1

Place of Supply of Goods/

Services

© Indirect Taxes Committee, ICAI

 Place of Supply of Goods – Sec 10 IGST
(other than goods imported / exported) 2

Section 10(1)(a) Section 10(1)(b) Section 10(1)(c) Section 10(1)(d) Section 10(1)(e)
Supply involves Goods supplied on Supply does not Goods are Goods supplied on
movement of direction of the involves movement assembled or board a
Goods third person of goods installed at site conveyance

Location of Principal Place

goods at the of Business of Location of
Location at
time at which the third goods at the Place of
which such
movement person (i.e., time of installation or
goods are
terminates for address in delivery to the assembly
taken on board
delivery to Registration recipient
recipient Certificate)

Sec 10(2) - Where none of the above rules apply, place of supply would be determined in the manner to be
prescribed
© Indirect Taxes Committee, ICAI
 Place of Supply of Goods – Sec 10 IGST
Illustrations 3

Section 10(1)(a): Supply involves movement of goods

Supplier's factory Termination of

Place of
Particulars from where goods movement for Tax Payable
supply
are removed delivery

Movement of goods by the supplier IGST payable at

Orissa Assam Assam
(goods dispatched by supplier) Orissa

[Section 10(1)(a) read with 2(96)(a) of CGST / SGST

Orissa Orissa Orissa
CGST Act] payable at Orissa

Movement of goods by the recipient IGST payable at

Kerala Goa Goa
(goods collected by recipient) Kerala

[Section 10(1)(a) read with 2(96)(b) of CGST / SGST

Kerala Kerala Kerala
CGST Act] payable at Kerala

© Indirect Taxes Committee, ICAI

 Place of Supply of Goods – Sec 10 IGST
Illustrations 4
Section 10(1)(b): Supply involves movement of goods, and delivered to a person on the
instruction of a third person
Principal place of
Place of delivery of Place of
Location of Lakshman who Type of tax payable by
Case goods - Office of supply for
Supplier - Seeta instructed delivery to Seeta
Ram Seeta
Ram
1 Ahmedabad Ahmedabad Amritsar Amritsar IGST at Ahmedabad
2 Ahmedabad Amritsar Amritsar Amritsar IGST at Ahmedabad
3 Ahmedabad Bangalore Bangalore Bangalore IGST at Ahmedabad
4 Ahmedabad Chandigarh Udaipur Udaipur IGST at Ahmedabad

Case Location of Place of delivery Principal place of Place of supply Type of tax payable by
Supplier - Seeta of goods - Office Lakshman who for Lakshman Lakshman
of Ram instructed delivery to
Ram
1 Ahmedabad Ahmedabad Amritsar Ahmedabad IGST at Punjab
2 Ahmedabad Amritsar Amritsar Amritsar CGST + Punjab GST
3 Ahmedabad Bangalore Bangalore Bangalore CGST + Kar GST at
Karnataka
4 Ahmedabad Chandigarh Udaipur Chandigarh IGST at Rajasthan
© Indirect Taxes Committee, ICAI
 Place of Supply of ‘Goods’ S. 10(1)(a)
5

IGST

A B

Supplier (U.P) Recipient (Punjab)

© Indirect Taxes Committee, ICAI

 Place of Supply of ‘Goods’ S. (10)(1)(b)
6

IGST - 10(1)(b)

B C

Supplier (U.P) Recipient (Punjab)

A
Third Party
(Delhi)

© Indirect Taxes Committee, ICAI

 Place of Supply of ‘Goods’ S. 10(1)(b)
7
IGST

B C

Supplier (U.P) Recipient (UP)

A
Third Party
(Delhi)

© Indirect Taxes Committee, ICAI

 Place of Supply of ‘Goods’ S. 10(1)(b) 8

CGST / SGST

B C

Supplier (U.P) Recipient (Punjab)

A
Third Party
(UP)
© Indirect Taxes Committee, ICAI
 Place of Supply of ‘Goods’ 9

B C

Supplier (U.P) Recipient (Punjab)

A
Third Party
(Delhi)

© Indirect Taxes Committee, ICAI

 Place of Supply of Goods – Sec 10 IGST
Illustrations 10

Section 10(1)(c): Supply does not involve movement of goods

Location of Location of Location of Place of Tax

Particulars
supplier recipient goods supply Payable
IGST
Sale of pre-installed DG Set Delhi Bhopal Bhopal Bhopal payable at
Delhi
Manufacture of moulds by CGST + TN
job-worker (supplier), sold to Tamil GST
Tamil Nadu Kerala Tamil Nadu
the Principal, but retained in Nadu payable at
job worker’s premises Tamil Nadu
Noida
But in this case, CGST + Sik
A businessman in Noida has
Sikkim GST
an old car lying unused in his Sikkim Sikkim Sikkim
(registration as payable at
hometown in Sikkim
casual taxable Sikkim
person)

