Mandatory ISD Registration from 1st April 2025

Mandatory registration as an Input Service Distributor (ISD) is required for all entities that have more than one GSTIN based on a single PAN effective 1st April 2025. ISD registration was previously optional, but it is now mandatory as per the new GST amendment. This amendment aims to facilitate the distribution of Input Tax Credit (ITC) while ensuring compliance and allowing credit management for entities with multiple branches. Companies receiving standard input service bills at a head office and distributing ITC to multiple branches will be most affected. To comply, they must pre-register as ISDs, establish proper ITC distribution processes, and ensure effective compliance practices from the start.

Understanding Input Service Distributor (ISD)

An input service distributor is an office of the business that receives tax invoices for input services and distributes the available input tax credit (ITC) to related branches or units having separate GSTINs but using the PAN of that business.
Distributing Input Tax Credit The input tax credit (ITC) available for distribution in every month has to be distributed in that month itself and to be reported in Form GSTR-6. Furthermore, the ISD must distribute every tax credit arising from payments made under the reverse charge mechanism under Sections 9(3) and 9(4) to the respective recipients. If the input service is availed only by one recipient, input tax credit should be distributed to that one recipient only. To distribute the available tax credit among multiple recipients who use the input services, they must do so in proportion to their turnover.

The distribution has to be done,
ITC to Branch = (Branch Turnover / Total Turnover) x Total ITC
Branch Turnover =  turnover, as referred to in section 20, of person R1 during the relevant period
Total Turnover = the aggregate of the turnover, during the relevant period, of all recipients to whom the input
service is attributable in accordance with the provisions of section 20
Total ITC = the amount of credit to be distributed.
XYZ Ltd. is a company with its head office in Mumbai (ISD) and branch offices in Delhi, Bangalore, and Chennai.
The Mumbai head office receives an invoice from an advertising agency for ₹1,00,000 + 18% GST (₹18,000 GST Credit). This advertisement benefits all three branches, so the ITC needs to be distributed proportionately.

Turnover of Branches:

ITC Distribution Calculation:

Since the ITC of ₹18,000 needs to be distributed based on turnover, the allocation is:

BranchTurnover (₹)Share (%)ITC Distributed (₹)
Delhi10,00,00050%₹9,000
Bangalore5,00,00025%₹4,500
Chennai5,00,00025%₹4,500
Total20,00,000100%₹18,000


Financial Risks of Non-Compliance with ISD Rules-

Failure to comply with Input Service Distributor (ISD) rules poses significant financial and operational risks to business organizations. Non-compliance with ISD protocols would deny branches any allowable Input Tax Credit (ITC) for general services, which would only increase tax cost. Similarly, errors in ISD and/or mismatches of ITC in Goods and Services Tax (GST) returns would increase the likelihood of receiving a GST notice, or auditing, and/or potential penalties.

Non-compliant businesses face increased scrutiny from tax authorities due to uncertainty in ITC apportionment, raising the risk of financial liabilities. The cost of ITC would be much more significant if taxpayers could claim benefits for any Reverse Charge Mechanism (RCM) transactions prior to April 2025, which leads to additional taxes being paid. However, this holds true if the company ensures satisfactory ISD compliance, properly apportions the ITC between branches, reduces compliance risks, and results in lower taxes with a clear flow of ITC. It also supports claiming ITC based on RCM, subsequently after April 2025, improving cash flow for the company's overall improved tax efficiency. To reduce tax litigation and financial losses, companies must value their ISD compliance and ensure proper ITC disbursement.

Conditions to be Met by an Input Service Distributor (ISD)

Registration:

An Input Service Distributor (ISD) is required to separately register as an "ISD" in addition to their regular GST registration. When applying through REG-01, the taxpayer will have to indicate ISD registration at serial number 14. Under the law, only upon making that declaration is the ISD permitted to distribute Input Tax Credit (ITC) to its recipients.

Invoicing :

Raise ISD invoices while disbursing ITC to respective units or branches.

Filing of Returns:

The returns will be filed on a monthly basis in GSTR-6 on or before the 13th of the ensuing month reporting the ITC paid out.

Returns:

The total tax credit paid out by the aggregators should not exceed the available tax credit at the end of the relevant month.

Filling :

ISD has to report the remitted ITC in GSTR-6, to be filed by 13th of next month.

Consequences of Not Registering as an Input Service Distributor (ISD)

From April 1, 2025, companies that do not register as an Input Service Distributor (ISD) can encounter various difficulties, including legal and monetary penalties:

Penalties and Interest

 Failure to comply with obligatory ISD registration can invite penalties for improper distribution of Input Tax Credit (ITC). If ITC is claimed in excess, tax officials can recover it from the recipient along with interest under Section 21 of the GST Act.

