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Implications of Non-Receipt of Common Service Invoices Under ISD Registration

Dipika Shetye

As per the ISD provisions, all invoices for common services—whether pertaining to eligible or ineligible ITC—must be received under the ISD registration. We kindly request you to inform us of the potential implications or consequences if such invoices are not received under the ISD registration and received on Normal Registration

Common Service Invoices Must Be Received Under ISD Registration per Section 20 and Rule 39 of CGST Act Under GST law, common service invoices must be received under the Input Service Distributor (ISD) registration as per Section 20 of the CGST Act and Rule 39 of the CGST Rules. Receiving such invoices under a normal registration instead of ISD registration constitutes a violation, potentially leading to denial or reversal of input tax credit (ITC). The credit must be distributed to multiple locations through the ISD registration, and failure to comply may result in audit scrutiny and litigation. While cross-charging from a normal registration to branches may be seen as a procedural lapse, it does not comply with prescribed rules and risks disputes with tax authorities. Expert consultation is advised to address and possibly rectify the issue. (AI Summary)
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