GST, CBIC Letter Dated 25/09/2025 – CBIC clarifies Place of Supply Rules for Goods Stored in Third Party Warehouses 

The clarification confirms that if a business entity, whose principal place of business is in Delhi, uses a warehouse or cold storage in Haryana to make taxable supplies to recipients, that facility in Haryana functions as a ‘place of business’ and necessitates a separate GST registration in Haryana. The fact that the cold storage is operated by a third party does not alter this requirement if supplies originate from that location. Furthermore, establishments in different states under the same PAN are treated as ‘distinct persons’, meaning the movement of goods between the Delhi and Haryana locations constitutes a taxable supply requiring a tax invoice and appropriate GST payment. Supplies made from the Haryana warehouse to customers within Haryana are treated as intra-State supplies and subject to Haryana’s CGST and SGST. 

(Link: CGST CBIC Letter Dated 25/09/2025)

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