Increased GST Audits and Scrutiny

Companies that are not registered under ISD are prone to audits and investigation by the tax department. Discrepancies in the claim of ITC can invoke in-depth inquiry, resulting in legal issues.

ITC Reversal and Cash Flow Interruptions

Incorrect or non-registered ISD operations might lead to ITC claim reversal. This makes branches pay tax directly rather than availing eligible ITC, affecting cash flow and working capital management.

Tax Notices and Financial Burdens

Mistaken ITC claims at the head office without ISD registration can result in tax notices. These notices can translate into extra financial burdens and operational interruptions.

Operational Inefficiencies and Credit Allocation Problems

In the absence of an appropriate ISD mechanism, companies might find it difficult to distribute ITC effectively among various branches. This can lead to credit distribution disputes and financial management inefficiencies.

The entity must obtain a separate registration as an ISD, even if it has a normal GST registration.

Step-by-Step ISD Registration Process

  • Step 1: Access the GST Portal
  • Step 2: Navigate to Registration Application
  • Step 3: Fill Part A of Form GST REG-01
  • Step 4: Fill Part B of Form GST REG-01
    Details of Promoters/Partners:
    Authorized Signatory:
    Bank Account Information
  • Step 5:  Upload Required Documents
    a. Proof of Constitution of Business
    b. Proof of Principal Place of Business
    c. Identity and Address Proofs of Promoters/Partners
    d. Bank Account-Related Proof
    e. Photograph of Promoters/Partners
    f. Letter of Authorized Signatory in case of partnership firm, company, HUF, etc.
    g. DSC in applicable cases like company , etc.

CONCLUSION

We at BMA take satisfaction in streamlining tricky tax regimes, and if each person is best proper to showcase this, it's far the Input Service Distributor (ISD) device beneath GST. Compliance calls for a painstaking recognition on detail, consistency, and a clear information of the way to distribute enter tax credit (ITC) between divisions. That's wherein we step in. We provide full support for businesses with ISD registration, compliance setup, and monthly return filings. Our strong approaches ensure that we assign ITC appropriately and fairly at locations, preventing mistakes, loss of credit, and undue notices from the tax department. Whether you have a decentralized headquarters or are a large company with decentralized operations, we streamline ISD management to ensure your tax credits are compliant and optimized.

With us on your side through BMA , you can cast off tax monitoring issues and cognizance at the boom of your enterprise, as we deal with your ISD requirements with accuracy and on time.    

Disclaimer

The above is general information. Material on this site is for general information purposes only. Readers are advised to consult a professional tax consultant before making any tax decision. Despite the exercise of care in updating information, BMA cannot be held liable for error or omission or loss arising from use of such information

Implementation of Mandatory HSN Codes in GSTR-1 & GSTR-1A

What You Need to Know

From January 2025, GSTN started phasing in the implementation of mandatory HSN codes in Table 12 of both GSTR 1 and GSTR 1A. It is a step based on the correct reporting of tax that has minimal human errors and simplifies compliance for businesses across the nation.

Below is a blog that has broken down what HSN codes are, change that has been introduced in Phase III, and compliance steps that need to be followed by businesses in India.

What Are HSN Codes and Why Are They Important?

It is, in fact the Harmonized System of Nomenclature, or HSN-an internationally accepted classification of goods and services. It classifies products or services with a unique numerical code, thereby standardizing trade and tax systems.

HSN is important for Goods and Services Tax in India in the following manners:

The implementation of HSN codes must be done correctly, and GST registered entities should cover it.

Phase III Implementation: Key Changes

GSTN has brought phase III in the process of reporting of HSN Codes in GSTR -1 and GSTR-1A. Here are the critical changes in the same:

  1. Segmentation of Table 12
    • Table 12 divided into two heads:
      • B2B Supplies: Business-to-business.
      • B2C Supplies: Sales to consumers.
    • Separation gives clear clarity and easy reporting of supplies.
  2. Validations Rules of Supplies and Value of Taxation
    • These supplies and taxation reported values have the new validations developed which cross-matching will happen on this reported value of supplies.
    • The business must complete the submission during this time period, so the rule will initially serve as a warning due to the mismatching.
  3. Features associated with the upgraded user
    • Download HSN Code List now with a new button whereby taxpayers can download the latest HSN and SAC codes along with descriptions in the Excel format.
    • My Master now facilitates search on product descriptions, making it easy to decide which HSN codes to use.

