Gujarat AAR Rejects Application on Multiple GST Registrations at a Virtual Office Address

The present application (No. Advance Ruling/SGST&CGST/2025/AR/27), dated July 24, 2025, has been filed by a company named Sweet Spot Spaces before the Gujarat Authority for Advance Ruling Goods and Services Tax D/5, Rajya Kar Bhavan, Ashram Road, Ahmedabad-380009. The personal hearing on the case was held on October 16, 2025.

The company is registered under the act of GST having GSTIN 24AFHFS7388R1ZV, and is located at 4-D, Vardan Tower, Fourth Floor, Lakhudi Circle, Ahmedabad, Gujarat-380009.

The applicant is involved in the business of providing co-working as well as virtual offices. They also rent out office spaces to clients so those clients can use the address as their official business address. These clients include e-commerce sellers, service providers, startups, and entrepreneurs from across India etc. The company provides facilities like video conferencing, mailing, GST registration support and authorised representative services. The applicant provides its rental offices to clients as the “Principal place of Business” (PPOB). The applicant also ensures all compliance with statutory record maintenance, KYC and Aadhar verification norms.

Question Asked Before Gujarat AAR:

Seeking the current Gujarat Advance Ruling (No. GUJ/GAAR/R/2025/50), dated November 19, 2025, the applicant has asked the following question:

“Question: Whether GST registration can be granted to multiple unrelated businesses, each allotted a distinct, identifiable and demarcated seat with unique seat numbers and time slots, at the same address as their “Principal Place of Business”, provided that:

• The address is used as a virtual office, allotted for a fixed time slot per day, week or fortnight (e.g. One hour, two hours or more as mentioned in the leave and licence agreement).
• Proper documentation, such as sub-rental/sub-lease agreements, is executed and available.
• Books of accounts are maintained and managed by the service provider firm and/or an authorised representative on behalf of the taxpayer upon the grant of GST registration.
• The clients are either legitimate service providers and/or suppliers of goods and/or both/e-commerce sellers working remotely from various states.
• Applicant raises an invoice to the clients.
• No physical stock is stored at the premises; however, the client will provide the address of a warehouse, either his own/rental or belonging to an e-commerce operator (e.g., Amazon, Flipkart), as their additional place of business.”

Answer Given by Gujarat AAR:

The Gujarat Authority for Advance Ruling (AAR), Goods and Services Tax (GST), gave the following answer to the question asked by the applicant:

The authority of advance ruling (AAR) has rejected the application of the applicant on the grounds that the questions asked by the applicant are not acceptable under Section 98(2) of the CGST Act, 2017, for the following reasons:

So, as we have discussed above, the applicant is a taxpayer registered under the act of GST Act and has bought a building on rent and wants to lease out these spaces to different clients so that they can use it as their virtual offices or co-working spaces for short periods (hourly, weekly, or monthly). Now, the applicant has a question regarding their business about whether their clients can get GST registration using this address, and to solve this query, the applicant has sought for advance ruling.

Before answering this, the Authority looks into some specific laws cited in this advance ruling:

1. Section 95(a) defines what an “advance ruling” is. An advance ruling can be given only about questions related to the supply of goods/services that the applicant is doing or plans to do.

Meaning, the ruling can be sought only on issues related to the applicant’s own supply of goods and services and anyone else’s. However, in the present advance ruling, the applicant is talking about a query related to its clients, i.e., whether their clients can get GST registration at these premises. As this question is not about the applicant’s own business, hence does not fall under the scope of section 95.

2. Section 97(2) lists the 7 types of issues for which advance rulings can be requested (like classification, time/value of supply, ITC, tax liability, etc.). One option is “whether the applicant is required to be registered”. However, in this case, the applicant is already registered under the GST Act, and as the applicant did not get any option related to its query, at serial no. 13, he ticked the box under “whether applicant is required to be registered”. However, the authority discovered that the questions asked by the applicant in the present advance ruling do not mandate the applicant to be registered; however, they are about whether multiple registrations can be granted at the same premises to the applicant’s clients. As the applicant is already registered under GST, the query for which the applicant had sought the ruling is incorrect.

3. Section 103 says, the ruling pronounced by the advance ruling authority is binding on the applicant. So even if a ruling were given, it would bind only the applicant, not their clients. Therefore, a ruling for the applicant cannot help their clients’ GST registration process. This makes the request meaningless under the law.

On the basis of the aforesaid findings, the authority concludes that the advance ruling sought by the applicant is not valid.