Whether GST is leviable on transaction between Liaison/ branch Office and Head Office ?
TRT-2026-236

Issue Favourable to Tax Payer ?:- yes

Held - For GST to be applicable on the accounting entry made for the purpose of Indian accounting requirements in the books of accounts of Project Office for salary cost of Expat employees paid by the Head Office, such accounting entry should be seen as a supply of goods, services or both. Since we find that there is a relation of employer and employee between the Project Office and the expat employees, the provisions of Schedule III of the CG.....

TRT-2026-237

Issue Favourable to Tax Payer ?:- yes

Held - We are in unison with the applicant that a Project Office is merely an extension of the foreign company in India to undertake the project in India and limited to undertake compliances required under various tax and regulatory requirements in India. Accordingly, it is observed that the Head Office and project office are the same legal entity and they cannot be treated as different legal entities. We also observe that the project office i.....

TRT-2026-238

Issue Favourable to Tax Payer ?:- yes

Held - The HO, Netherlands reimburses the expenses incurred by the applicant for their operations in India which are in the nature of salary, rent, security, electricity, travelling etc. The applicant does not have any other source of income and it is solely dependent on the HO for all the expenses incurred by the applicant, which are subsequently reimbursed by the HO. Therefore the HO and Liaison Office cannot be treated as separate persons.<.....