Change in Detail

  1. Verification for B2B Supplies
    • Verification rules will be applicable on tables like:
      • 4A, 4B, 6B and 6C for registered recipient.
      • 9A, 9B, and 15A for Exports or to registered recipient. 
    • This verification is an adjustment of tax values with correct tax amount.
  2. Verification in B2C Supplies
    • We will verify the non-registered recipient on the table such as.
      • 5A, 6A, 7A, and 7B. Domestic Supplies for non-registered recipient.
      • 9A (Ex) and 10 or 15 for unregistered recipient.

Addressing Amendments

If they conduct a revaluation, they will compare it based on differential value to eliminate the reuse of similar data.

Business Implication

Phases III Changes to GST registered will have more substantial effects for tax payers as follows -What Businesses should know:

Benefits of the new system
Challenges to be Overcome

Steps to comply with Phase III

To align the business to the new needs and ensure compliance, the businesses need to do:

  1. Study the Advisory
    • Read the official advisory given by GSTN in detail and understand what is changed and its implications.
    • The complete guidance is available on the GST portal that can be referred to.
  2. Accounting System
    • Check whether your accounting and billing software has the facility of dropping down the codes of HSN.
    • If yes then collaborate with the software vendor also to make the changes
  3. Train Your Employee
    • Train those employees who are handling GST return, which will file returns along with new updations.
    • Completely educate them about the drooping system as well as newly implemented validation rule and all change
  4. Validation Warnings Monitoring
    • Develop a procedure in order to trace the validation warnings that are arising while filing of returns.
    • Clear up the mismatches at once so no further penalties should arise.

FAQs on HSN Code Implementation

Q1: Will the validation warnings prevent the returns from being filed?

No, in the initial days, the validation warnings will not stop the filing of returns. However, the business needs to correct the warnings so as not to incur improper compliance in the future.

Q2: How can I get the new list of HSN codes?

You can download the latest HSN and SAC codes from the GST portal by clicking on the "Download HSN Code List" button on Table 12.

Q3: Is the drop-down selection compulsory for all taxpayers?

No, HSN code entry cannot be done manually. All the taxpayers must choose the appropriate HSN codes available in the list.

Why Compliances Are Important

In case of non-compliance with the latest rule, among other issues, the following may be faced:

Companies can avoid such issues and maintain smooth compliance with GST regulations by raising awareness and taking proactive measures.

Conclusion
The introduction of HSN codes in GSTR-1 and GSTR-1A in Phase III is a major step toward the betterment of GST compliance and accuracy. Mandatory drop-down selection, validation rules, and enhanced features make the process easy for businesses and promote transparency in taxation.
For that, companies should update their systems, train the teams, and be vigilant for validation warnings. Need help?
Contact Book My Accountant for expert assistance with GST compliance, tax planning, and more. Together, let's simplify your tax journey!

Book My Accountant

TDS on Metal Scrap under GST: A Complete Guide

The Indian government has brought into effect new TDS provisions under the framework of Goods and Services Tax-specifically targeting all transactions in the form of metal scrap. With effect from 10 October 2024, these rules are aimed at improving tax compliance and transparency in the scrap materials sector. Let us dive into this and see what it will mean for the businesses buying and selling metal scrap.

What is TDS in GST for Metal Scrap?

TDS is a mechanism where tax is deducted at source at the time of making payment to the seller. Based on the latest GST rules, businesses, whose subject of business is procurement of metal scrap, are dutifully liable to deduct TDS at the time of entering into qualifying transactions.

And the transactions which attract TDS are under Chapter 72 to Chapter 81 of the Customs Tariff Act 1975, which comprises of:

Important Provisions of the TDS Rule

TDS shall apply on metal scrap under GST if the aggregate value of supplies exceeds ₹2,50,000 per transaction. The taxable value of scrap material will be deducted for deduction, and not the total invoice value.

Rate of deduction is provided as 2%, split as below:

Who must deduct TDS?

The Ministry of Finance issued Notification No. 25/2024-Central Tax on October 9, 2024, amending the earlier Notification No. 50/2018-Central Tax to clarify the Tax Deduction at Source (TDS) provisions under Section 51 of the CGST Act, 2017. Section 51 of the CGST Act 2017 deals with the mechanism of Tax Deduction at Source (TDS).

TDS provisions under Section 51 of the CGST Act shall not apply to the supply of goods or services between certain categories of persons specified in clauses (a), (b), (c), and (d) of sub-section (1) of Section 51 except for those specified in clause (d).

Process for becoming compliant

If you are a buyer dealing with metals scrap, here is what you need to do to become compliant with the new GST rules:

Obtain a Separate GST Registration

The buying party would be required to apply for a separate GST registration under REG-07 in order to start deducting TDS. Subsequently, the buyer can claim TDS on eligible transactions with which they will have to file a return month under Form GSTR-7. Simultaneously, the system generates a certificate of TDS, just like Form 16A under the Income Tax Act, after filing GSTR-7.

