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How-To · 12 min read

Trent Westside Apparel VMI Reconciliation

A Tier-2 Bengaluru garment supplier VMI-places 65,000 units at a Trent Westside distribution centre in October, retaining legal title until consumption. Reconciling the DC stock register, monthly call-off invoicing under Section 12 CGST time-of-supply, and residual return-to-supplier at season-end decides whether the supplier books revenue on the correct GST tax period — or ends up with unbilled stock, un-recognised sales, and an audit flag.

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Terra Insight Editorial Team Reconciliation Infrastructure

Content authored by practitioners with experience at Amazon India, Intuit QuickBooks, and the Tata Group. Meet the team →

Published 6 July 2026
Domain expertise
TDS Reconciliation GST Input Credit Platform Settlements NACH Batch Matching Bank Reconciliation Form 26AS Matching ERP Integrations Enterprise Finance Ops
Knowledge Card
Problem

A Tier-2 garment supplier VMI-places 65,000 units at a Trent Westside distribution centre in October under a Rule 55 delivery challan and retains legal title until consumption. Monthly consumption call-offs across November, December, and January draw down the stock at different unit counts and unit rates, and each call-off must convert to a Section 31 tax invoice at the correct time of supply under Section 12 CGST — with GST charged at the call-off date rate, invoice flowing into GSTR-1 for the call-off month, and Trent's ITC becoming available in GSTR-2B/3B in the same period. Residual stock at season-end must be closed either by return delivery challan (pre-invoicing units) or by Section 34 credit note (post-invoicing sales return). A supplier that manages this in a spreadsheet loses call-off timing, invoices in the wrong tax period, mis-classifies residual returns as credit notes instead of challan returns, and drifts on Section 194Q (payment code 1031) TDS reconciliation once the ₹50 lakh annual threshold is crossed.

How It's Resolved

Build a VMI dispatch register keyed by the parent Rule 55 outbound challan reference at DC placement; expand each parent challan into an expected drawdown profile aligned with the season sell-through calendar. Ingest every consumption call-off notification from the brand, match by SKU, quantity, and running balance against the parent challan, and generate the Section 31 tax invoice within the day of the call-off. Flag every invoice with the Section 12 time-of-supply date and validate that the GSTR-1 filing period aligns. Track running balance at the DC by SKU; at season-end, reconcile the closing balance to the physical stock take shared by the DC and issue either a Rule 55 return-inward challan (for pre-invoicing units) or trigger a Section 34 credit note (for post-invoicing sales returns). Cross-check the invoice cumulative value against the ₹50 lakh Section 194Q threshold to identify the tipping invoice from which the buyer's TDS deduction under payment code 1031 becomes applicable, and reconcile the deducted TDS against Form 26AS at the supplier's PAN monthly.

Configuration

Brand and DC master with GSTIN, PAN, PIN code, and delivery address; SKU master with HSN, unit-of-measure, standard unit rate for the season, and VMI parent challan reference; VMI dispatch register with outbound Rule 55 challan (challan number, date, HSN, quantity, declared taxable value, e-way bill reference); consumption call-off ingest schedule (weekly or monthly per the arrangement); Section 12 time-of-supply rule engine configured to earlier-of invoice-date or call-off date; Section 31 invoice issue window (same-day of call-off preferred, no later than the removal or making-available date); Section 34 credit note issue window (30 November following FY of original supply); Section 194Q payment code 1031 threshold tracker (₹50 lakh per PAN per FY) with 0.1 percent deduction rate; TDS credit reconciliation against Form 26AS at PAN level monthly.

Output

A month-end VMI reconciliation pack: opening balance at DC by SKU by parent challan, monthly consumption call-off (with invoice numbers and time-of-supply dates), invoice value and GST charged, running balance at DC by SKU, cumulative FY purchase value against the Section 194Q threshold, buyer TDS deducted under payment code 1031 with 26AS reconciliation status. At season-end, closing balance at DC is reconciled to physical stock take; residual units returned pre-invoicing close on a return-inward Rule 55 challan; post-invoicing sales returns close on a Section 34 credit note within the 30 November following-FY deadline. The pack feeds the supplier's GSTR-1 for the invoicing month, the customer's GSTR-2B mirror check, and the statutory audit workpapers for revenue recognition timing under Ind AS 115.

