SOP 3 for Roles and Responsibilities.pdf

GST

18 Dec 2025

Roles and Responsibilities:

Circle Offices, Postal Accounts Office, and DDOs are fundamental to comprehending the practical implementation of the ‘One State, One GSTIN’ model. Each of these entities plays a distinct yet interconnected role in ensuring compliance with GST regulations, facilitating accurate reporting, and maintaining seamless coordination across the postal network. As per the nomenclature of the GST Act, the following offices may be designated as under: -

S.No. Particulars (As per the GST Act)

1 Principle Place of

Business (“PPOB”)

2 Additional Place of Business (“APOB”)

3 Accounts Wing of the PPOB

Remarks

The Circle Office or the highest administrative office in a State or Union Territory shall be designated as the PPOB.

All operational units, such as GPOs and HOs, shall be designated as APOBs.

Postal Account Office (“PAO”) shall be designated as the Accounts Wing of the PPOB.

4	GST Nodal Office	The PAF Wing at the Directorate shall be designated as the GST Nodal Office.

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Roles and Responsibilities

I) After obtaining the New GST, GST-TDS & ISD

1. Role of Accounts Wing of PPOB: [Postal Accounts Office]

[The Accounts

registrations, the PAO shall file NIL returns in respect of NEW GST, GST-TDS & ISD registrations (if applicable) till instructions received from the Directorate. PAOs shall wait for further instructions from the Directorate.

Wing of

the PPOB plays a

critical role in

ensuring financial

compliance,

statutory reporting,

and accurate return

filing under

the GST regime]

II) After the confirmation from the Directorate, i. The PAO must circulate the newly obtained GSTINs to PPOB, APOBs, and all other entities within the respective jurisdiction. ii. The PAO will intimate all the units regarding confirmation of Operational of NEW GSTIN & NEW GST-TDS registration including instructions mention that “All the transactions now be reported under the new GSTIN ______________________& GST-TDS ______________________with effect from ______________________. NO TRANSACTIONS should be reported under the old GSTIN/GST-TDS. NIL returns shall be filed under the old GST/GST-TDS registrations until the formal cancellation/surrender of those registrations is completed. Also mention in the instructions that it is the responsibility of the concerned unit Heads (Circle Office/ PAO/ RO/ DO/ DDO/

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PCD/ PSD/ SRM/ MMS) and all entities, if any transaction is under the OLD GSTIN/GST-TDS registration.

III) In addition to return filing, the Accounts Wing is responsible for issuing ISD invoices for the purpose of distributing ITC to other States/UTs or units that have actually utilized the input services. This must be done in strict compliance with the provisions of Rule 39 of the CGST Rules, 2017, which governs the ISD mechanism.

IV) After the implementation of the One State One GTSIN in a Circle, in cases where no transactions have occurred during a particular tax period in GST or GST-TDS or ISD, the Accounts Wing must ensure that NIL returns are filed in the respective registration to maintain compliance and avoid penalties.

V) In the event of any amendments to the GST, GST-TDS, or ISD registrations, such as changes in address, authorized signatory, or business structure, the PAO is responsible for filing the appropriate amendment applications along with supporting documentation to ensure that the changes are accurately reflected in the official records.

VI) Through these responsibilities, the Accounts Wing ensures that the Department of Posts maintains a high standard of financial governance and statutory compliance under the GST framework, thereby supporting the successful implementation of the “One State, One GSTIN” model.

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2. Role of Principal Place of Business:

[Circle Office/PPOB]

The PPOB serves as the central administrative authority within each state or union territory for the implementation and operationalization of the “One State, One GSTIN” model under the Department.

 The Chief Postmaster General, who will act as the Proprietor.

 The DPS (HQ) will work as the Authorised Representative.

I) Once the new GSTINs are obtained by the PAO, the PPOB is also responsible for circulating the new GSTINs to RO/DO/DDOs/all units, including their vendors, to ensure a seamless transition into the new GST framework.

II) The PPOB may also instruct all the Divisional Heads/DDOs/other units to assist the PAO for filing of the returns and also provide data to the PAO promptly, if required.

III) If the PAO faces any inconvenience in receiving responses/data/information from the DDOs/other units, they may take immediate action for the timely filing of the GST, GST-TDS, and ISD returns to avoid penalties.