© Indirect Taxes Committee, ICAI

 Place of Supply of Goods – Sec 10 IGST
Illustrations 11

Section 10(1)(d): Supply of goods assembles/ installed at site

Registered Installation/
Location of Place of
Particulars office of Assembly Tax Payable
supplier supply
recipient Site
IGST
Installation of weigh bridge Delhi Bhopal Bhopal Bhopal payable at
Delhi
CGST + Kar
Servers supplied and installed
Karnataka Goa Karnataka Karnataka GST payable
at the office of a marketing firm
at Karnataka

IGST
Supply of work-stations Gujarat Gujarat Kerala Kerala payable at
Gujarat

© Indirect Taxes Committee, ICAI

 Place of Supply of Goods – Sec 10 IGST
Illustrations 12

Section 10(1)(e): Supply of goods supplied on board a conveyance

Location of Loading of Passenger Place of

Particulars Tax Payable
supplier goods boards at supply
CGST + Pun
Supply of canned aerated
Punjab Punjab Delhi Punjab GST payable
drinks on a flight
at Punjab
Sale of Haldirams mixtures by IGST
their sales person during the Pune Goa Hyderabad Goa payable at
journey Pune

IGST
Sale of sun-glasses on a ship Bangalore Chennai Cochin Chennai payable at
Bangalore

© Indirect Taxes Committee, ICAI

 Place of Supply of Goods – Sec 11 IGST
(goods imported into / exported from India) 13

 Export of goods: Means taking goods out of India to a place outside India;
 Import of goods: Means bringing goods into India from a place outside India;

Section Situation Place of supply

11(a) Goods imported into India Location of importer (Place of
supply of goods)
11(b) Goods exported from India Location outside India
Note: Section 5 provides that IGST shall be levied on goods imported into India as per
Section 3 of Customs Tariff Act
 Point of taxation - When duties of customs are levied on the said goods
 Value - As determined as per Customs Act

© Indirect Taxes Committee, ICAI

 Place of Supply of Goods – Sec 11 IGST
(Illustrations) 14
Section 11(a): Import of goods
Case Location of Location of Goods Location of Place of supply
supplier goods before supplied to recipient
supply
1 Thailand Thailand Assam Assam Assam
2 China China Kashmir Haryana Kashmir
3 Sri Lanka Sri Lanka Kerala Kerala Kerala
4 Karnataka Iran Dubai Karnataka Not an import
Section 11(b): Export of goods
Case Location of Location of Goods supplied Location of Place of supply
supplier goods to recipient
1 Assam Assam Thailand Assam Thailand
2 Tamil Nadu Kashmir China Texas China
3 Sri Lanka Kerala Sri Lanka Sri Lanka Sri Lanka
4 Maharashtra Dubai Iran Iran Not an export

© Indirect Taxes Committee, ICAI

 Place of Supply of Services – Sec 12 IGST
(where supplier and recipient are in India) 15

Section 12(2)(a)): Registered recipient:

For Supply of any other
Service,
Place of supply is:
(General Rule)
Location of recipient
Section 12(2)(b): Unregistered recipient:
Location of recipient if address in supplier’s
records
Location of supplier if address not available

© Indirect Taxes Committee, ICAI

 Place of Supply of Services – Sec 12 IGST
(where supplier and recipient are in India) 16

Services directly in relation to:

a) Immovable property – grant-of-
rights, construction, use,
accommodation, marriage, letting
out, architects, surveyors, etc.
b) Boat, Vessel – lodging, club, etc.
c) Ancillary services to the above
Supply of:
Place of supply - Section 12(3):
Location of property/ boat/
vessel
If property is outside India –
Location of Recipient

a) Restaurant and catering

b) Personal grooming
Place of supply - Section 12(4):
c) Fitness
Location of ‘actual’
d) Beauty treatment performance
e) Health service including cosmetic
© Indirect Taxes Committee, ICAI and plastic surgery
 12(3)
17
Que: An architect contracted to design the landscaping of particular resort hotel in
Goa. Place of supply?
Goa
Que : Mr. Suresh is marketing head of a Delhi based leading software development
company. On an official visit, Mr. Suresh goes to Mumbai and stays in Hotel Taj.
Invoice is prepared at the time of check-out in the name of the software company.
Place of Supply?
Location of recipient of supply is in Delhi. Location of the supplier is in
Mumbai. Place of supply is Mumbai (i.e. place where Hotel Taj is located)

Mr Keshav of Hyderabad takes a function hall on rent in Bangalore to perform

marriage function of his son. Place of supply?
© Indirect Taxes Committee, ICAI
 18
12(4)

 X Ltd is an event management service provider and located in Mumbai. It organises

a fashion show in Dubai for Raymond. For this purpose, it engages a beauty parlour
in Dubai for giving beauty treatment for its models in Dubai. Place of supply?

