CBIC Clears Confusion Over ITC Treatment Of Post-Sale Discounts, Says No Reversal Needed | Tax News

There has been confusion among buyers that if they require to reverse ITC, given the supplier issues commercial or financial credit notes post the supply. 

Dispersing the confusion in regard to input tax credit (ITC) when suppliers issue post-sale financial or commercial credit notes, the Central Board of Indirect Taxes and Customs (CBIC) has clarified that in that scenario, buyers will not be required to reverse ITC even if payments are made at a discount.

Even if the buyers pay the less after the discount, they don’t need to reverse ITC. The supplier still pays full GST on the original invoice.

In a circular dated September 12, 2025, CBDT said that the issuance of financial/commercial credit notes does not reduce the tax liability on the supplier. “…it is clarified that the recipient will not be required to reverse the Input Tax Credit attributed to the discount provided on the basis of financial/ commercial Credit notes issued by the supplier, as there is no reduction in the original transaction value of the supply and accordingly the corresponding tax liability would also not get reduced,” CBDT said in the circular.

There has been confusion among buyers that if they require to reverse ITC, given the supplier issues commercial or financial credit notes post the supply.

Under the GST, the supplier of goods can issue financial/commercial credit notes. However, these are not considered for tax purpose. Sellers can issue them for various purposes like discounts, incentives, rebates or compensation. Thus they don’t reduce the taxable value or GST liability of the original invoice.

Abhishek Jain, Partner & National Head, Indirect Tax at KPMG in India, said, “it provides much-needed clarity on the GST treatment of various types of discount transactions between manufacturers and distributors/dealers.

“The tax treatment of such discounts has been a subject matter of dispute between the tax authorities and the industry and this circular clarifies the matter in favour of the industry,” argued Karthik Mani, Partner- Indirect tax at BDO India, praising he timing of the circular considering the upcoming festive season, giving the manufacturers clarity for giving support to lower the customer prices.

The circular further distinguished between different types of post-sale discounts. Discounts offered by manufacturers to dealers merely for competitive pricing and sales push cannot be treated as consideration for any service. However, if discounts are linked to specific agreements with end customers, such benefits would be considered part of the overall supply consideration.

CBDT also mentioned in the circular that these credit notes should not be treated as payment for promotional activities done by dealers, unless there is a clear agreement for distinct services such as advertising, co-branding, or customer support.