A Tier-2 garment supplier to Trent Ltd’s Westside store network closes the October dispatch cycle with a VMI placement of 65,000 units at a Trent distribution centre — an illustrative ₹4.2 crore stock value on the outbound Rule 55 delivery challan, title still with the supplier, no tax invoice issued at movement. Over the next twelve weeks, Trent will draw down against this stock through three consumption call-offs — an illustrative 22,000 units in November, 28,000 in December, 12,000 in January — and the supplier must convert each call-off into a Section 31 tax invoice at the correct Section 12 CGST time of supply, book revenue in the correct GST tax period, and reconcile Section 194Q (payment code 1031) TDS deduction against Form 26AS. Residual 3,000 units at end-January come back on a return-inward delivery challan or carry over to the February-March season, and the closing balance at the DC must reconcile to the physical stock take before the March GSTR-1 filing. This is Trent Westside apparel VMI reconciliation India at the scale a specialist garment supplier operates, and the discipline that carries this cycle cleanly is the same discipline that turns confirmed brand-and-retailer volume into a clean GST tax period and a defensible revenue recognition workpaper.

Quick reference

AspectDetail
Governing GST provision (time of supply)Section 12 CGST — earlier of invoice date or Section 31 last invoice date
Governing GST provision (invoicing)Section 31 read with Rule 47 — invoice at or before removal / making-available
VMI placement documentRule 55 delivery challan (INS-01 format) — no tax invoice at placement
Consumption call-off documentSection 31 tax invoice issued on the day of call-off
Residual return (pre-invoicing)Rule 55 return-inward delivery challan — no credit note
Sales return (post-invoicing)Section 34 credit note — deadline 30 Nov following FY of original supply
Buyer TDS (purchase of goods)Section 8 Sl. 8 code 1031 — 0.1% above ₹50 lakh/PAN/FY threshold
Illustrative brand contextTrent Ltd (Tata Group) — Westside, Zudio store network
E-invoicing threshold₹5 crore aggregate turnover from 1 August 2023
Reconciliation cadenceWeekly call-off match; monthly stock-take; season-end closing balance

The reconciliation in one paragraph

A Vendor Managed Inventory arrangement between a Tier-2 garment supplier and a national branded-apparel retailer such as Trent Ltd operating the Westside and Zudio store network places physical stock at the brand’s distribution centre on a Rule 55 delivery challan with legal title retained by the supplier. No supply occurs at placement; no tax invoice is issued; no time-of-supply liability arises under Section 12 CGST at the placement date. Supply crystallises only when the brand issues a consumption call-off drawing units from the DC-held stock — at that point Section 12 fixes the time of supply as the earlier of the invoice date or the last date on which the supplier is required to issue the invoice under Section 31, which for a consumption call-off is the call-off date itself. The supplier issues a Section 31 tax invoice on or before the call-off date, GST is charged at the rate applicable on that date, the invoice flows into the supplier’s GSTR-1 for the call-off month, and the brand’s GSTR-2B populates in the same period for ITC. Season-end residual units at the DC close either on a return-inward Rule 55 challan (for units where no invoice was ever issued) or on a Section 34 credit note (for post-invoicing sales returns), and the closing balance at the DC must reconcile to the physical stock take before the March GSTR-1 filing.

What the Trent Westside VMI arrangement looks like in India — safe illustrative brands

Trent Ltd is the branded-apparel and lifestyle arm of the Tata Group operating the Westside chain (mid-market fashion for the ₹1,500 to ₹4,500 unit-price band) and the Zudio chain (mass-value fashion at the ₹200 to ₹999 unit-price band), together spanning several hundred stores across India and expanding aggressively into Tier-2 and Tier-3 cities. The volume, SKU count, and season-turnaround requirement across these formats makes VMI arrangements with Tier-2 garment suppliers a workable operational shape — Trent hands off the working-capital burden of pre-season stock accumulation to the supplier in exchange for confirmed programme volume and cadence.