Dubai. GST is not applicable on amount charged by beauty parlour from X Ltd.

© Indirect Taxes Committee, ICAI

 Place of Supply of Services – Sec 12 IGST
(where supplier and recipient are in India) 19
Sec 12(5): Supply of Sec 12(7): Supply of:
Sec 12(6): Supply of
Services of Training a) Organising cultural, arts,
Services for admission to:
and Performance sports, educational, scientific,
a) Cultural and artistic
Appraisal entertainment, conference, fair
b) Sporting
exhibition or similar events
c) Scientific and
Registered b) Services ancillary to above
educational
recipient:
d) Entertainment event
Location of e) Amusement Park Registered recipient:
recipient
f) Services ancillary to Location of recipient
above
Unregistered
recipient:
Unregistered
Place of ‘actual’ recipient:
performance Venue of event/
park Venue of event

Event outside India:

Location of recipient
© Indirect Taxes Committee, ICAI
 20
12(5)
Princeton Academy (P) Ltd is a leader in executive education and corporate
training. It is located in Mumbai. On October 13, it organises a corporate training
programme on Transfer Pricing at Oberai Hotel. From the list of participants, a few
names are given below-
 Employees of A Ltd., Delhi (X and Y from tax department attended the training
programme
 C, an individual (He is a research scholar)
Place of Supply?

A Ltd is a registered GST dealer in Delhi. – Delhi – Inter-state supply

C is an individual – Mumbai – Intra-state supply

© Indirect Taxes Committee, ICAI

 21
12(6)

 X of Delhi visits Hyderabad. During his stay in Hyderabad, he visits Wonderla.

Place of supply?
Hyderabad

© Indirect Taxes Committee, ICAI

 22
12(7)

 X Ltd is an Indian company based in Pune and engaged in fashion designing. It is

not registered under GST to organize a fashion show in Dubai. X Ltd engages Y&
Co, an event organisor based in Mumbai (having GST registration). To organise
Dubai fashion show, it charges Rs 4 lakh from X Ltd. Place of Supply?
 In this case, service provider is Y & Co, a registered dealer. Supply is received by X
Ltd, an unregistered dealer. Event is held outside India.
Accordingly, place of supply of service is location of recipient (Pune). GST is
applicable- It is intra-state supply. Y&Co. charges CGST and SGST

Suppose event is held in Chennai. Place of Supply?

Chennai
© Indirect Taxes Committee, ICAI
 Place of Supply of Services – Sec 12 IGST
(where supplier and recipient are in India) 23

Sec 12(8): Transportation of Registered Recipient: Location of Recipient

goods, including by mail or Unregistered Recipient: Location where goods
courier handed over for transportation

Registered Recipient: Place of Registered

Sec 12(9): Passenger Recipient
Supply of Transportation Service (Return
services of: journey treated as separate Unregistered Recipient: Place where passenger
journey) embarks on the conveyance for a continuous
journey

Sec 12 (10): Services on board

First scheduled point of departure of that
conveyance like vessel,
conveyance for that journey
aircraft, train, motor vehicle
© Indirect Taxes Committee, ICAI
 24
12(8)

 X Ltd is Indore based GST registered company. It engages a courier company

located in Nagpur to send its samples by courier from Nagpur to different locations.
Place of supply?
Indore as recipient is registered and located in Indore

Suppose in the above case, X Ltd is not registered under GST, Place of Supply?

Nagpur (Place where goods are handed over to the courier)

© Indirect Taxes Committee, ICAI

 25
12(9)

 X Ltd is a GST registered company located at Chennai. On December 1, 2017, it

books Delhi-Hongkong for B (who is marketing head of the company). The
booking is made on official website of Jet Airways. Place of Supply?
Chennai
Suppose, in the above case, ticket is booked by B himself, he does not give name
of X Ltd and GSTIN of X Lt to the Airlines. B is not registered under GST. Place
of Supply?

Delhi, as it is the place where passenger embarks on the conveyance for a

continuous journey.

