Clarification on Separate GST Registration in the State Where Goods are Stored in Cold Storage

The Key principle of obtaining registration under GST is the storage of goods. Wherever the goods are stored, the taxpayer is required to disclose such a place to the GST Authority in the form of Principal Place of Business or Additional Place of Business. Even if the goods are stored in multiple warehouses within the same state, all such locations should be disclosed as Additional Places of Business in the GST Registration.

Similarly, if the warehouses are located in different states, the taxpayer is required to obtain GST registration in such states for the purpose of storing goods. For the purpose of obtaining registration, such a warehouse can be declared as the principal place of business, or any other place can be obtained as the principal place of business.

In this area, the GST Authority received various representations regarding the requirement of obtaining GST registration where goods are stored in cold storage in other states.

In this regard, the Central Board of Indirect Taxes and Customs has issued a clarification regarding the requirement of obtaining GST registration where goods are stored in different warehouses vide circular No. CBIC-20016/75/2025-GST/1025 dated 25th September, 2025.

1. Requirement of Registration in Different States

• The primary concern is whether the taxpayer is registered in the state of Delhi and is required to store his goods in the cold storage available in the state of Haryana. 

• In such a case, the CBIC has clarified that the taxpayer is required to obtain GST registration in the state of Haryana.

• As per Section 22 of the CGST Act, 2017, every person making taxable supplies from a State is liable to be registered in that State, provided the aggregate turnover exceeds the prescribed threshold. 

• As per Section 2(85) of the Act, "place of business" includes any location from where business is ordinarily carried out, including warehouses and storage facilities.

• If the goods are stored in the state of Haryana and subsequently dispatched to the customer from such location, the warehouse effectively functions as a place of business for the purpose of making outward taxable supplies.

• The fact that the cold storage is operated by a third party does not alter the legal position if the supply originates from that location. 

• Therefore, in such a scenario, the business entity is required to obtain GST registration in the state of Haryana, and all provisions of the CGST Act shall apply mutatis mutandis to such supplies made from the State of Haryana.

2. GST Payment on Movement of Goods

• In above mentioned scenario, once the taxpayer obtains separate GST registration in the state of Haryana, all transfers of goods from the Delhi godown to cold storage facilities in Haryana, the movement must be accompanied by a valid tax invoice and e-way bill, and GST must be discharged appropriately. 

• Similarly, when the goods are returned from Haryana to Delhi, the movement shall again be accompanied by the same documents with applicable taxes.

• Further, on the supply of goods from the warehouse to customers located within Haryana, the supply shall be considered as intra-State and shall attract the CGST and SGST of Haryana. 

• For supplies involving movement of goods, the place of supply shall be determined as per Section 10(1)(a) of the IGST Act, 2017, i.e., the location where the movement of goods terminates for delivery. 

• Therefore, if the supply originates from Haryana state and terminates within Haryana, such supply shall be considered as an intra-State supply and shall be subject to CGST & SGST.

3. Distinct Person Status for Cold Storage

• As per Section 25 (4) of the CGST Act, establishments of a person in different States are treated as distinct persons for GST purposes. 

• Where a business entity operates from warehouses or cold storage facilities in multiple States under the same PAN, each such establishment shall be considered as a separate taxable person.

• Therefore, movement of goods between such establishments constitutes a supply and shall be liable to GST.

• Therefore, a tax invoice must be issued for such transfers, and applicable tax (i.e., IGST or CGST & SGST) shall be charged on the same.

• In the above-mentioned case, if the business entity is registered in the state of Delhi and goods are moved from Delhi to Haryana, such a transaction shall be considered as a supply between distinct persons, and GST shall be charged accordingly.

• The cold storage facility in Haryana, if used as a place of business for making taxable supplies, assumes the status of a distinct person under the GST law. 

• This entails separate compliance obligations, including filing of returns, maintenance of records, and discharge of tax liability in Haryana. 

• Therefore, the cold storage facility functions as a separate taxable entity for GST purposes, and the business entity must ensure full compliance with the provisions applicable to such registration.

4. Determination of Place of Business and Place of Supply

• The Place of supply is determined under Section 10(1)(a) of the IGST Act, which stipulates that for supplies involving movement of goods, the place of supply shall be the location where the movement of goods terminates for delivery.

• Therefore, on the supply of goods from the warehouse in Haryana, GST shall be charged in the following scenario:
  
  • Goods supplies to customers in Haryana: Intra-state Supply and CGST & SGST shall be charged;
  • Good supplies to customers in Other states: Interstate Supply and IGST shall be charged

• The warehouse in Haryana, in such cases, is not merely a storage point but a place of business from which taxable supplies are made.

• Accordingly, the business entity is liable to register in Haryana and comply with all GST provisions applicable to that State. 

• Further, as per Section 35 of the CGST Act and Rule 56 of the CGST Rules, 2017, every registered person is required to maintain proper records at each place of business, including stock registers, records of inward and outward supplies, and documentation of goods stored or moved.

5. GST on Cold Storage Services and Related Supplies

• The Cold storage services are classified as services involving immovable property and are taxable under GST. 

• As per Section 12(3) of the IGST Act, the place of supply for services directly related to immovable property is the location of the property. Therefore, CGST & SGST shall be applied on the invoice raised for the cold storage facility.

6. Practical issues:

6.1 Storing goods in different warehouses:

• Practically, every Dealer is required to store goods in multiple cold storage facilities as per the availability of space. Some warehouses may be used for temporary storage or storage of small quantities.
• As per the clarification issued, every place where goods are stored is considered a place of business.
• In such a case, it will be practically difficult for the taxpayer to add every warehouse in his Additional Place of Business.
• E.g., A taxpayer obtains GST registration in the state of Haryana and adds warehouse A as his place of business. But he may be required to store goods in multiple other warehouses, B, C, or D, in the same state, as per the circumstances. 
• It will be difficult to register every warehouse as APOB. 
• This provision shall create hurdles in carrying out business.

6.2 Storage for urgent purchases:

• In Cold storage, generally those perishable goods are stored that require urgent storage.
• If any goods are to be stored in any warehouse on urgent bases, then adding such a warehouse as APOB will take multiple days and may cause huge losses to the taxpayer.

6.3 Deletion of place of business:

• Similar to the addition of APOB in GST RC, deletion of the same is not an easy process.
• The Taxpayer will have a continuous job of adding any APOB or deleting APOB.

6.4 Multiple GST registrations at one place:

• Since cold storages store goods of various taxable persons, multiple GST registrations shall be registered at the same place of business and which will compromise the authenticity of taxpayers.

Conclusion

The CBIC's September 25, 2025, clarification is a timely reminder for businesses to align their operations with GST's territorial principles. Delhi-based entities using Haryana warehouses must prioritize separate registrations, proper documentation, and accurate tax payments to avoid liabilities. Further, the Government should consider the challenges associated with these processes and provide some solutions, such as automatic approval of additions and deletions of warehouses/ cold storages.