Managing Multiple GST Registrations Under One PAN: Practical GST Guide

Goods and Services Tax is designed as a dual levy shared between the Centre and the States. While the Permanent Account Number (PAN) identifies the legal entity at the national level, GST registration is anchored to each State or Union Territory. As a result, a single legal entity may be compelled to maintain several GST registrations (GSTINs), with each registration treated as a separate “distinct person” under Section 25(4) of the CGST Act.

This framework has day-to-day implications for:

  • Whether and when to obtain registration in a new State
  • How to treat branch/stock transfers
  • Handling common input services and the mandatory Input Service Distributor (ISD) mechanism from 1 April 2025
  • Valuation and cross-charge between distinct persons
  • Application of PAN-based thresholds such as e-invoicing
  • Use of warehouses and temporary business places such as exhibitions

Recent statutory amendments and administrative developments—such as mandatory ISD, the new simplified registration route under Rule 14A, and the constitution of a CBIC working group for centralised administration—have reshaped the compliance environment for multi-State businesses. This article reorganises these developments and explains their practical impact for an assessee expanding or already operating across multiple States.

1. Core Registration Rule – State-wise GSTINs on an All-India Turnover

The starting point remains the statutory requirement to register in every State from which taxable supplies are made:

  • Section 22(1) of the CGST Act mandates registration in the “State or Union territory from where the taxable supply of goods or services or both is made”.
  • Section 25(1) further requires separate registration in each such State/UT where the assessee is liable.
  • Section 2(6) defines “aggregate turnover” on an all-India PAN basis. That means the registration threshold is tested on the combined turnover of all establishments under the same PAN, not State-wise in isolation.
  • Section 24 lists categories where registration is compulsory irrespective of turnover, subject to operative exemptions.
  • Under Section 25(4), every registered establishment with a separate GSTIN under the same PAN is treated as a “distinct person”.

Illustration
Consider Mr. Sharma, who runs a consulting office in Delhi and has opened a branch in Jaipur:

  • Delhi consultancy receipts: ₹15 lakh
  • Jaipur branch receipts: ₹8 lakh
  • Combined receipts under the same PAN: ₹23 lakh

Individually, neither location crosses ₹20 lakh, but the aggregate turnover exceeds the threshold. Mr. Sharma must therefore examine registration requirements in both Delhi and Rajasthan by applying Section 22(1) and Section 25(1) together with PAN-level aggregate turnover.

2. Compulsory ISD Mechanism From 1 April 2025

The Finance Act, 2024 introduced a significant shift by amending Section 2(61) (definition of Input Service Distributor) and Section 20 (ISD provisions). These amendments were brought into force from 1 April 2025 through Notification No. 16/2024–Central Tax.

Key change
An office that:

  • Receives tax invoices towards input services, and
  • Those services are used by one or more distinct persons (different GSTINs) under the same PAN,

is now required to obtain an ISD registration and distribute the corresponding input tax credit (ITC) in accordance with the ISD provisions. This obligation also includes specified input services under reverse charge, to the extent they are allocable to other GSTINs of the same assessee.

Illustrative scenario

A head office (HO) in Delhi receives a statutory audit invoice covering the entire company:

  • Audit invoice value: not relevant for distribution mechanics
  • GST charged: ₹1.8 lakh
  • Turnover of recipient registrations for the relevant period:
    • Delhi GSTIN: ₹50 crore
    • Maharashtra GSTIN: ₹30 crore
    • Karnataka GSTIN: ₹20 crore

Under Rule 39, the Delhi HO, registered as an ISD, must distribute the ITC in the same tax period in proportion to the turnover of the concerned recipient units:

  • To Delhi: ₹90,000
  • To Maharashtra: ₹54,000
  • To Karnataka: ₹36,000

The ISD will report the distribution in GSTR-6, and the respective units will receive the credit in their electronic credit ledgers. From 1 April 2025, this is no longer optional where the statutory conditions are met; it is mandatory compliance.

3. Fast-Track Registration Under Rule 14A Effective 1 November 2025

Notification No. 18/2025–Central Tax inserted Rule 14A into the CGST Rules, applicable from 1 November 2025. This provision creates a simplified and time-bound route for certain applicants meeting defined criteria.

Who can opt?

An applicant can choose this route in FORM GST REG-01 if:

  • The self-assessed output tax liability (excluding reverse charge) on supplies made to registered persons does not exceed ₹2.5 lakh per month, and
  • All other prescribed conditions are satisfied.

Key features of Rule 14A