© Indirect Taxes Committee, ICAI

 26
12(10)

 Air Asia provides a video game or a movie on demand on board as entertainment

against a charge during the Kolkata-Delhi leg of a Bankok- Kolkata-Delhi flight.
Place of supply?
Bankok, which is situated in a non taxable territory and consequently not
chargeable to GST.
Conversely, if the above service is provided by Air Asia on board in its Delhi-
Kolkata-Bankok-Jakarta flight during the Bankok-Jakarta leg. Place of supply?

Delhi and GST is applicable

© Indirect Taxes Committee, ICAI

 Place of Supply of Services – Sec 12(11) IGST
(where supplier and recipient are in India) 27
(a) Services of fixed
including data transfer, broadcasting,
Supply of telecommunication services

telecommunication line, leased

Location where line / device is installed
circuits, internet leased circuit,
cable or dish antenna
DTH, cable etc.

(b) Post-paid mobile connection for

Location of billing address of the recipient on
telecommunication and internet
record
services*

Through internet: Location of recipient on

record
(c) Pre-paid mobile connection for
Through selling agents: Location of selling
telecommunication and internet
agent on record of supplier
services*
Though others: Location where pre-payment
received / vouchers sold
• In cases not covered, address of recipient on records shall be the place of supply;
• Where no address of the recipient available in records, location of the supplier shall be the place of supply
© Indirect Taxes Committee, ICAI
 Place of Supply of Services – Sec 12 IGST
(where supplier and recipient are in India) 28

Supply of:

Sec 12(12) Banking Sec 12(14)

and Other Financial Sec 12(13) Insurance Advertisement
Services including Services Services to
Stock Broking Government, etc.

Registered recipient:
Location of recipient
Location of recipient Place is State of
in suppliers records
dissemination in
Unregistered recipient:
(If not available, proportion
Location of recipient in
location of supplier)
supplier’s records

© Indirect Taxes Committee, ICAI

 29
12(14)

 X Ltd is registered in Chennai. It provides advertisement services. It enters into an

agreement with Kerala Government to provide advertisement services pertaining to
Swach Bharath Abhiyan in the entire state of Kerala. Place of supply of service?
Kerala

© Indirect Taxes Committee, ICAI

 Place of Supply of Services – Sec 13 IGST
(where supplier or recipient is outside India) 30
Service by way of Banking services to
Services when goods Services supplied admission to / Transportation of
account holders,
required to be made directly in relation to organising an event, intermediary services, goods (other than by
physically available immovable property etc. and ancillary hiring of means of way of mail / courier)
by recipient or services transport (other than
requiring physical aircraft and vessels)
presence of receiver / upto 1 month
person acting on his
behalf

Location of such
immovable Place where the
Location where Location of Destination of
property (or event is actually
services actually supplier the goods
where it is held
performed
intended to be
located)

1 to 3  When supplied at >1 location (including India)  Deemed location in India.

When supplied from >1 state / UT  In proportion to the value of services
© Indirect Taxes Committee, ICAI
 31
13(3)

 X of Hong Kong provides software repair services to Y Ltd of Mumbai. Service is

performed at software development site of Y Lt in Chennai.
Since service is performed in Chennai, Place of Supply is Chennai.

X sends a consignment of artificial grass from Hyderabad to Hong Kong by air.

The place of supply of transportation of service will be Hong Kong.

© Indirect Taxes Committee, ICAI

 Place of Supply of Services – Sec 13 IGST
(where supplier or recipient is outside India) 32
To prevent double
Passenger Service provided taxation / non-
transportation on board a Online information Residuary taxation, or for the
service conveyance and database uniform
access or retrieval application of
services rules, CG has
power to notify
Location of the services/
First
recipient; circumstances
Place where scheduled
passenger point of If not available
embarks on the departure of Location of in the ordinary Place of
conveyance for that recipient course of effective use
a continuous conveyance business, and enjoyment
journey for that location of of a service
journey supplier

© Indirect Taxes Committee, ICAI

 33
13(5)

 A management school located in the Netherlands organizes a road show in Mumbai

for prospective students. Any service provided by an event management will be
deemed to be provided in
Mumbai
A single ticket is issued by Air India to a foreign tourist for Delhi-Mumbai-Dubai-
London journey. Place of Supply
Delhi
A single ticket is issued by Jet Airways for London-Mumbai-London flight. Date
of flight for London-Mumbai sector: October 10, for return journey Mumbai-
London, October 27. Place of Supply?
Place of Supply for onward journey – London
Place of Supply for return journey - Mumbai
© Indirect Taxes Committee, ICAI