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GST - Place of Supply

Concept of Place of Supply


 GST is a destination based tax, i.e., the goods/services will be taxed at the
place where they are consumed and not at the origin. So, the state where
they are consumed will have the right to collect GST.
 This, in turn, makes the concept of place of supply crucial under GST as all
the provisions of GST revolves around it.
I. Supply of Goods Where it involves movement of
Goods
Place of Supply shall be the Location of the goods at the time when movement of the goods terminates for
delivery to the recipient.

Example 1:
Mr A of Maharashtra gets an order from Mr B in Gujarat for supply of T.V. Mr A arranges for transport and supply
goods at the office of Mr B in Gujarat.
Ans
Movement of goods terminates for delivery to the recipient in Gujarat.
Hence Mr A will charge IGST on such supply.
 
Example 2:
Mr A of Maharashtra gets an order from Mr B in Gujarat for supply of T.V. Mr B of Gujarat arranges for transport in
Maharashtra and transporter loads goods and supply goods at the office of Mr B in Gujarat.
 
Ans
Movement of goods terminates for delivery to the recipient in Gujarat.
Hence Mr A will charge IGST on such supply even though his duty / risk is completed in Maharashtra itself.
 
II. Supply of Goods : Where goods are delivered by
supplier to the recipient or any other person on
direction of third person
 Goods shall be delivered to the recipient or any other person.
 Goods shall be delivered on direction of 3rd person who may
be an agent
 Goods directed to be delivered during movement of goods
either by way of transfer of documents of title to the goods or
otherwise.

In this case, Place of Supply shall be the Location of Place of


Business of 3rd person under whose direction goods have
been delivered.
II. Supply of Goods : Where goods are delivered by
supplier to the recipient or any other person on
direction of third person_Illustration
Example 1:
Q.Mr X in Maharashtra places an order to Mr Y in Maharashtra to deliver 100kgs of Material A to Mr Z
in Gujarat.
Ans
Placeof supply shall be location of the person under whose direction goods have been delivered .
Hence place of supply shall be Location of Mr X ie Maharashtra.
Mr Y will charge CGST and SGST to Mr X in Maharashtra.
And Mr X will later charge IGST to Mr Z in Gujarat.

Points to remember
Supplier, Receiver and Third Person all must be engaged in the business.
 
It will be three party transaction where Supplier will raise an invoice to Third Person on whose
direction goods are delivered and that third person will raise an invoice to actual receiver of goods.

 
II. Supply of Goods: Where goods are delivered by supplier
to the recipient or any other person on direction of third
person_Illustration
Example 2:
Q. Mr A of Mumbai a salaried employee has a friend Mr B who has an showroom
of T.V in Mumbai. Mr C of Gujarat a friend of Mr A requires a TV for his office
purpose. Mr A gives direction to Mr B to transfer TV to Gujarat to Mr C.

Ans
Since Mr A is not carrying on any business and has only helped Mr C in finding
a dealer of TV such transaction will not be taxed in hands of Mr A. It will be
directly taxed in hands of Mr C and IGST will be charged
Business connection is essential ingredient.
III. Supply of Goods_Where Supplies does
not involve Movement of Goods.
 Ownership of the goods is changed
 There is no Actual Transfer of the goods

In this case, Place of Supply shall be Location of the Goods at the time of
delivery to the recipient.

Example : 1
 S Ltd. (Chennai) opens a new showroom in Bangalore. It purchases a building
for showroom from ABC Realtors (Bangalore) along with pre-installed
workstations
 Place of supply: Bangalore
 GST: CGST& SGST
 There is no movement of goods (work stations), so the place of supply will be
the location of such goods at the time of delivery (handing over) to the
receiver.
IV. Supply of Goods_Where Goods are
assembled or installed at site.
 In this case, Place of Supply of such goods shall be the Place of Installation
or Assembly.
 Location of the buyer and seller is immaterial.

Q. Mr X of Mumbai, place order on Mr Y of Mumbai for Installation of Generator


in his factory located in Gujarat.
Ans
 Generator is assembled by Mr Y in State of Gujarat. Hence as per Clause d of
Section 10(1), Place of Supply will be the Place where Goods are Installed.
 It is immaterial that both X and Y are located in Mumbai
 Mr Y will charge IGST to Mr X in state of Gujarat.
V. Supply of Goods_Where Goods are
assembled on Board a Conveyance
 In this case, Place of supply of goods shall be the Location where goods are
loaded.

 Location of the buyer and seller is immaterial.

Example 1:
Q. Mr X of Delhi has supplied goods in Delhi to Y airlines (registered under GST in
Maharashtra) flying from Delhi to Chandigarh. Goods are consumed by passengers in
Chandigarh.

Ans
Place of Supply of Goods is Location where goods are loaded. Hence Place of supply
shall be Delhi and Mr X who is also of Delhi shall charge CGST + SGST to airlines.
V. Supply of Goods_Where Goods are
assembled on Board a Conveyance
Example 2:
Mr. Ajay is travelling from Mumbai to Chennai by air on behalf of his company R
Ltd (registered in Bangalore). In the plane he purchases lunch. The airlines is
registered in Mumbai & Chennai. Lunch was loaded in Plane from Mumbai,
Maharashtra.