File Monthly Returns

The buyers who deduct TDS are liable to file GSTR-7 for the month. The return should be filed by the 10th of the next month where a payment liability will arise along with the return filing. This return should state the amount of TDS deducted.

Provide TDS Certificates

Once the return is filed by the purchaser, he shall issue the TDS certificate, GSTR-7A, to the supplier. Therefore, he would get the TDS credit to his ledger of cash at the end of every month.

TDS not Applicable in Respect of Metal Scrap

It is another important aspect that TDS under GST is not levied upon importing the metallic scraps. It does not draw any TDS deduction under such rules if the buyer imports scraps from abroad.

Conclusion

The introduction of TDS on metal scrap under the GST is perhaps a landmark to ensure better tax compliance in the industry. With the above move, the government has consequently mandated 2% TDS on all transactions, with an element of transparency and accountability that can be availed by the suppliers in due time.

Ensure your business is GST compliant with these new provisions by registering for GST TDS and the timely returns filing, contact Book My Accountant today for help with GST registration, TDS filing, and much more in accounting.

Strengthening the GST System: India's Second All-India Drive Against Fake GST Registrations

India’s GST is a key part of the tax system, aiming to unify indirect taxes effectively. However, some of the challenges have been fraudulent activities especially the abuse of GST registration. CBIC launched a drive to combat fake GST registrations, protect revenue, and fortify the GST system.

Identifying Fake GST Registrations

There are also fake GST registrations which are very dangerous since they affect the credibility of the GST system. The dishonest players get fake GST Identification Numbers (GSTINs) to commit tax fraud and falsely claim input tax credit. These actions impact the revenue and at the same time burden the honest taxpayers.

The CBIC, in consultation with the Directorate General of Analytics and Risk Management (DGARM), has a comprehensive strategy in place to track down and neutralize these fake GSTINs. New age data analytics and risk parameters identify suspicious GST numbers sent to tax departments for confirmation.

The Role of the GST Portal

The GST portal is very useful in registration as well as the monitoring of the whole process. You can use this channel to manage GST registration, check your application status, and access necessary tax details. Many fake registrations have been reported, resulting in strict verification procedures on the GST website. Tax officers are using the GST portal during this drive to verify GST numbers and registration compliance of genuine businesses.

Actions Against Fraudulent GSTINs

When fake GST registrations are identified, appropriate action is taken against them. Entities can be suspended or cancelled in their GST registration by the tax authorities if they are found to be committing fraud. They can suspend the input tax credit and reclaim any erroneously availed credit as well. Anyone who tries to misuse the GST system is immediately stopped.

Another essential part of this drive is the crackdown on the e-way bill system. Inter-state transportation requires the generation of the e-way bill through the GST portal, which is mandatory. From the analysis of e-way bills, tax authorities can also get additional information and prevent the abuse of GST registration.

Monitoring and Reporting

This drive must therefore have a sound monitoring and reporting system that can enhance its success. The GST Council Secretariat compiles weekly reports on identified tax evasion cases and activities leading to recoveries. An approach like this allows you to track progress and keep the drive from being deflected.

Special GST Drive Guidelines

Tax officers will visit registered businesses from August 16 to October 31, 2024, as part of a GST drive. Businesses are advised to take the following actions to ensure compliance:

  • Disclose all additional places of business.
  • Keep proper and updated records of all transactions, including purchase and sale invoices, consignment notes, and e-way bills.
  • Reconcile stock and cash balances regularly.
  • Maintain all bill books, vouchers, and documents in an organized manner.
  • Prominently display the GST registration certificate at every place of business, including godowns.
  • Complete bank authentication and KYC verification on the GST portal.
  • Place signboards properly at every location.

Conclusion

The second All-India drive against fake GST registrations is evidence of the Indian government’s seriousness towards maintaining a proper tax regime. This initiative proposes the use of the GST portal in protecting government revenue and the integrity of the GST system through data analytics. The government has called on business organizations to observe the GST laws by registering their GST number and other tax details. This drive is not merely to punish the offenders but also to build confidence in the Indian taxation system.

At Book My Accountant (BMA), we understand the complexities of the GST system and the importance of compliance. Experienced professionals on our team provide comprehensive GST consultancy services, ensuring that your business stays compliant with all regulations. From GST registration to ongoing compliance checks, BMA is your trusted partner in navigating the intricacies of the Indian tax system. Contact us today to learn how we can support your business in this crucial All-India drive against fake GST registrations.