Introduction
In the modern-day business landscape, companies are setting up
their Head Office (HO) in one State and setting up various branch
offices (BO) all over India to operate their business efficiently.
Insofar as the GST law is concerned, such offices at different
States are considered as distinct persons and have different GST
registrations. In such a model, there exists a concept of
cost-centres where the common expenditure incurred at HO is
expensed and shared to the BOs. Distribution of input tax credit
(ITC) on such common expenditure is being done either through Input
Service Distributor (ISD) mechanism or by way of cross-charge.
Controversy
The industry has been perennially marred with the controversy of
distribution of ITC through ISD mechanism vis-à-vis cross
charge with the Revenue authorities questioning the manner of
distribution for each route. The GST Advance ruling authorities
have also pronounced contradictory rulings further complicating
