorisation.
  • Rule 25 verification during/after registration:
    While Rule 25 doesn’t explicitly say “written authorisation,” in practice the visit is approved by a competent officer (usually via an internal assignment order), and the verification report (FORM GST REG-30) must record the visit. For transparency, the officer should carry such approval, though law mandates the report rather than the authorisation itself be recorded.

Conclusion

  • For inspections under Section 67 (refund verification, unregistered persons, scrutiny/assessment visits) — written authorisation is mandatory and must be produced on-site. ID card alone is not enough.
  • For Rule 25 premises verification — prior written authorisation is not expressly stated in the rule, but departmental practice and good governance demand that such visits be based on a documented order and officers should produce it if asked.
  • Taxpayers are entitled to request a copy or view the authorisation to confirm legality of the visit.