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Circular No. 23/23/2017

Date: December 21, 2017
Subject: Maintenance of books of accounts for additional places of business in auction-based supplies
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Description:

This circular provides clarification on the requirement for maintaining books of accounts by principals and auctioneers dealing in goods such as tea, coffee, rubber, etc., which are supplied through auctions and stored in multiple warehouses.

It clarifies that, under the CGST Act, both the principal and the auctioneer are required to declare warehouses where such goods are stored as their additional places of business. Buyers who store auction-purchased goods in these warehouses are also required to declare the same as their additional place of business.

While the law requires books of accounts to be maintained at each place of business, the circular recognises practical difficulties in maintaining records at every warehouse. Accordingly, it allows principals and auctioneers to maintain the books of accounts relating to additional places of business at their principal place of business, instead of at each warehouse. However, this relaxation is subject to the condition that the concerned principal or auctioneer must intimate the jurisdictional proper officer in writing about such centralized maintenance of records.

The circular further clarifies that principals and auctioneers will remain eligible to avail input tax credit, subject to fulfilment of the prescribed conditions under the CGST Act and Rules. This clarification is specifically applicable to cases where goods are supplied exclusively through auction and the auctioneer claims input tax credit on supplies received from the principal prior to the auction.

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