High Sea Sale & FTWZ imports exempt from CGST, SGST, IGST tax. ITC reversal exception. Inter-state supplies simplified.

The Authority determined that supplying imported goods on High Sea Sale basis or from Free Trade Warehousing Zone does not attract tax under CGST, SGST, or IGST Acts. Such transactions are exempt from ITC reversal, except for specific cases. Invoices can be issued from one office for inter-state supplies from different locations, and registration in states with FTWZ facilities is not required for inter-state supplies.

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Issues:
1. Determination of liability to IGST on supply of imported goods on High Sea Sale basis or from Free Trade Warehousing Zone (FTWZ).
2. Reversal of input tax credit if no IGST liability.
3. Qualification of invoice issuance from one office for supplies from FTWZ facilities.
4. Requirement of registration in states where FTWZ facilities are located.

Analysis:
1. The applicant sought clarification on the liability to IGST for supplying imported goods on High Sea Sale basis or from FTWZ. The Authority determined that such transactions fall under Schedule III of CGST/SGST Acts and do not attract tax under CGST, SGST, or IGST Acts. The value of these transactions is not considered as 'value of exempted supply,' as per the explanation to section 17(3) of CGST Act, thereby exempting them from ITC reversal.

2. In case of no IGST liability, the issue of reversing input tax credit was raised. The Authority ruled that no reversal of ITC is required for inputs, input services, and capital goods used for the aforementioned supplies, as they are not considered exempt supplies under Schedule III, except for Entry 5.

3. The applicant inquired about issuing invoices from their Hyderabad office for supplies from FTWZ facilities in Mumbai and Chennai. The Authority clarified that the place of supply is where the goods are located at the time of delivery to the recipient, making it an inter-state supply. Hence, the applicant does not need registration in other states to carry out such transactions.

4. Lastly, the question of obtaining registration in Maharashtra and Tamil Nadu, where the FTWZ facilities are situated, was raised. The Authority reiterated that registration in those states is not necessary as the supplier's location and the place of supply are in different states, constituting an inter-state supply, eliminating the need for additional registrations.

In conclusion, the Authority ruled that there is no liability to IGST on the mentioned transactions, no reversal of ITC is required, invoice issuance from one office suffices for inter-state supplies, and registration in states with FTWZ facilities is unnecessary due to the nature of the transactions.

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