IV) Its responsibility spans across registration, compliance, coordination, and oversight functions, ensuring that all GST

related obligations are fulfilled in accordance with the applicable legal framework.

V) In respect of New GST registration, all legal /litigation issues may be carried out at the Circle Office. GST notices, etc, will also be handled at the Circle Office. The Authorised Representative may personally watch to clear all litigation issues in due time.

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VI) Circle Office shall nominate an APMG/AD, who will work as an Authorised Signatory. (i) In respect of Old GSTIN, the Circle level Authorised signatory may ensure to settle all litigation issues with coordination with DDOs and prepare a report in Annexure ‘I’ and represent it before the Authorised Representative and Circle level GST Committee. (ii) In respect of New GSTIN registration, the Circle level Authorised signatory may also report to the Authorised Representative to clear all litigation issues with the coordination with the PAO.

3. Role of Additional Place of Business:

[The APOB plays a vital operational role in supporting the implementation and compliance of the “One State,

I) Once the new GSTINs are obtained by the PAO/Circle Office, the APOBs shall note the New GSTIN and wait for further instructions from the PAOs. (if received without instructions from PAOs)

One GSTIN” model within the Department. DDOs (CDDO & NCDDO) will work as an Additional Place of Business.]

II) ONLY AFTER THE CONFIRMATION FROM THE PAO, I) Divisional Heads/ DDOs/Other units are responsible for circulating

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the new GSTINs to all

vendors to ensure a

seamless transition into the

new GST framework.

Additionally, APOBs must

ensure that the GSTINs are

prominently displayed at all

business locations.

II) During the transition from old to new GSTINs, APOBs

must ensure that NIL

returns are filed under the

old GST registrations until

the formal cancellation of

those registrations is

completed. It is critical that

NO TRANSACTIONS are

reported under the old

GSTINs once the new

GSTIN becomes

operational [As confirmed

from the PAOs]

III) APOBs are further responsible for transferring all relevant transactional data to the Accounts Wing for the purpose of filing monthly GST, GST-TDS, and ISD returns. They must also provide any additional assistance required for reconciliation, audit, or compliance reviews.

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IV) In cases where pending litigation or disputes exist under the OLD GSTINs/GST-TDS, the APOB shall act as the primary point of contact for responding to notices, providing documentation, and coordinating with the GST authorities to resolve the matter. Upon successful resolution and closure of all pending cases, the APOB shall initiate the formal cancellation process of the old GST registrations, and a monthly report may be submitted to the Circle Office in Annexure ‘I’.

I) The Circle-level GST Committee serves as a

4. Role of Circle-level GST Committee:

dedicated governance and oversight body established at the Circle level to address operational, transitional, and compliance related matters arising under the GST regime. Its primary objective is to ensure the smooth implementation of the “One State, One GSTIN” model and to resolve legacy issues associated with previously held GST registrations.

II) One of the Committee’s key responsibilities is to monitor and manage all pending litigation related to the old GSTINs. This includes coordinating with all DDOs through the Circle Office. The Circle-level Authorised signatory will submit the Annexure ‘I’ with the approval of the Authorised Representative and leveraging the expertise of the Circle-level

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GST Consultant to resolve disputes, respond to departmental notices, and facilitate the closure of legacy cases. The Committee must ensure that all such matters are settled in a timely and legally compliant manner.

III) Following the resolution of litigation and other legacy issues, the Committee is responsible for overseeing the formal surrender of old GSTINs. This process must be completed within the prescribed timelines to avoid regulatory complications and to ensure a clean transition to the new GSTIN structure.

IV) To maintain compliance during the transition period, the Committee must also monitor the timely filing of NIL returns, including Form GSTR-1, GSTR

3B, GSTR-7, and other returns by all APOBs for the old GSTINs until their formal cancellation is processed. This ensures that no transactions are inadvertently reported under obsolete GST registrations, thereby maintaining the integrity of the department’s tax records.

V) To support these functions, the Circle level GST Committee shall establish a robust reporting and monitoring mechanism to track the return filing status of all APOBs under the OLD Registrations. This includes identifying delays, discrepancies, or non-compliance, and taking corrective action as necessary. The Committee may also issue advisories, conduct reviews, and escalate unresolved

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issues to the PPOB or Directorate, as appropriate.

