One PAN, Many GSTINs: Navigating Multi-State GST Registration

Summary: GST registration is State-specific even though aggregate turnover is calculated on an all-India PAN basis. A business operating from multiple States may therefore require separate GSTINs, with each registration treated as a distinct person under Section 25(4) of the CGST Act. This structure affects branch transfers, input tax credit, invoicing, e-invoicing and compliance. From 1 April 2025, the amended Input Service Distributor provisions require eligible common input-service credits received for distinct persons under the same PAN to be distributed through the ISD mechanism. Rule 14A, effective from 1 November 2025, provides a simplified registration route for eligible applicants whose self-assessed output tax liability on supplies to registered persons does not exceed ₹2.5 lakh per month, subject to prescribed conditions. Transactions between separately registered branches can constitute taxable supplies even without consideration, while Rule 28 governs valuation between distinct persons. ISD and cross-charge also serve different purposes: ISD deals with specified third-party input-service credits, whereas internally generated services between distinct persons require separate examination. PAN-level thresholds, including e-invoicing applicability, can also affect a newly registered branch from the outset. CBIC’s July 2026 working group is examining centralised administration of taxpayers having multiple GSTINs, but this does not presently replace State-wise GST registration. Until any new mechanism is notified, businesses should continue maintaining separate GSTIN-wise compliance and carefully review registration, stock transfers, ISD, cross-charge, valuation and ITC before expanding into another State.

Introduction

A trader in Delhi opens a godown in Haryana. A Bengaluru software company sets up a sales office in Pune. An online seller finds that the marketplace has moved its stock to a warehouse in Gujarat. Each of them must ask the same question: do we need another GST registration?

The answer is usually yes. GST is shared between the Centre and the States, so registration is linked to the State and not to the business as a whole. The PAN identifies the business; the GSTIN identifies it in a particular State. A company working in ten States may hold ten GSTINs, each with its own returns, ledgers and tax officer.

This “one PAN, many GSTINs” design has caused practical difficulty since 2017. Under the old Service Tax law, a service provider could take a single centralised registration. Under GST, the same business deals with several registrations, and questions on stock transfers, head office costs and common input tax credit (ITC) arise every month.

Recent developments have changed the picture. ISD registration became mandatory from 1 April 2025, a three-day registration route came into force on 1 November 2025, and in July 2026 CBIC set up a working group on centralised administration. This article explains what has happened and what it means in practice.

Part A: What Has Happened

1. The Basic Rule

Section 22(1) of the CGST Act requires registration in the State from where a taxable supply is made, and Section 25(1) requires it in every such State. Aggregate turnover under Section 2(6) is counted on an all-India PAN basis. Section 24 makes registration compulsory, regardless of turnover, for specified cases, subject to applicable exemptions. Under Section 25(4), each registration is a distinct person.

Example: Mr. Verma’s consultancy in Delhi earns ₹14 lakh and his Jaipur branch earns ₹9 lakh. Neither crosses the ₹20 lakh threshold alone, but the aggregate of ₹23 lakh does. He must examine registration liability in both Delhi and Rajasthan.

2. Mandatory ISD From 1 April 2025

The Finance Act, 2024 amended Sections 2(61) and 20, effective from 1 April 2025 through Notification No. 16/2024–Central Tax. An office that receives invoices for input services used by other GSTINs under the same PAN must now register as an Input Service Distributor (ISD) and distribute the credit. This applies to services, including specified services taxed under reverse charge.

Example: A Delhi head office receives an audit invoice carrying GST of ₹1.8 lakh for the whole company. Branch turnovers are ₹50 crore (Delhi), ₹30 crore (Maharashtra) and ₹20 crore (Karnataka). Under Rule 39, the ISD distributes ₹90,000, ₹54,000 and ₹36,000 respectively in the same month and files GSTR-6.

3. Simplified Registration Under Rule 14A

Notification No. 18/2025–Central Tax inserted Rule 14A with effect from 1 November 2025. An applicant whose self-assessed output tax on supplies to registered persons does not exceed ₹2.5 lakh a month can opt for it in FORM GST REG-01. After Aadhaar authentication and subject to the prescribed conditions, registration is granted electronically within three working days. The route is not available for more than one registration in the same State under the same PAN.

4. CBIC Working Group on Centralised Administration

By Office Memorandum F. No. 20019/2/2026-GST dated 18 July 2026, CBIC formed a working group to examine centralised administration of taxpayers having multiple GSTINs under one PAN across Central Tax jurisdictions, with its report due within 30 days. In September 2026, the press also reported a proposed single-State registration scheme for small e-commerce sellers. Neither proposal has been notified so far.

