As per clause 2 of Schedule I of the CGST Act Supply of goods or services or both between distinct persons as specified in section 25, when made in the course or furtherance of business will be treated as supply even if made without consideration.

As per section 25(4) of the CGST Act, A person who has obtained or is required to obtain more than one registration, whether in one State or Union territory or more than one State or Union territory shall, in respect of each such registration, be treated as distinct persons for the purposes of this Act.

As per section 25(5) of the CGST Act, Where a person who has obtained or is required to obtain registration in a State or Union territory in respect of an establishment, has an establishment in another State or Union territory, then such establishments shall be treated as establishments of distinct persons for the purposes of this Act.