VI) Through these responsibilities, the Circle level GST Committee plays a crucial role in ensuring legal compliance, operational continuity, and effective governance during the transition to the unified GSTIN model.

VII) The committee may also follow all the instructions as mentioned in the Directorate letter No PA/Accounts/GST 2/2024-25/2873 to 2926 dated 01.08.2024. The committee may meet many times in the month to resolve the above issue, if required.

I) Each Circle within the DoP shall

5. Role of GST Consultants at Circle Level:

engage a qualified GST Consultant to provide specialized legal, procedural, and operational support in the implementation and ongoing compliance with the GST framework. These consultants act as subject matter experts and play a pivotal role in ensuring that the Circle adheres to statutory obligations while strategically optimizing its tax positions.

II) The Circle-level GST Consultant is responsible for offering expert guidance on a wide range of GST-

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related matters. This includes, but is not limited to:  Legal and Procedural Advisory: Providing interpretation and application of GST laws, rules, and notifications relevant to the operations of the Circle. This ensures that all actions taken by the Circle are legally sound and compliant with the latest regulatory developments.  ITC Optimization: Assisting in the identification, classification, and maximization of eligible ITC across various transactions. The consultant will help ensure that ITC is claimed accurately and efficiently, minimizing tax outflows and avoiding disallowances.  Litigation and Dispute Resolution: Supporting the Circle in responding to notices, managing assessments, and resolving disputes related to legacy GSTINs or ongoing compliance matters. The consultant will work closely with the Circle-level GST Committee and DDOs to prepare responses, compile documentation, and represent the department’s position effectively.

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 Strategic Compliance Support: Advising the Circle-level GST Committee on procedural compliance, risk mitigation, and best practices for GST implementation. This includes reviewing return filing processes, advising on amendments, and ensuring that all statutory filings are completed accurately and on time.  Training and Capacity Building: Assisting in the development and delivery of training programs for APOBs, DDOs, and other stakeholders to enhance understanding of GST procedures, compliance requirements, and operational responsibilities under the “One State, One GSTIN” model.  Support to PAO for filing: The Circle-level GST Consultant may provide support to PAO for filing and other works related to GST.  As mentioned in the Term of Reference, circulated by the Directorate letter No PA/Accounts/GST Consultant Engagement/2023-24/356S to 3619 dated 14.10.24.

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	III) The consultant’s recommendations shall be documented and reviewed periodically, and the Circle must maintain a record of all advisory inputs and corresponding actions taken. This ensures transparency, accountability, and continuity in GST governance across the Circle.

I) The GST Nodal Office i.e., Postal

Accounts and Finance (“PAF”)

Wing at the DoP Headquarters,

plays a central and strategic role

6. Role of GST Nodal Office (PAF Wing, DoP HQ):

in the implementation of the ‘One State, One GSTIN’ model across the postal network. One of its primary responsibilities is to facilitate the procurement of a new Permanent Account Number at the Directorate level, which is to be officially registered in the name of the ‘Department of Posts’ for the purpose of centralized GST compliance.

II) In addition to its administrative functions, the GST Nodal Office is entrusted with the overall monitoring and oversight of the implementation of the ‘One State,

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7. Role of Directorate level GST Committee:

One GSTIN’ model across all

Circles and operational units. This

includes tracking progress,

evaluating compliance levels,

identifying operational challenges,

and providing timely guidance or

resolution in case of any policy

level issues faced by field units.

The monitoring function is critical

to ensuring that the

implementation is both effective

and efficient, and that all

statutory obligations under the

CGST Act, 2017, and related rules

are met.

III) The GST Nodal Office shall keep watch on the surrendering of OLD GSTIN, GST-TDS & ISD registrations.

I) The Directorate-level GST Committee shall ensure smooth implementation of the “One State, One GSTIN” model in PAN India.

II) One of the Committee’s key responsibilities is to monitor all pending litigation related to the old GSTINs, as reported by the Circle-level GST committee. This includes coordinating with the PAF wing and leveraging the expertise of the Directorate-level GST Consultant to respond on time for the timely surrendering of the OLD GSTIN/GST-TDS registrations.

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	III) The committee may also follow all the instructions as mentioned in the Directorate letter No PA/Accounts/GST 2/2024-25/2927 to 37 dated 01.08.2024.

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