Invoicing Through Agents explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Three movements look similar on a warehouse floor and are documented three different ways.
Principal to agent, where the agent will supply in its own name: a supply under Schedule I paragraph 3, requiring a tax invoice valued under Rule 29. Between two registrations of the same person: a supply between distinct persons under s.25(4) and Schedule I paragraph 2, requiring a tax invoice valued under Rule 28. Between two locations under one GSTIN: not a supply at all — the movement goes on a delivery challan under Rule 55(1)(c).
Principal to agent
Schedule I paragraph 3 deems a supply of goods by a principal to his agent, where the agent undertakes to supply them on behalf of the principal, to be a supply even without consideration.
Circular No. 57/31/2018-GST supplies the test: whether the agent has the authority to pass or receive the title in the goods on behalf of the principal, and in practice, whether the invoice for the further supply is issued by the agent in his own name.
Agent invoices in its own name → Schedule I paragraph 3 applies. The principal issues a tax invoice to the agent, valued under Rule 29 — open market value, or at the supplier's option 90% of the price the agent charges an unrelated customer. Rule 29: valuing a supply through an agent →
Principal invoices the customer directly, agent only facilitates → no supply of goods to the agent. The agent supplies a service and invoices its commission, taxable at 18%.
Between two registrations of the same person
Section 25(4): a person who has obtained more than one registration, whether in one State or more than one State, shall be treated as distinct persons in respect of each registration.
Schedule I paragraph 2: a supply between distinct persons made in the course or furtherance of business is a supply even without consideration.
So a stock transfer from a Maharashtra GSTIN to a Karnataka GSTIN of the same company is a supply requiring:
- a tax invoice under s.31(1);
- IGST, because it is inter-State;
- valuation under Rule 28, with the second proviso deeming the invoice value to be the open market value where the recipient has full credit;
- an e-way bill for the movement;
- an IRN where e-invoicing applies — a distinct-person supply is a B2B supply.
The same applies between two GSTINs in the same State under Rule 11, with CGST plus SGST instead of IGST. Rule 11: separate registration →
Between two locations under one GSTIN
A factory and a depot in the same State, both declared on one registration — the principal place and an additional place of business.
Not a supply. There is one person, one registration, and no distinct persons. Section 7 requires a supply to someone.
So:
- no tax invoice;
- no tax;
- movement on a delivery challan under Rule 55(1)(c) — transportation for reasons other than by way of supply;
- an e-way bill where the value crosses the threshold, generated from the challan;
- both locations declared in the registration certificate, and records kept at each under Rule 56(7). Principal place of business →
Issuing a tax invoice for such a movement is a common and harmless-looking error that creates an output liability the business then has to explain.
The service equivalents
Cross charge between distinct persons — internally generated services such as management, finance, HR and IT support, supplied by one registration to another. A supply, requiring a tax invoice, valued under Rule 28. Cross charge between distinct persons →
ISD distribution — credit on third-party input services received at a common location, distributed by ISD invoice under Rule 54(1). Not a supply; a distribution of credit. Mandatory from 1 April 2025 for common third-party input services. Rule 54: special invoicing →
Rule 54(1A) invoice — the document by which a location transfers credit of a common input service, including one on which it paid reverse charge, to the ISD.
The three are distinct and are frequently conflated. The test is straightforward: third-party service → ISD; internally generated service → cross charge; same registration → nothing.
Key takeaways
- Agent invoicing in its own name → Schedule I paragraph 3 supply, tax invoice, Rule 29 valuation.
- Agent merely facilitating → the agent supplies a service and invoices commission.
- Between two registrations of one person → supply between distinct persons, tax invoice, Rule 28 valuation, e-way bill, IRN.
- Between two locations under one GSTIN → not a supply; delivery challan under Rule 55(1)(c).
- Third-party input services move through ISD; internally generated services through cross charge.
- Circular No. 57/31/2018-GST supplies the agency test.
Read next
- Rule 29: Valuing a Supply Made Through an Agent
- Cross Charge Between Distinct Persons
- Rule 55: The Five Situations That Need a Delivery Challan
- Rule 54: Special Invoicing for ISD, Banks, GTAs and Transport
Disclaimer: Positions stated as on 5 September 2026, based on the CGST Act and Rules as amended to 31 March 2026 (ICAI Bare Law, 12th edition), the ICAI Handbook on Invoicing under GST (2025) and Circular No. 57/31/2018-GST.