Part B: Implications

1. Separate GSTINs Still Mean Separate Compliance

The working group proposal concerns centralised administration, not a single national GSTIN. Until something is notified, each GSTIN must file its own returns and keep its own ledgers. Businesses should not plan around proposals.

2. Stock Transfers Are Taxable

Example: ABC Ltd. sends goods worth ₹10 lakh from Delhi to its Mumbai branch. Since separately registered establishments are treated as distinct persons under GST, the Delhi GSTIN must raise a tax invoice, generate an e-way bill where applicable and pay IGST of ₹1.8 lakh at 18%. Mumbai can claim the credit, subject to the ITC conditions, but the credit remains with that GSTIN until utilised. Under Rule 28, the invoice value is accepted as open market value where the recipient is eligible for full ITC.

3. ISD and Cross-Charge Are Different

ISD covers eligible input services bought from outside parties for or on behalf of distinct persons. Services generated by the head office itself, such as accounts or HR support, are handled through cross-charge principles. Circular No. 199/11/2023-GST clarifies that where the branch is eligible for full ITC, the invoice value is accepted as open market value, and the value may be deemed nil if no invoice is raised. The risk remains for hospitals, banks and others making exempt supplies, whose branches cannot claim full credit. For them, cross-charge can carry a real tax cost.

4. PAN-Level Thresholds Apply to Every New GSTIN

E-invoicing applies where the prescribed PAN-level aggregate turnover threshold is crossed. The present threshold is ₹5 crore, subject to notified exclusions. A new branch of an already covered business may therefore have to issue e-invoices from its first applicable B2B transaction.

5. Warehouses Count

Section 2(85) treats a warehouse as a place of business. An online seller whose own stock sits in a marketplace warehouse in another State needs to examine GST registration in that State. An “Additional Place of Business” can be added only within the same State.

Practical Queries

Query 1: We Provide IT Services From Noida to Clients Across India. Do We Need a GSTIN in Each Client’s State?

No. Registration follows the supplier’s place of business and the State from which the supply is made, not merely the location of customers. A Uttar Pradesh GSTIN is enough if there is no place of business requiring registration elsewhere, and inter-State supplies generally attract IGST subject to the applicable place-of-supply provisions.

Query 2: Can Surplus ITC in Our Delhi GSTIN Pay the Tax of Our Maharashtra GSTIN?

No. ITC cannot be transferred between GSTINs merely because they have the same PAN. However, specified balances in the electronic cash ledger can be transferred to another GSTIN under the same PAN through FORM GST PMT-09 under Rule 87(14), subject to the prescribed conditions, including absence of unpaid liability in the transferring GSTIN.

Query 3: We Are Taking a Stall at a 10-Day Exhibition in Another State. What Is Needed?

Registration as a casual taxable person may be required where taxable supplies are made in a State in which the person has no fixed place of business. The application must generally be made at least five days in advance. Under Section 27, registration is valid for up to 90 days, subject to the statutory conditions, and requires an advance deposit of the estimated tax liability.

Conclusion

Multi-State GST registration affects how a business moves goods, shares costs and uses credit. The basic rule has not changed since 2017: one PAN, separate GST registrations in States where registration liability arises, and each GSTIN treated as a distinct person.

What has changed is the system around it. Mandatory ISD means common service credits covered by the amended provisions must now be distributed formally. Rule 14A makes registration quicker for eligible small taxpayers. Circular No. 199/11/2023-GST has reduced the cross-charge valuation dispute for businesses with full ITC. The July 2026 working group shows that centralised administration of multi-GSTIN taxpayers is under consideration.

Until any new scheme is notified, businesses should keep each GSTIN fully compliant, record a consistent position on stock transfers and cross-charge, and apply PAN-level thresholds to every new registration. A short review before entering a new State, covering location, turnover, ISD and valuation, can help avoid penalties and blocked credit.

References

1. Central Goods and Services Tax Act, 2017: Sections 2(6), 2(61), 2(85), 20, 22, 24, 25, 27 and 49.
2. Central Goods and Services Tax Rules, 2017: Rules 14A, 28, 39 and 87.
3. Notification No. 16/2024–Central Tax dated 6 August 2024.
4. Notification No. 18/2025–Central Tax dated 31 October 2025.
5. Circular No. 199/11/2023-GST dated 17 July 2023.
6. CBIC Office Memorandum F. No. 20019/2/2026-GST dated 18 July 2026.
7. Press reports, September 2026, on the proposed single-State registration scheme for e-commerce sellers.

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Disclaimer: The views expressed are the personal views of the author and are for general information only. They do not constitute legal advice. The law is stated as on 1 October 2026.