ISD Compliance Under GST Mandatory w.e.f. 1st April 2025

With Notification No. 16/2024-Central Tax (dated August 6, 2024), the Indian government mandated the Input Service Distributor (ISD) framework beginning April 1, 2025. This change has a substantial impact on enterprises that receive common input service invoices from a central location and distribute Input Tax Credit (ITC) to various locations.

Businesses previously had the option of not registering as an ISD; but, with this update, any company receiving bills for shared services must comply or face ITC mismatches, penalties, and tax consequences.

This guide provides a full overview of the future changes, including the correct ITC distribution procedure, compliance techniques, and how firms should prepare before April 1, 2025.

What is ISD and Why is It Mandatory Now?

An Input Service Distributor (ISD) is a GST-registered firm that accepts input service invoices at its headquarters and distributes ITC to its branches based on turnover. This guarantees that firms do not wrongly claim ITC at a single location, but rather distribute it proportionally.

Key Changes in ISD Starting from 1st April 2025

• ISD registration has become mandatory for all firms that use common input services across numerous branches.
• Reverse charge ITC (RCM) can now be distributed through ISD, whereas previously ISD could not claim RCM ITC.
• Businesses who fail to comply with ISD guidelines will receive GST notices and penalties.

These changes will have an impact on enterprises across industries, particularly those in IT services, retail chains, consultancy firms, and multi-branch manufacturing.

Let’s Understand the Impact of ISD on Businesses with Example

ABC Ltd. is based in Bangalore and has operations in Mumbai, Chennai, and Delhi. The company receives a Rs.10 lakh software subscription invoice from a vendor.

Before 1st April 2025

• The headquarters claimed full ITC, despite the fact that the software was used throughout multiple sites.
• This resulted in tax discrepancies and probable GST audits.

After 1st April 2025

• XYZ Ltd. must register its headoffice as an ISD.
• The software vendor submits an invoice to the ISD GSTIN.
• The ITC must now be disbursed to branches based on their turnover proportion using ISD invoices.

This ensures that each branch receives its appropriate share of ITC, avoiding future tax disputes and financial penalties.

When ISD is Not Applicable?

Despite the new mandate regulation, ISD compliance is not applicable in certain cases.

• ISD cannot provide ITC for physical goods such as machinery, raw materials, or office equipment.
• ITC for such products must be claimed by the location where they are received.
• ISD cannot allocate ITC to companies that outsource their manufacture, shipping, or services.
• Until March 31, 2025, ISDs cannot claim ITC on reverse charge transactions.
• Starting in April 2025, RCM ITC can be distributed to GST-registered branches.

What Happens When Businesses Fail to Comply?

• GST discrepancies result in the rejection of ITC claims.
• Tax notices for improper ITC claims are issued at the headquarters.
• Cash flow concerns would arise as branches would be required to pay tax rather than use applicable ITC.

How to Distribute ITC Correctly Under the New ISD Rules?

Branch-Specific ITC: Amounts are allocated directly to the branch that used the service.

Multi-Branch ITC: Shared by a few select branches that used the service.

Common ITC: Used by all branches and requires proportional distribution.

Formula of ITC Distribution Under ISD

To avoid GST discrepancies, ITC must be allocated depending on the turnover ratio.

ITC to Branch = (Branch Turnover / Total Turnover) x Total ITC.

ISD Registration and GST Return Filing

Register as an ISD

• Apply for ISD registration using GST REG-01.
• Declare ISD status on the form using Serial No. 14.
• The GST portal creates a unique ISD GSTIN.
• Businesses can only utilise this GSTIN for ITC distribution.

Issue an ISD Invoice

• ISD has to issue an invoice to each branch for ITC distribution.
• Individual ISD invoices for CGST, SGST, and IGST are necessary.

File Monthly ISD Return (GSTR-6)

• ISD must submit GSTR-6 by the 13th of each month.
• Late filing incurs a Rs.50 per-day penalty.
• ISD must match the ITC in GSTR-6 to the supplier invoices in GSTR-2B.