Tier-2 garment suppliers that operate this shape at scale in the Indian branded-apparel supply chain include Shahi Exports, Gokaldas Exports, Pearl Global Industries, and specialist cut-make-pack units in Bengaluru, Tiruppur, Ludhiana, and the NCR region. Illustrative context — a mid-tier Bengaluru cut-make-pack unit with approximately ₹120 crore of annual turnover running a dedicated programme for Westside menswear may VMI-place 60,000 to 80,000 units into a single Trent DC ahead of a season, drawing on cotton-blend fabric procured from a Tiruppur or Solapur weaver upstream and finishing through in-house cutting and stitching. Other national brand-and-retailer chains that run comparable VMI-adjacent replenishment shapes with Tier-2 garment suppliers — depending on category and programme structure — include Aditya Birla Fashion and Retail (Pantaloons, Allen Solly, Van Heusen), Reliance Retail (Reliance Trends), and the digital-first pure-plays Myntra (Walmart-owned), Ajio (Reliance-owned), Flipkart Fashion (Walmart), and Nykaa Fashion, though the pure-plays typically operate on hybrid marketplace or wholesale rather than physical-DC VMI.

Regional geography of the supplier base matters for the reconciliation. Bengaluru and Chennai supply large-format menswear and womenswear programmes to national brands; Tiruppur supplies knitwear (T-shirts, polos, sleepwear); Ludhiana supplies winter knitwear and layering; Panipat supplies home-textile-adjacent categories that Westside occasionally programmes into store; the NCR belt supplies structured woven-wear. Each geography has its own factory-to-DC transit lead time, and the VMI placement date must lead the season sell-through calendar by enough runway for the DC to allocate to stores.

The regulatory overlay

Section 12(2) of the CGST Act 2017 defines the time of supply of goods as the earlier of the date on which the supplier issues the invoice (or the last date on which the supplier is required to issue the invoice under Section 31), or the date on which the supplier receives payment. Section 31(1) requires the tax invoice to be issued before or at the time of removal of goods for supply where the supply involves movement of goods, and in any other case, before or at the time of delivery of goods or making them available to the recipient. For a VMI placement at a distribution centre, movement to the DC is not a movement for supply — it is a movement on Rule 55 delivery challan for stock placement where title has not passed. The ‘making available to the recipient’ event does not occur at DC arrival because Trent does not yet own the stock; it holds it as bailee. Supply crystallises on the consumption call-off — when Trent issues an internal drawdown instruction converting DC-held VMI stock into owned inventory available for store dispatch. That is the point at which the goods are ‘made available to the recipient’ for Section 31 purposes, and the supplier must issue the tax invoice at or before that point.

Rule 55 of the CGST Rules 2017 governs the movement document for the initial VMI placement. Every physical movement of goods for reasons other than by way of supply — including stock placement to a brand DC where title does not pass on movement — must be accompanied by a delivery challan carrying the consignor’s GSTIN (the supplier’s), the consignee’s GSTIN (the brand’s DC), HSN and description of goods, quantity, declared taxable value (this is a declared value for movement — typically supplier cost-plus-margin, not a taxable supply value), and challan number and date. The challan is issued in triplicate. For inter-state movement or intra-state movement above the applicable state e-way bill threshold, an e-way bill (Form GST EWB-01) is generated with the same reference details.

Section 34 CGST governs the credit note where post-invoicing returns happen. Once the supplier has issued a Section 31 tax invoice on a consumption call-off, any subsequent return of those specific units from the brand or from the store channel is a sales return under Section 34. The supplier issues a credit note referencing the original tax invoice, declares the credit note in the GSTR-1 of the month it is issued, and must issue the credit note no later than 30 November following the end of the FY of the original supply or the date of furnishing the annual return, whichever is earlier. The Section 34 credit note is distinct from a Rule 55 return-inward challan — the credit note applies to invoiced-and-supplied units; the return-inward challan applies to units still on the parent VMI outbound challan that were never invoiced.

Section 8 Sl. 8 payment code 1031 of the Income-tax Act 2025 is the successor to legacy Section 194Q — the buyer’s TDS obligation of 0.1 percent on purchase of goods above the ₹50 lakh threshold in a financial year from any single seller. For a VMI arrangement where the brand’s aggregate purchase from the supplier will predictably cross the ₹50 lakh threshold within the season, the brand must deduct TDS on invoices exceeding the threshold, and the supplier reconciles the deduction against Form 26AS at PAN level monthly. Where both Section 194Q (buyer TDS) and Section 206C(1H) (seller TCS) are theoretically applicable, Section 194Q takes precedence — a common reconciliation error is double-application on the same transaction. For upstream conversion charges (fabric to garment), Section 8 Sl. 4 code 1023 applies to job-work TDS where the principal supplies raw material — at 1 percent (Individual/HUF job worker) or 2 percent (other resident job worker), deducted on the conversion charge only.

