FTWZ Sale Not Supply | No TN GST Registration Needed—AAR

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  • Last Updated on 17 July, 2025

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FTWZ GST registration

Case Details: West Pharmaceutical Packaging India (P.) Ltd., In re - [2025] 175 taxmann.com 1038 (AAR-TAMILNADU)

Judiciary and Counsel Details

  • B. Suseel Kumar & Balakrishna S., Member

Facts of the Case

The applicant, registered in Telangana under the CGST Act and the Telangana GST Act, is engaged in trading rubber stopper products for pharmaceutical use, imported through a Free Trade Warehousing Zone (FTWZ) located in Tamil Nadu, where the applicant has no business activity or presence. The applicant sold goods while they were lying in the FTWZ warehouse before clearance for home consumption. It was noted that ‘warehoused goods’ as specified in clause 8(a) of Schedule III of the CGST Act includes goods warehoused in an FTWZ. The applicant sought a ruling on whether such transactions attract Customs duty or IGST, and whether a separate GST registration is required in Tamil Nadu. The matter was accordingly placed before the AAR Tamil Nadu.

AAR Held

The AAR, Tamil Nadu, held that the sale of goods while lying in the FTWZ warehouse before clearance for home consumption is not a ‘supply’, and hence, no Customs duty or IGST arises on such transactions. It held that Customs duty and IGST are leviable only when warehoused goods are cleared for home consumption. It further held that the applicant’s registration in Telangana is sufficient to meet tax compliances, if any, and that no separate registration is required in Tamil Nadu under Section 22 of the CGST Act or the Tamil Nadu GST Act.

List of Cases Referred to

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Author: Taxmann

Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied