TaxTMI 
TaxTMI 
Dear Experts,
Good Evening!!
Kindly clarify whether TCS @0.075% is applicable on sale of goods w.e.f. 01.10.2020 in between branches having same single PAN but different GST numbers in various states. .
Thanks & Regards: G VENUGOPAL
TCS u/s,206C(iH) applicable for goods sale between branches having same PAN
14 Sep 2020 
2 Replies 
3015 Views Asked by
Tax Collection at Source may not apply to intra-PAN stock transfers between branches with same PAN but different GST registrations.
One expert view concludes that Tax Collection at Source does not apply to intra-PAN inter-branch movements of goods because they are stock transfers and not sales to customers; however, a contrasting observation highlights that stock transfer is not recognised in GST except where delivery is within the same GSTIN, meaning the characterisation and resulting TCS liability require further analysis. (AI Summary)
One expert view concludes that Tax Collection at Source does not apply to intra-PAN inter-branch movements of goods because they are stock transfers and not sales to customers; however, a contrasting observation highlights that stock transfer is not recognised in GST except where delivery is within the same GSTIN, meaning the characterisation and resulting TCS liability require further analysis. (AI Summary)