Section 9(1) versus Section 9(5) treatment matters for the classification of the transaction itself. Section 9(5) CGST notifies specific service categories (passenger transport, housekeeping, restaurant and cloud kitchen, accommodation) where the electronic commerce operator is deemed to be the supplier and pays GST. Apparel goods are not notified under Section 9(5); a VMI supply from a Tier-2 supplier to Trent Westside is a normal Section 9(1) supply where the supplier is the taxable person and charges GST on the tax invoice. The ECO deemed-supplier framework does not apply to a physical VMI arrangement between a supplier and a brand-and-retailer.

A worked example — a Bengaluru menswear supplier and a single Westside DC placement

Illustrative — the following figures represent the operating pattern of a representative Bengaluru cut-make-pack unit running a dedicated Westside menswear programme. Public disclosures do not reveal internal VMI-placement values, call-off invoicing rates, or DC-level running balances; cross-verify against your own dispatch register, call-off ingest feed, and Section 194Q threshold tracker before action.

On 15 October 2026, the Tier-2 supplier VMI-places 65,000 units of assorted menswear SKUs (shirts, chinos, polos) at a Trent DC location. The outbound Rule 55 delivery challan VMI/25-26/TRT/00047 carries the supplier’s GSTIN, the Trent DC’s GSTIN, HSN 6205 (men’s shirts of cotton) and 6203 (men’s trousers), aggregate quantity 65,000 units, declared taxable value ₹4.2 crore (representing supplier cost-plus-margin at illustrative average unit rate ₹646). Inter-state e-way bill is generated for the transport leg. The DC acknowledges receipt on 17 October 2026; the supplier’s VMI dispatch register opens the parent-challan record with a running balance of 65,000 units.

November call-off — 22,000 units. On 22 November 2026, the DC issues a consumption call-off drawing 22,000 units against the parent challan — mixed SKUs at an illustrative average call-off rate of ₹645 per unit (accounting for SKU mix and the pricing schedule embedded in the VMI programme). The supplier issues Section 31 tax invoice INV/25-26/TRT/00312 dated 22 November 2026, taxable value ₹14,190,000 (₹1.42 crore), IGST at 5 percent for apparel below ₹1,000 unit-price threshold and 12 percent above ₹1,000 unit-price — say a blended aggregate GST of ₹86,000 on the November call-off, populated to GSTR-1 for November 2026 due 11 December 2026 (or the specified deadline for the supplier’s turnover band). Section 12 time of supply is fixed at 22 November 2026. Running balance at DC drops from 65,000 to 43,000 units.

December call-off — 28,000 units. On 20 December 2026, the DC issues a consumption call-off drawing 28,000 units — the peak-season replenishment. The supplier issues Section 31 tax invoice INV/25-26/TRT/00389, taxable value ₹1.81 crore at an illustrative average rate of ₹646.4 per unit. The cumulative FY purchase value from this supplier at the brand crosses the ₹50 lakh Section 194Q threshold well before this invoice (already crossed inside the November call-off), so the brand deducts payment-code-1031 TDS at 0.1 percent on the invoice amount — ₹18,100 deducted, remitted, and reflected on Form 26AS at the supplier’s PAN by the following month-end. GSTR-1 for December 2026 receives the invoice. Running balance drops from 43,000 to 15,000 units.

January call-off — 12,000 units. On 18 January 2027, the DC issues the final consumption call-off drawing 12,000 units at an illustrative average rate of ₹641.7 per unit — end-of-season pricing under the pre-committed VMI schedule. Section 31 tax invoice INV/25-26/TRT/00465 dated 18 January 2027, taxable value ₹77 lakh; TDS at 0.1 percent under code 1031 remitted ₹7,700. GSTR-1 for January 2027 receives the invoice. Running balance drops from 15,000 to 3,000 units.

