TaxTMI 
TaxTMI 
TaxTMI 
All imports will be deemed as inter-State supplies for the purposes of levy of GST. IGST is leviable on imports in addition to other duties of customs. Full set-off will be available as ITC of the IGST paid on import on goods and services. The importers may have warehouses for storing the imported goods. The said ware house may be in the same State where the taxpayer is doing the business or in other State for the purpose of keeping warehouse and storing the goods imported. In this article the applicability of GST provisions to such warehouse keeping imported goods which is working in other State than the State in which the registered person is running business.
The GST Policy wing vide its F. No. CBIC-20016/75/2025-GST/1025, dated 25.09.2025 gave clarifications on requirement of GST Registration for importers storing goods in warehouses in other States.
Registration
Suppose the principal place of business of a registered person (importer) is placed in one State and the said registered person, being an importer and the imported goods are stored in cold storage, operated by a third party in another State from where the goods is dispatched to the consumers. Whether registration is required for such activities under the provisions of the CGST Act? The GST Policy wing clarified that according to Section 22 of the Act every person making taxable supplied from a State is liable to be registered in that State, if the aggregate turnover exceeds the prescribed threshold limit. The Policy Wing also analysed the provisions of Section 2(85) of the Act which defines the expression ‘place of business’. According to this definition the expression ‘place of business’ included any location from where business is ordinarily carried out, including ware houses and storage facilities.
The Policy Wing clarified that the goods are stored in other State and dispatched the goods to customers from there, the warehouse effectively functions are a place of business for making outward taxable suppliers. The fact that the ware house is operated by a third party does not alter the legal position if the supply originates from the said place.
The Policy Wing clarified that in such cases, the business entity is required to get GST registration in another State in which the ware house is located. All the provisions of GST Act shall apply mutatis mutandis to such supplies made from the other State.
Payment of tax
Suppose we consider the goods are transferred from the Delhi godown to cold storage facilities in Haryana, the movement of goods from Delhi to Haryana must be accompanied by a valid tax invoice along with E-way Bill. The GST shall also be discharged. Similarly, when the goods are returned from Haryana Ware house to Delhi the movement of such goods must be documented and taxed as per the provisions of the GST Act.
In case, the goods are supplied from the Haryana Ware house to consumers located in Haryana, the supply is treated as ‘Intra-State Supply’. The CGST and SGST are payable to such transactions. In case the goods are supplied from the Haryana Ware house to Delhi office or to the consumers in Delhi or the States other than the Haryana, IGST is to be payable since the movement of goods and between two States and the delivery of goods is happening in other State.
Distinct Person
Section 25(4) of the Act provides that a person who has obtained or is required to obtain more than one registration, whether in one State or Union territory or more than one State or Union territory shall, in respect of each such registration, be treated as distinct persons for the purposes of this Act. Where a business entity operates from warehouses in multiple States under the same PAN, then each such establishment is considered as Distinct Person and considered as a taxable person. The movement of goods between such entities amount to a supply and is liable to GST. Invoice shall be issued and the same is to be paid to the exchequer. Therefore, the warehouse, being a distinct person entails separate compliance obligations, such as filing returns, maintenance of records and discharge of tax liability in the respective State.
Place of Business and Place of supply
According to Section 10(1)(a) of the IGST Act, 2017 the supply involving the movement of goods, the place of supply shall be the location where the movement terminates for delivery. In the example shown above, the Delhi is the place of business. The warehouse is the place of business from where the taxable supplies are made. Therefore, the warehouse at Haryana is liable to be registered.
In addition to registration, the same is required to maintain proper records at each place of business, such as stock registers, records of inward and outward supplies and documentation of goods stored or moved.
GST on cold storage services and related services
The storage warehouses are classified as services involving immovable property and taxable accordingly. Section 12(3) of the IGST Act provides the place of supply for services directly related to the immovable property is the location of the property. CGST and SGST would apply if the transactions are done within Haryana. If the goods are dispatched from the warehouse to customers in other States, the place of supply is determined and tax is to be levied based on the origin and destination of the supply. The business entity shall ensure invoicing, documents and tax payment are aligned with the actual place of supply and registration status.