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Microlesson · 5-min read

Schedule I — Activities treated as Supply without Consideration

# Schedule I — Supply WITHOUT Consideration

Schedule I lists four categories that are treated as supply even when no consideration flows.

## 1. Permanent Transfer/Disposal of Business Assets

Where Input Tax Credit (ITC) has been availed on such assets.

### Two Important Points ("Do Imp Baate")

  • ITC not blocked / available on the asset, AND
  • ITC has actually been availed.

If ITC was not availed (e.g., asset purchased before registration), Schedule I does NOT apply to its permanent disposal.

## 2. Supply between Related Persons or Distinct Persons

In the course or furtherance of business — treated as supply even without consideration.

### Three Important Sub-categories ("Tin Important Baate")

(i) Distinct persons (e.g., branches of same entity in different states with separate registrations).

(ii) Stock transfers / Branch transfers across states.

(iii) Related persons — including:

  • Family members
  • Officers/directors of one another's business
  • Persons controlling/controlled by a third person
  • Employer-employee (gifts above ₹50,000 in a financial year)

### Exception: Employer–Employee Gifts

Gifts by employer to employee up to ₹50,000 per FY are NOT treated as supply.

Above ₹50,000 → treated as supply.

## 3. Principal–Agent Supplies

Supply of goods between principal and agent (or vice versa) where the agent supplies/receives goods on behalf of the principal.

### Key Distinction — Whose Name on the Invoice?

  • Bill in Agent's name → Schedule I applies (deemed supply).
  • Bill in Principal's name → Pure agency; NOT a supply under Schedule I.

## 4. Import of Services from Related Person

Import of services by a taxable person from a related person or from any of his other establishments outside India, in the course or furtherance of business — treated as supply even without consideration.

Worked example

### Example 1

Example 1 (Asset Disposal): A company donates a machine (on which ITC was availed) to a charity. → Treated as supply under Schedule I; GST payable on the value.

### Example 2

Example 2 (Branch Transfer): Mumbai HQ transfers goods worth ₹2 lakh to its Bangalore branch (both separately registered). No consideration charged. → Deemed supply between distinct persons under Schedule I.

### Example 3

Example 3 (Employer Gift): Employer gifts a watch worth ₹40,000 to an employee in FY 2025-26. → Not supply (within ₹50,000 limit). If watch is ₹70,000 → full value is supply.

### Example 4

Example 4 (Agent): Principal A in Delhi sends goods to Agent B in Mumbai who sells them. If invoice to end customer is in B's name → Schedule I supply between A and B. If invoice is in A's name → No Schedule I supply.

⚠️ Common exam mistakes

  • Forgetting the ₹50,000 threshold per financial year for employer-to-employee gifts.
  • Applying Schedule I to permanent transfer of assets even when ITC was never availed.
  • Missing that import of services from related person is taxable even without consideration.
  • Not distinguishing agent transactions based on whose name appears on the invoice.
Bare-Act text Schedule I · CGST Act, 2017 · click to expand
Schedule I — Activities to be treated as supply even if made without consideration: 1. Permanent transfer or disposal of business assets where input tax credit has been availed on such assets. 2. Supply of goods or services or both between related persons or between distinct persons as specified in section 25, when made in the course or furtherance of business: Provided that gifts not exceeding fifty thousand rupees in value in a financial year by an employer to an employee shall not be treated as supply of goods or services or both. 3. Supply of goods — (a) by a principal to his agent where the agent undertakes to supply such goods on behalf of the principal; or (b) by an agent to his principal where the agent undertakes to receive such goods on behalf of the principal. 4. Import of services by a person from a related person or from any of his other establishments outside India, in the course or furtherance of business.
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