Residual 3,000 units. By end-January the season sell-through has plateaued and the DC decides not to draw down further from this parent challan. The supplier and the DC reconcile physical stock take on 31 January 2027 — 3,000 units of assorted SKUs remain in the parent-challan pool. The DC issues a return-inward Rule 55 delivery challan VMI-RET/25-26/TRT/00019 dated 5 February 2027 referencing the original outbound challan VMI/25-26/TRT/00047, quantity 3,000 units, HSN and declared value proportional to the parent-challan average. No credit note is issued because no tax invoice was ever issued for these 3,000 units — they were never supplied under Section 12. The units come back to the supplier’s Bengaluru factory as finished-goods inventory; the supplier redeploys them into the next-season assortment, the distress channel, or a warehouse write-down depending on saleability.

Section 194Q threshold tracker. The supplier’s threshold tracker across the FY at this brand’s PAN shows the ₹50 lakh threshold crossed inside the November call-off (invoice value ₹1.42 crore alone exceeds it). From the November invoice onwards, the brand deducted 0.1 percent TDS. Cumulative TDS deducted by 31 January 2027 on this VMI programme alone — approximately ₹40,000 across the three call-off invoices — reconciles against Form 26AS at PAN level, and any variance triggers a rate-and-value line-item audit at each invoice.

Reconciliation pack — end-January 2027. The supplier’s VMI reconciliation pack for the Westside menswear programme surfaces the following:

VMI reconciliation line itemQuantityValue (₹ lakh)
Opening balance at DC (15 Oct 2026 placement)65,000 units420.0
November call-off invoice (INV/25-26/TRT/00312)22,000 units141.9
December call-off invoice (INV/25-26/TRT/00389)28,000 units181.0
January call-off invoice (INV/25-26/TRT/00465)12,000 units77.0
Return-inward challan (VMI-RET/25-26/TRT/00019)3,000 units20.1
Closing balance at DC (31 Jan 2027)0 units0
Cumulative FY purchase against Section 194Q ₹50 lakh thresholdAboveBuyer TDS active from Nov invoice
Cumulative buyer TDS under payment code 1031 (0.1%)Approx 0.40

The programme closes cleanly. Revenue recognition under Ind AS 115 aligns with the Section 12 time-of-supply dates on each call-off invoice; GSTR-1 filings for November, December, and January carry the correct invoices; Form 26AS reconciles to buyer-deducted TDS at PAN level; the parent-challan-to-return-inward chain proves the residual 3,000 units were never supplied. The audit trail satisfies the statutory audit workpaper on revenue-cutoff for the FY.

Common reconciliation breakages

Five breakages recur across Tier-2 garment suppliers running VMI programmes with national brand-and-retailers, and each maps to a specific control failure.

  • Invoice-in-wrong-tax-period. Consumption call-off happens on 30 November, but the supplier issues the tax invoice on 3 December because the DC’s call-off notification landed after the November GSTR-1 cut-off. Section 12 fixes the time of supply at 30 November (the earlier of invoice-date and Section 31 last-invoice-date, which for a call-off is the call-off date itself). Invoicing on 3 December pushes the transaction into December’s GSTR-1 incorrectly, creates a Section 12 time-of-supply exposure, and forces a subsequent adjustment when the auditor picks it up.

  • Residual return mis-classified as credit note. Units still on the parent Rule 55 outbound challan (never supplied, never invoiced) are erroneously closed on a Section 34 credit note. There is no original tax invoice to which the credit note can refer, so the credit note is defective — GSTR-1 will accept it but the buyer’s ITC reversal will not tie, and the mismatch surfaces at year-end. The correct close is a Rule 55 return-inward challan referencing the parent outbound challan.

  • Section 194Q threshold missed on the tipping invoice. The first invoice that crosses the ₹50 lakh cumulative FY threshold at the brand’s PAN is where the buyer’s TDS deduction under payment code 1031 becomes active. If the supplier’s threshold tracker updates only monthly rather than per-invoice, the tipping invoice may go out without the buyer deducting TDS, and the correction on the next invoice creates a 26AS mismatch. The correct discipline is per-invoice cumulative tracking with an alert on the crossing invoice.

  • Chain reference lost between parent challan and call-off invoice. Each consumption call-off tax invoice must reference the parent Rule 55 outbound challan by challan number, so the audit trail proves that the supply crystallised only on the call-off date and not at the placement date. Suppliers that skip this reference (or store it only in a spreadsheet not linked to the invoice) lose the trail; a Section 65 audit will treat the placement as the time of supply and assess retrospective GST from the placement date.

