Clarification on Requirement of Separate GST Registration for Warehouses in Other States

17Oct 2025 by admin

Issued by: CBIC, GST Policy Wing 

F. No.: CBIC-20016/75/2025-GST/1025 

Date: 25th September 2025 

Background 

CBIC received representations regarding whether importers or traders having their principal place of business in one State (e.g., Delhi) but storing goods in warehouses or cold storages in another State (e.g., Haryana) are required to obtain separate GST registration in that other State. 

After examination of the provisions under the CGST Act, 2017 and IGST Act, 2017, the following key clarifications have been issued. 

  1. Requirement of GST Registration in Another State 
  • Under Section 22 of the CGST Act, 2017, every person making taxable supplies from a State must be registered in that State once the turnover threshold is crossed. 
  • The term “place of business” under Section 2(85) includes any warehouse, godown, or premises where goods are stored or supplied from. 
  • Therefore, if goods are stored and dispatched from a warehouse in another State (even if operated by a third party), such warehouse becomes a “place of business”, and registration in that State is mandatory. 
  • Example: If a Delhi-based entity stores and sells goods from a Haryana warehouse, it must obtain GST registration in Haryana. 
  1. GST on Movement of Goods Between States 
  • Transfer of goods from Delhi to Haryana warehouse must be supported by a valid tax invoice and e-way bill. 
  • When goods return from Haryana to Delhi, similar documentation is required. 
  • Supplies made from the Haryana warehouse to customers within Haryana will be treated as intra-State supplies, attracting CGST + SGST (Haryana). 
  • Place of supply is determined as per Section 10(1)(a) of the IGST Act, 2017 — where the movement of goods ends for delivery. 
  1. Distinct Person Concept under Section 25(4) 
  • When the same PAN has registrations in multiple States, each registration is treated as a distinct person. 
  • Movement of goods between such distinct persons (e.g., Delhi to Haryana) is considered a supply liable to GST, even without consideration. 
  • A tax invoice must be raised, and GST paid (CGST + SGST of the recipient State). 
  • The warehouse in Haryana will have independent compliance obligations — return filing, record maintenance, and tax payment. 
  1. Place of Business and Record Maintenance 
  • The warehouse in another State is a place of business from which taxable supplies are made. 
  • Accordingly, the entity must register and maintain records as required under Section 35 of the CGST Act and Rule 56 of the CGST Rules. 
  • Stock registers, inward and outward supply records, and documentation for goods movement must be maintained at each place of business. 
  1. Cold Storage Services and Place of Supply 
  • Cold storage services are treated as services related to immovable property. 
  • Under Section 12(3) of the IGST Act, the place of supply for such services is the location of the property (warehouse). 
  • Hence, GST on storage services in Haryana will attract CGST + SGST (Haryana). 
  • For onward supply of goods from the warehouse, the applicable tax (IGST or CGST+SGST) will depend on origin and destination of the supply. 

Conclusion 

  • Separate registration is mandatory in every State from which taxable supplies are made, even if the warehouse is managed by a third party. 
  • Each such warehouse becomes a distinct taxable person under GST law. 
  • Businesses must ensure proper invoicing, e-way bill generation, and record maintenance for goods transferred and supplied through such facilities.