A business with multiple GSTINs under the same PAN—branches, warehouses, project offices—operates as a set of “distinct persons” for GST purposes. From 1 April 2025, the amended ISD provisions require eligible common input-service credits received for distinct persons under the same PAN to be distributed through the Input Service Distributor mechanism, with ISD registration and GSTR-6 filing. Non-compliance can result in loss of credit, interest and penalty.
The ISD Transition
The business should identify the common input services—head-office rent, shared IT, management support, professional fees—and route the credit through the ISD. The ISD registration is separate from the regular GSTINs. The GSTR-6 distributes the credit to the recipient GSTINs in the prescribed ratio.
The Cross-Charge Reconciliation
Where a service is not a common input service but an internal cost allocation, the cross-charge analysis applies. The德里 High Court’s KEI Industries ruling permits zero valuation where full ITC is available. The business should map each inter-GSTIN transaction to the ISD route, the cross-charge route or a third-party supply.
The Return and Reconciliation Discipline
The multi-GSTIN business should reconcile the GSTR-1, GSTR-3B and GSTR-2B across all GSTINs, and should ensure that the ISD distribution ties to the recipient’s credit ledger. A mismatch across GSTINs is a common scrutiny trigger.
What the Consultant Does
The consultant assists with the ISD registration, the cross-charge mapping, the GSTR-6 filing and the multi-GSTIN reconciliation. The value is in the architecture that keeps the credit flow compliant after the April 2025 transition.
Call to Action: We advise multi-GSTIN businesses on ISD registration, cross-charge mapping and multi-state reconciliation. For a multi-GSTIN review, contact office@anujdesaiassociates.com, Ph No. 9619456656, Website https://anujdesaiassociates.com, LinkedIn linkedin.com/in/ca-anuj-desai-122547230.