  • Physical stock take at DC not reconciled to running balance. The supplier’s running-balance calculation at the DC (parent-challan quantity minus consumption call-offs to date) must match the DC’s physical stock take at each period-end. Where the DC has short-shipped from stores, damaged units in transit, or held units back for internal transfer without notifying the supplier, the running balance drifts from the physical count. The month-end stock take is the control point that surfaces the drift; suppliers that skip the reconciliation carry a stale balance into the next call-off cycle and eventually into the season-end residual return.

How a reconciliation platform handles this

A purpose-built branded-apparel VMI reconciliation platform ingests the outbound Rule 55 delivery challan at DC placement, every consumption call-off notification from the brand’s replenishment system, every Section 31 tax invoice raised, the physical stock take at the DC at period-end, and the Form 26AS feed at the supplier’s PAN — and produces a per-parent-challan chain view that closes the loop from DC placement to season-end residual return. The platform runs the Section 12 CGST time-of-supply rule on every call-off, ensuring the tax invoice is issued on or before the call-off date and populates the correct GSTR-1 tax period. It runs the Section 194Q payment code 1031 cumulative FY purchase tracker at PAN level, alerts on the tipping invoice that crosses the ₹50 lakh threshold, and reconciles buyer-deducted TDS against Form 26AS monthly. It classifies residual returns correctly — Rule 55 return-inward challan for pre-invoicing units, Section 34 credit note for post-invoicing sales returns — and enforces the 30 November following-FY deadline on credit notes. It produces the audit-ready pack — parent challan, call-off invoices, return-inward challans, credit notes, closing balance, and 26AS reconciliation — that satisfies the supplier’s statutory audit workpaper on revenue-cutoff and the GST Section 65 audit team. Match rate improvement of 51 to 88 percent on the parent-challan-to-invoice chain, combined with ISO 27001:2022 posture and DPDP Act 2023 aligned data handling, turns the VMI reconciliation from a spreadsheet firefight into a repeatable close.

The VMI reconciliation discipline in this article opens the Wave T4 garment-ops theme. For the general Tier-2 VMI framework covering the supply-chain shape and the working-capital transfer, read Vendor Managed Inventory Tier-2 garment supplier reconciliation. For the branded-apparel Section 9(1) versus Section 9(5) classification question that decides whether the transaction is a normal supplier-invoiced supply or an ECO deemed supply, read Branded apparel reconciliation India — Section 9(1) vs 9(5). For the post-invoicing sales-return path when units come back after a tax invoice has been raised, read Returns and RTV branded apparel credit note Section 34. For the online-channel counterpart where Myntra, Ajio, and Flipkart Fashion aggregate the settlement leg, read Myntra Ajio Flipkart Fashion apparel settlement reconciliation. Upstream in the conversion chain, the cut-make-pack economics and the job-work TDS taxonomy at code 1023 are covered in CMP conversion manufacturing price garment export reconciliation and the multi-hop job-work reconciliation for textile manufacturing cornerstone. The commercial pillar for the entire textile cluster is Textile reconciliation software India; the broader authority is reconciliation software India.

The five FAQs below address the operational questions Indian branded-apparel controllers and Tier-2 supplier finance leads ask most often when implementing structured VMI reconciliation with a national retailer.

Terra Insight
Terra Insight Editorial Team Reconciliation Infrastructure

Content authored by practitioners with experience at Amazon India, Intuit QuickBooks, and the Tata Group. Meet the team →

