GST Input & GST Output in same company with two different GSTIN

This query is : Resolved

Sanjay Sharma (Querist)
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08 May 2025 Dear Experts,
We have a company registered in Delhi having its GSTIN in Delhi & Mumbai. company dealing in services. Should company take purchase bills (input gst) in mumbai GST Registration for particular service "A" and Sold this particular service "A" from Delhi GST Registration. If yes, is there any issue raised while going for GST Refund or any other issue raised in future for these adjustments.
Thanks in advance

CA R SEETHARAMAN

CA R SEETHARAMAN (Expert)
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09 May 2025 Yes, but in GST Act, the services provided by Hotels, Exhibitions etc., from the same state alone eligible for ITC and if issued from other state where the PoS is different from your base location the ITC becomes ineligible.

Sanjay Sharma

Sanjay Sharma (Querist)
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10 May 2025 Thanks for your valuable reply.
It means, if the services relates to music & film industry than we can do this practice.
please also clear should we swicth our ITC from one state to other state in same company?

Aashok Kumar Sharma

Aashok Kumar Sharma (Expert)
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12 August 2025 . Separate GST Registrations — Separate Entities for GST purposes
Each GSTIN under the same PAN is treated as a separate taxable entity for GST compliance.

Input Tax Credit (ITC) availed on purchases under one GSTIN cannot be automatically utilized against output tax liability of another GSTIN.

ITC is restricted to be utilized only against output liability of the same GSTIN where input credit was availed.

2. Purchases and Sales from Different GSTINs
If you purchase services under Mumbai GSTIN (input GST charged there), and

You sell those services from Delhi GSTIN (output GST charged under Delhi GSTIN),

Then ITC on purchase from Mumbai GSTIN cannot be claimed/utilized against output liability of Delhi GSTIN.

3. Place of Supply (PoS) Considerations
For services, Place of Supply (PoS) rules determine which state GSTIN the service is supplied from.

If PoS is in Delhi, output GST is payable under Delhi GSTIN.

If the purchase/service received is charged under Mumbai GSTIN, ITC is available only under Mumbai GSTIN, but cannot be transferred to Delhi GSTIN.

4. Implications on Refunds and Adjustments
No direct transfer or set-off of ITC between GSTINs.

If Delhi GSTIN has output tax liability but no corresponding ITC, they must pay GST accordingly.

Mumbai GSTIN can claim ITC and adjust output liability in Mumbai only.

No cross-utilization or switching ITC across GSTINs within the same company.

Refund claims must be made separately for each GSTIN based on input/output for that registration.

5. Special Cases:
Some sectors like export of services can claim refunds of unutilized ITC.

Services like music & film industry follow PoS rules, so ensure the PoS is correctly applied to determine which GSTIN invoices should be booked under.

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