GST_clarification_on_registration_for_storing_goods_in_WH_1762226424*CBIChttps://suketucshahco.com/wp-content/uploads/2025/11/GST_clarification_on_registration_for_storing_goods_in_WH_1762226424.pdf Clarifies GST Registration Requirement for Importers Using Warehouses in Other States*
Circular Reference: F. No. CBIC-20016/75/2025-GST/1025
Date: September 25, 2025
The Central Board of Indirect Taxes and Customs (CBIC) has issued a clarification regarding the requirement of separate GST registration for importers who store goods in warehouses located in States other than their principal place of business.
This clarification follows references from letter F.No. GCC0/1/22/0TH/126/2025 dated 27.06.2025, along with a representation submitted by the Kirana Committee, Delhi, dated 28.02.2025.
After a detailed examination of the provisions of the CGST Act, 2017 and related rules, the following key points have been outlined:
*1. GST Registration Requirement in Other States*
Businesses with their principal place of business in one State (e.g., Delhi) but storing goods in another State (e.g., Haryana) must obtain separate GST registration in that State if the goods are supplied from the warehouse located there.
As per Section 22 and Section 2(85) of the CGST Act, 2017, a “place of business” includes warehouses and storage facilities from where supplies are made.
Therefore, even if the warehouse is operated by a third party, it is deemed a place of business if goods are supplied from that location. Consequently, GST registration in the State where such supplies originate (Haryana, in this example) is mandatory.
*2. Tax Implications on Movement of Goods*
Movement of goods from the Delhi warehouse to the Haryana cold storage must be supported by a valid tax invoice and e-way bill, and GST must be duly paid.
Similarly, when goods are returned from Haryana to Delhi, the transaction must be properly documented and taxed.
Supplies made within Haryana (from the Haryana warehouse to customers in Haryana) are treated as intra-State supplies, attracting Haryana CGST + SGST.
Under Section 10(1)(a) of the IGST Act, 2017, the place of supply for goods involving movement is where the movement of goods terminates for delivery.
*3. Distinct Person Concept for Multi-State Operations*
Under Section 25(4) of the CGST Act, 2017, business establishments in different States under the same PAN are treated as distinct persons.
Hence, movement of goods between such registrations (e.g., Delhi and Haryana) constitutes a taxable supply and must be invoiced accordingly.
The Haryana registration will be treated as a separate taxable entity, with its own compliance obligations — including return filing, maintenance of records, and payment of taxes.
*4. Place of Business and Place of Supply Clarifications*
If goods are supplied from a warehouse in Haryana to customers located within the same State, the transaction is intra-State and attracts CGST + SGST of Haryana.
The warehouse, in this case, is not merely a storage point but a place of business under GST law.
Registered persons must also comply with Section 35 of the CGST Act and Rule 56 of the CGST Rules, 2017, which require proper maintenance of stock records and documentation at each registered place of business.
*5. GST on Cold Storage and Related Services*
Cold storage services are classified as services related to immovable property. As per Section 12(3) of the IGST Act, the place of supply for such services is the location of the property itself.
Therefore, GST on cold storage services located in Haryana would be payable as CGST + SGST (Haryana).
When goods are supplied from Haryana to other States, the nature of supply (intra-State or inter-State) will depend on the destination, and GST (IGST or CGST+SGST) must be levied accordingly.