Published 6 July 2026
Domain expertise
TDS Reconciliation GST Input Credit Platform Settlements NACH Batch Matching Bank Reconciliation Form 26AS Matching ERP Integrations Enterprise Finance Ops
Primary reference: CBIC GST portal — for Section 12 CGST time-of-supply provisions, Section 31 tax invoice timing, and Section 34 credit note rules that govern VMI consumption call-off invoicing and season-end returns.
Primary sources cited
Last reviewed against sources on 6 July 2026
  • Section 12, Central Goods and Services Tax Act 2017 — Time of supply of goods. The liability to pay tax on goods arises at the time of supply, which is the earlier of (a) the date of issue of invoice by the supplier or the last date on which the supplier is required to issue the invoice under Section 31, or (b) the date on which the supplier receives the payment. For VMI arrangements, no supply occurs on placement at the buyer's premises — title remains with the supplier. Supply crystallises on consumption call-off from the buyer, triggering the Section 31 invoicing obligation within thirty days of the removal of goods for supply.
  • Section 31 read with Rule 47, Central Goods and Services Tax Act and Rules 2017 — Tax invoice. A registered supplier of taxable goods must issue a tax invoice before or at the time of removal of goods for supply to the recipient, where the supply involves movement of goods, or delivery of goods or making available to the recipient in any other case. For VMI call-off supplies, the invoice must be issued on or before the consumption call-off date since the earlier movement to the DC was on a delivery challan under Rule 55 and did not constitute a supply.
  • Section 34, Central Goods and Services Tax Act 2017 — Credit note. Where the taxable value or tax charged in a tax invoice is found to exceed the taxable value or tax payable, or where goods supplied are returned by the recipient, the supplier may issue a credit note. The credit note in respect of any tax invoice issued during a financial year must be declared in the return for the month in which the credit note is issued, and not later than 30 November following the end of the financial year in which the original supply was made, or the date of furnishing the annual return, whichever is earlier.
  • Rule 55, Central Goods and Services Tax Rules 2017 — Transportation of goods without issue of invoice. A consignor may issue a delivery challan for movement of goods for reasons other than by way of supply, including movement of goods on approval basis or for stock transfer to a location where title does not pass on movement. VMI placement at a brand distribution centre — where legal title remains with the supplier until consumption — is a Rule 55 challan movement, not a taxable supply.
  • Section 8 Sl. 4 code 1023 and Sl. 8 code 1031, Income-tax Act 2025 — Payment code 1023 applies to job-work TDS where the principal supplies raw material — relevant for the CMP conversion charge upstream of VMI placement, at 1 percent (Individual/HUF) or 2 percent (other resident job worker). Payment code 1031 is the successor to Section 194Q for purchase of goods above the ₹50 lakh annual threshold at 0.1 percent, deductible by the buyer on consumption call-off invoicing — relevant where the brand's aggregate purchase from the supplier crosses the threshold in the FY.

