Reliance - Inter-state stock transfer
Facts
Inter-state stock transfer between units of same legal entity.
Issue
GST applicability on branch transfer.
Held
Inter-state branch transfers between distinct persons (each GSTIN treated as distinct under Section 25(4) of CGST Act) attract IGST; intra-state transfers between units of same GSTIN do not.
Ratio
Distinct person concept governs IGST applicability.
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