APOB in GST: it cannot cross a state line

The answer first: an APOB cannot cross a state line

Section 25(2) of the CGST Act says a person seeking registration shall be granted a single registration in a State or Union territory. Its proviso lets a person with multiple places of business in a State or Union territory get a separate registration for each. Both halves are bounded by the same four words. Section 25(1) requires an application in every such State or Union territory in which you are liable, and section 25(4) treats each registration as a distinct person.

Read together, there is no room for an additional place of business in a state where the registration was not granted. So when your stock sits in a fulfilment centre in another state, add an APOB is the wrong instruction. You need a registration in that state, with the fulfilment centre declared as an additional place on it. One dating tip: the proviso to section 25(2) once allowed separate registration for each business vertical in a state, substituted with the current places of business wording by section 13 of the CGST (Amendment) Act, 2018 (Act 31 of 2018) from 1 February 2019. Sources still saying verticals are stale.

Two recent developments only make sense on this reading. The CBIC clarification bearing F. No. CBIC-20016/75/2025-GST/1025, dated 25 September 2025, told a Delhi business storing goods at a third-party cold store in Haryana that it needs a separate Haryana registration. And at its 57th meeting on 8 October 2026 the GST Council recommended a new rule 14B letting small sellers register in a state where they hold no premises, by declaring an operator’s warehouse as their principal place of business. If an out-of-state APOB worked, neither would have been needed. Rule 14B has no notification and no effective date yet.

What an APOB is, and the form that adds it

Section 2(89) defines principal place of business as the place specified as the principal place of business in the certificate of registration. It is a label on your REG-06, not a separate legal species. Every other place declared there is an additional place of business, and section 2(85) is what makes a warehouse where you store goods a place of business at all.

This runs through rule 19 of the CGST Rules, 2017. File FORM GST REG-14 within 15 days of the change. A place of business is a clause (a) change under rule 19(1), so the proper officer approves it within 15 working days by order in FORM GST REG-15, and the amendment takes effect from the date the event occurred, not the date of approval.

So it is officer-approved rather than automatic, with a backstop. Under rule 19(2) the officer may issue a show-cause notice in FORM GST REG-03 within 15 working days; you reply in FORM GST REG-04 within 7 working days under rule 19(3); rejection comes in FORM GST REG-05 under rule 19(4). Rule 19(5) then provides that where the officer takes no action within 15 working days of the application, or 7 working days of your reply, the certificate shall stand amended to the extent applied for. Plan three weeks of working days for a clean file, closer to five if a notice lands.

What the marketplace has to give you

The document list is not platform policy. It comes from the instructions to FORM GST REG-01, read with CBIC Instruction No. 03/2025-GST dated 17 April 2025, which supersedes the 2023 instruction and tells officers the list is indicative. Three routes:

• Own premises. Any ownership document: latest property tax receipt, municipal khata copy or electricity bill.
• Rented or leased. The valid rent or lease agreement, plus an ownership document for the lessor.
• Neither of those. A consent letter with an ownership document for the consenter, which also covers shared properties.

A marketplace fulfilment centre is the third route: neither owner nor tenant. What you need from the operator is a consent letter or no-objection certificate naming your entity and the premises, plus an ownership document for it, typically a lease copy or an electricity bill in the operator’s name.

What the platforms publish is thinner than the advice industry implies. Amazon publishes the requirement. Its Seller Central announcements for new fulfilment centres tell sellers to add the location to the GST certificate as an additional place of business before sending inventory, and point to the FBA dashboard. It does not publish what documentation it supplies for the filing. On the thread announcing the Rajpura, Punjab centre (LDX1, opened 1 July 2025), a seller asked for exactly those documents and no answer appears. Amazon’s Go Local programme separately says it introduces sellers to a tax consultant who sources commercial space to serve as the principal place of business in that state.

For Flipkart, Blinkit, Zepto and Instamart, we found no publicly accessible seller documentation stating what the operator provides. Every source describing an NOC from them is a consultant or a virtual-office vendor. That is an absence of published terms, not proof nothing is given: ask your category manager in writing and keep the reply. It is why a marketplace document checklist should carry this as a dependency you chase, the way the documents required for Blinkit onboarding arrive only once someone asks.

Where it goes wrong in practice

The usual failure is sequencing: stock moves before the registration or the amendment exists. A transfer to your own out-of-state registration is a supply between distinct persons under section 25(4), so it needs a tax invoice and an e-way bill against a destination GSTIN. Where that GSTIN does not exist, the document cannot be raised, the credit has nowhere to land, and the fulfilment centre rejects the inbound anyway.

The second is address mismatch. The address on the amended REG-06 must match the warehouse line for line, because platform verification compares them. One wrong building name or PIN sends you through another REG-14 cycle while the stock waits.

The third is ship-to data. GSTN’s mandatory ship-to GSTIN field for e-way bills is parked rather than dropped, with the supporting advisories withdrawn, so keep bill-to and ship-to masters clean: a multi-state footprint is the setup that breaks when it returns.

On exposure, the clean citation is section 122(1)(xi), which penalises a person liable to be registered who fails to obtain registration: ten thousand rupees or an amount equivalent to the tax evaded, whichever is higher. We found no published CBIC position quantifying exposure for stock held in an already registered state before the APOB amendment clears, so treat any confident number as an estimate.