Frequently Asked Questions

What is a Vendor Managed Inventory (VMI) arrangement in the branded apparel context and why does Trent Westside use it with Tier-2 garment suppliers?
Vendor Managed Inventory is a supply-chain arrangement where the supplier retains legal title and inventory risk on stock physically located at the buyer's premises until the buyer consumes it. In branded apparel, VMI is common between a national brand-and-retailer such as Trent Ltd (which operates the Westside and Zudio store network as part of the Tata Group) and its Tier-2 garment suppliers who fabricate seasonal SKUs on cut-make-pack basis. The arrangement lets Trent hold the entire season's assortment at a distribution centre without booking inventory on its balance sheet; the supplier ships in a large forward-committed quantity aligned to the season sell-through forecast, and Trent draws down against consumption call-offs as stores replenish. For the supplier, the arrangement locks in confirmed volume for the season but shifts the working-capital burden — the supplier funds fabric, cut-make-pack, and DC placement upfront, and receives payment only as consumption call-offs are invoiced across the November to January selling window. From a GST perspective, the placement at the DC on a Rule 55 delivery challan does not constitute supply because title has not passed; supply crystallises on the consumption call-off, which triggers the Section 12 CGST time-of-supply rule and the Section 31 invoicing obligation. Residual stock at season-end (typically 3 to 8 percent of the placed quantity) is either returned to the supplier under a return delivery challan or held for the next-season carry-over.
How does Section 12 CGST time-of-supply work for VMI consumption call-offs?
Section 12(2) of the CGST Act 2017 fixes the time of supply of goods as the earlier of the date on which the supplier issues the invoice (or the last date by which the supplier is required to issue the invoice under Section 31), or the date on which the supplier receives the payment. Section 31(1) requires the invoice to be issued before or at the time of removal of goods for supply where the supply involves movement of goods, or delivery of goods (or making them available to the recipient) in any other case. For a VMI arrangement, the initial movement from the supplier's factory to the brand's distribution centre is a Rule 55 delivery challan movement — no supply, no invoice. The 'making available to the recipient' event does not happen at DC arrival because title has not passed; the recipient (Trent Westside) does not yet own the stock. Supply crystallises when Trent issues a consumption call-off drawing units from the DC-held VMI stock, and the supplier must issue the tax invoice under Section 31 on or before the call-off date, which then becomes the time of supply under Section 12. GST is charged at the rate applicable on the call-off date, and the invoice flows into the supplier's GSTR-1 for the month of the call-off and Trent's GSTR-2B/3B for ITC in the same period. Any delay in issuing the invoice past the call-off date creates a time-of-supply exposure — the last date under Section 31 (the removal or making-available date) still triggers the supply, and interest runs from that date.
How is the residual stock at VMI season-end handled under GST — return delivery challan or credit note?
Residual stock at season-end has two distinct GST treatments depending on what actually happens to the units. Path one is physical return of unconsumed units from the brand DC to the supplier's factory. Because the units are still on the supplier's Rule 55 delivery challan (no supply crystallised, no invoice issued for those units), the return leg is documented on a fresh Rule 55 return-inward delivery challan issued by the brand DC, referencing the original outbound challan, with quantity and HSN details. There is no credit note because there was no original tax invoice for the returned units — they were never supplied. The supplier updates the VMI dispatch register to close the outbound challan against the return-inward challan, and the residual value reverts to finished-goods inventory at the supplier's premises for redeployment (next-season carry-over, distress channel, or write-down). Path two is where the brand has already consumption-called-off units, invoicing has happened, but the units are then returned post-invoicing (sales-return path, distinct from VMI residual). In that case, Section 34 CGST applies and the supplier issues a credit note referencing the original tax invoice, declared in the GSTR-1 of the month the credit note is issued, no later than 30 November following the end of the FY of the original supply. The reconciliation platform must not conflate the two paths — VMI residual return is a challan-to-challan close; sales return post-consumption is an invoice-to-credit-note close under Section 34.
How does Section 194Q (Income-tax Act 2025 payment code 1031) affect VMI consumption call-off invoicing?
Payment code 1031 under Section 8 Sl. 8 of the Income-tax Act 2025 is the successor to legacy Section 194Q — the buyer's TDS obligation of 0.1 percent on purchase of goods above the ₹50 lakh threshold in a financial year from any single seller. For a VMI arrangement between a national brand such as Trent Ltd (whose aggregate purchase from a Tier-2 supplier over a season will typically cross the ₹50 lakh threshold on a single garment programme) and a Tier-2 supplier, the buyer deducts 0.1 percent TDS at the time of payment or credit, whichever is earlier, on the invoice amount exceeding ₹50 lakh in the FY. The consumption call-off invoicing pattern (three or four invoices across November-January for a single VMI placement) means the ₹50 lakh threshold is typically crossed within the first two call-offs; from the third invoice onwards, TDS deduction under code 1031 applies. The supplier's Form 26AS at PAN level will show the deduction; the supplier reconciles 26AS credit against the invoice-level TDS deduction rate and value to detect under-deduction, over-deduction, or misclassification. Where the buyer has both Section 194Q (buyer TDS on purchase) and Section 206C(1H) (seller TCS on sale) applicability, Section 194Q takes precedence — Trent as buyer deducts TDS under 1031, and the supplier does not collect TCS. The order-precedence rule is critical because dual application on the same transaction is a common reconciliation error at year-end.
Why does VMI placement use a Rule 55 delivery challan rather than a tax invoice?
Rule 55 of the CGST Rules 2017 governs movement of goods for reasons other than by way of supply. A VMI placement at the brand distribution centre is not a supply because title has not passed to the buyer at the point of movement — legal title remains with the supplier, inventory risk remains with the supplier, and no consideration has become due or receivable at the placement event. The absence of the supply trigger means no tax invoice under Section 31 is required and no time-of-supply liability arises under Section 12 at the placement event. Rule 55 requires the outbound movement to be accompanied by a delivery challan carrying the consignor's GSTIN (the supplier's), the consignee's GSTIN (the brand's DC), HSN and description of goods, quantity, declared taxable value (this is the value declared for movement — typically the supplier's cost-plus-margin, not a tax base), and challan number and date. The challan is issued in triplicate. For inter-state VMI placement or intra-state above the e-way bill threshold, an e-way bill (EWB-01) is generated for the transport leg with the same reference details. The critical reconciliation implication is that the supplier's outbound register must chain every consumption call-off tax invoice back to the parent Rule 55 challan by challan number, HSN, and running quantity — the audit trail is what proves that the supply crystallised only on the call-off date and not at the placement date.

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