The Finance Act 2024 introduced a game-changing requirement for businesses with multiple GST registrations under the same PAN: mandatory Input Service Distributor (ISD) registration from April 1, 2025. Previously optional, the ISD mechanism now becomes compulsory for any office that receives input services on behalf of multiple branches. Notification No. 16/2024-CT dated August 6, 2024 formalized this change, requiring businesses to register as ISD to distribute Input Tax Credit (ITC) across locations. This guide explains who must register, the benefits, compliance requirements, and step-by-step registration process.
What is an Input Service Distributor (ISD)?
- Definition: An office that receives tax invoices for input services on behalf of multiple GSTINs under same PAN
- Purpose: Facilitates distribution of ITC on common services (rent, IT services, consulting) to branches
- Legal basis: Section 20(1) of CGST Act, made effective from April 1, 2025
- Example scenarios: Head office paying rent for branch offices, centralized IT services, group insurance premiums
- Key limitation: ISD mechanism applies only to services, not goods (inputs or capital goods)
Who Must Register as ISD from April 1, 2025?
- Mandatory requirement: Any business with multiple GSTINs under same PAN
- Head office scenario: HO receives invoices for services used by branches
- Branch network: Chain stores, manufacturing units, regional offices
- No turnover threshold: Mandatory regardless of aggregate turnover
- Exemptions: Single GSTIN businesses, businesses receiving only goods (not services)
- Check your status: If you have multiple GSTINs and receive common service invoices, ISD is mandatory
Benefits of ISD Registration
- Centralized ITC management: Simplifies credit distribution across multiple locations
- RCM ITC distribution: New provision allows distribution of reverse charge ITC (previously restricted)
- Compliance efficiency: Streamlines reporting for multi-location businesses
- Proper ITC utilization: Ensures credits reach the branches that need them
- Audit clarity: Clear documentation trail for ITC distribution
- Tax optimization: Prevents ITC lapse or under-utilization
Legal Framework and Timeline
- Finance Act 2024: Section 148A amendments introducing mandatory ISD
- Notification No. 16/2024-CT: Dated August 6, 2024, operationalizing ISD requirement
- Effective date: April 1, 2025 (start of FY 2025-26)
- Section 20(1) CGST Act: Specifies ISD registration and distribution requirements
- Grace period: No grace period; compliance expected from April 1, 2025
How ISD Mechanism Works
- Step 1: ISD office receives tax invoice for input services (e.g., rent, IT services)
- Step 2: ISD distributes ITC to recipient branches based on defined formula (pro-rata or as per usage)
- Step 3: ISD files GSTR-6 by 13th of following month, declaring ITC distribution
- Step 4: Recipient branches view distributed ITC in auto-generated GSTR-6A
- Step 5: Branches claim ITC in their monthly GSTR-3B returns
- Distribution formula: Proportionate to turnover, headcount, or actual usage (must be documented)
ISD Registration Process: Step-by-Step
- Step 1: Log in to GST portal with existing GSTIN credentials
- Step 2: Navigate to Services > Registration > Amendment of Registration Core Fields
- Step 3: Fill GST REG-01 form, select ISD status in Serial No. 14
- Step 4: Provide details of recipient GSTINs (branches that will receive distributed ITC)
- Step 5: Upload required documents (authorization letter, address proof of ISD office)
- Step 6: Submit application and await approval (ARN generated)
- Step 7: GST Officer reviews and approves ISD status
- Step 8: ISD registration effective; GSTIN updated with ISD designation
- Timeline: Typically 7-15 working days for approval
GSTR-6 Filing Requirements
- Monthly return: ISD must file GSTR-6 by 13th of following month
- Contents: Details of input services received, ITC available, ITC distributed to each recipient GSTIN
- No payment required: GSTR-6 is informational return, no tax payment
- Late fee: Rs 100 per day (Rs 50 CGST + Rs 50 SGST) for delayed filing
- TallyPrime support: Configure ISD in TallyPrime to auto-generate GSTR-6
- Reconciliation: Recipient branches must verify GSTR-6A matches ISD distribution
RCM ITC Distribution: New Provision
- Game changer: ISD can now distribute reverse charge mechanism (RCM) ITC
- Previous restriction: ISD could not claim or distribute RCM ITC, creating compliance gaps
- Applicability: Services like GTA, advocate fees, director remuneration paid by ISD office
- Compliance simplification: Centralized RCM payment and ITC distribution
- Example: Head office pays advocate fees under RCM, distributes ITC to branches that used legal services
Consequences of Non-Compliance
- Penalty risk: Failure to register as ISD may attract penalties under GST Act
- ITC disallowance: Excess ITC claims by branches without proper ISD distribution can be recovered
- Interest liability: Section 50 interest on erroneous ITC claims
- Audit exposure: Increased risk of GST audits and scrutiny
- ITC reversal: Mismatches in ITC claims can trigger reversal demands
- Operational disruption: Delayed ITC availability affects working capital
ISD Configuration in TallyPrime
- Enable ISD feature: F11 > Statutory & Taxation > Enable Input Service Distributor
- Create ISD voucher type: For recording ITC distribution entries
- Define recipient GSTINs: Configure branch locations in company master
- Distribution formula setup: Pro-rata by turnover or custom allocation
- Auto-generate GSTR-6: Use TallyPrime's GST compliance features
- Track distributed ITC: Monitor ITC flow from ISD to recipient branches
- Reconciliation: Match ISD distribution with branch GSTR-6A and GSTR-3B
Best Practices for ISD Management
- Document distribution formula: Maintain clear methodology for ITC allocation
- Centralize service procurement: Route common services through ISD office
- Monthly reconciliation: Verify ISD distribution matches recipient claims
- Maintain registers: ISD should keep detailed ITC distribution register
- Train accounts teams: Ensure ISD office and recipient branches understand the process
- Leverage technology: Use TallyPrime or ERP systems to automate ISD accounting
- Compliance calendar: Track GSTR-6 due dates to avoid late fees
Confused about ISD registration or need help setting up ITC distribution workflows? Mark IT Solutions specializes in multi-location GST compliance and TallyPrime implementation. Our team can handle your ISD registration, configure TallyPrime for automated GSTR-6 filing, and train your staff on the new requirements. Contact us for expert ISD setup and support.