Is ITC Reversal Necessary for Post-Sale Discounts? CBIC Clarifies

Synopsis
Key Takeaways
- No ITC reversal needed for post-sale discounts.
- Credit notes do not reduce original transaction values.
- Discounts from manufacturers to dealers are not additional compensation.
- Manufacturer-customer agreements with discounts are part of overall consideration.
- Promotional activities may incur GST separately.
New Delhi, Sep 13 (NationPress) The Central Board of Indirect Taxes and Customs (CBIC) has provided important clarifications regarding the treatment of secondary or post-sale discounts under Goods and Services Tax (GST).
This clarification follows numerous inquiries about whether such discounts influence tax obligations and input tax credit (ITC).
The circular states that when a supplier issues financial or commercial credit notes for discounts, the recipient retains the right to claim the full input tax credit.
“This is because these credit notes do not alter the original transaction value or the tax liability associated with the supply. Consequently, businesses purchasing goods at discounted rates are exempt from reversing their ITC,” the CBIC added.
Furthermore, the circular specifies that discounts provided by manufacturers to dealers should not be considered as additional compensation for the dealer's supply of goods to end customers.
According to CBIC, the interaction between manufacturers and dealers is based on a principal-to-principal relationship, with such discounts typically aimed at enhancing sales through competitive pricing.
Nonetheless, it was noted that if a manufacturer has an arrangement with an end customer to deliver goods at a discounted price, and issues credit notes to the dealer, those discounts will be integrated into the overall compensation.
“In these scenarios, the discount acts as an incentive for supplying goods at a reduced price,” per the circular.
The circular further elaborated that post-sale discounts provided to dealers should not be treated as payment for promotional services.
Dealers frequently engage in promotional activities that benefit their own sales, meaning these discounts simply lower the selling price of goods.
However, if dealers are specifically contracted to perform tasks such as advertising, co-branding, or unique sales campaigns, GST will be applicable separately for those services.
The CBIC has urged tax authorities to disseminate these clarifications to ensure consistent application of GST law nationwide.