Ans
Place of supply: Mumbai
GST: CGST & SGST
The food items were loaded into the plane at Mumbai. So, place of supply
becomes Mumbai. It does not matter where the buyer is registered
VI. Supply of Goods_When Goods are
Imported into India or Exported out of India
The place of supply of goods:
Imported into India will be the location of the importer.
Exported from India shall be the location outside India.
VI. Supply of Goods_When Goods are
Imported into India or Exported out of India
Example 1- Import
Q. Ms. Malini imports school bags from China for her shop (registered in Mumbai)

Ans
Place of supply: Mumbai
GST: IGST to be paid

 
Example 2- Export
Q. Ms. Anita (Kolkata) exports Indian perfumes to UK

Ans
Place of supply: Kolkata
GST: Exempted or pay IGST and than claim Refund.
SKIT- Supply of Goods
3 people are standing (Mr A holding paper of Maharashtra, Mr B holding paper of Gujarat, Mr C holding
paper of Delhi) and I am standing as speaker to explain

Case 1: When there is movement of goods:


a)Iwill say that Mr B called to Mr A to deliver him goods of 1 Lakh. Now Mr A will go to place of Mr B and
deliver the goods. Location of supplier is Maha, Location of Recipient is Gujarat and consumption of
goods will take place in Gujarat hence IGST will be charged and Gujarat Govt will take revenue
b)Iwill say that Mr B called to Mr A to deliver him goods of 1 Lakh. Now Mr B is coming to take delivery
of goods. Location of supplier is Maha, Location of Recipient is Gujarat and consumption of goods will
take place in Gujarat hence IGST will be charged. It is immaterial that supplier collects ya recipient.
c)Now I will say that Mr A has sold goods to Mr B. Now Mr A will charge IGST and Gujarat Govt will take
revenue. Later Mr B sold goods to Mr C hence again IGST will be charge and Delhi govt will take
revenue as consumption is in Delhi.

Case 2: Bill to Ship 2 model


a)Now I will explain Bill to Ship To Model by using same example of Pt C. Mr B ne order diya to Mr A for
1 lakh. And same time par Mr C ne same goods k liye order diya to Mr B for 2 lakh. Mr B ne socha ki
kyun transportation ka bhi kharcha karu isliye Mr B ne Mr A ko bola ki directly Mr C ko de do. Ab
supplier is Mr A- Maharashtra and receipient is Mr C – Delhi hence delhi govt took entire revenue. Ab
Maharashtra Govt ne socha ki yaar ye kya hua, na hi Mr A Mr C ko janta tha (and vice versa) to fir ye
dono supplier and recipient kaise hua. Ye to Mr B Maharashtra ki wajah se transaction hua so GST
Revenue mujhe bhi ti milni chahiye. SO Govt ne Mr B ko pakda ki shanna hain tu, is transaction ko
mein double manunga and dono states ko revenue jayegi.
SKIT- Supply of Goods
Case 3: Supply when there is no movement of goods

Mr A school k owner hain. School is in Maharashtra. Mr A ne school ko Mr B of


Delhi ko bech diya. Supplier is of Maha, Receiver is of Delhi. But kya goods maha
se delhi gaya ?. Maha govt bolegi ki goods ka consumption pehle bhi maha mein
tha and aaj bhi maha mein hi hoga. To Fir tax delhi govt ko kaise ?. Also ye school
maha ka space khati hain, maha ka elec, tel, water, internet use karti hain than
GST Revenue bhi maha ko hi milna chahiye. So in case when there is no
movement of goods, POS shall be location of goods.

Case 4: Supply when goods are assembled or board a conveyance


Mein ek plane mein travel kar raha huin from Maha. Ab place mein khana load
kiya. Plane chalu hua and khana mujhe mila Gujarat mein fly kar raha tha tabhi.
Meine ek sip khaya so Gujarat Govt aayi ki tax de. Ab place chal raha hain and
meine dusra sip khaya jab mein delhi mein tha to delhi govt aayi. To mein bhadak
gaya ki kisko tax dena hain. To yaha par consumption tax nahi chalega hence
decide kiya ki jaha goods load honge wo tax lekar jayega.
VII. Supply of Services_General
Rule
VII. Supply of Services_General Rule
Registered to Registered
ILLUSTRATIONS
a) Mr. A, a Chartered Accountant from Karnataka provides consultancy services to
M/s S Ltd. (registered in Maharashtra). Mr A visits office of S Ltd in Maharashtra to
provide consultancy services.
Answer
Place of supply: Maharashtra (location of registered person)
GST: IGST

b) Mr A, a Chartered Accountant from Karnataka receives a querry through EMAIL


from M/s S Ltd. (registered in Maharashtra). Mr A reply to the querry ie consultancy
services through email.

Answer
Place of supply: Maharashtra (location of registered person)
GST: IGST
VII. Supply of Services_General Rule
Registered to Registered
c) Mr A, a Chartered Accountant has its office in Karnataka. Mr B, a Registered Taxable Person from
Maharashtra visits office of Mr A in Karnataka. He gets consultancy services from Mr A from Mr A’s
office.

Answer
Place of supply: Maharashtra (location of registered person)
GST: IGST

d) Mr A, a Chartered Accountant from Karnataka is travelling to Maharashtra to attend a conference.


Mr B a registered taxable person in Maharashtra meets Mr A in Maharashtra through co-incidence
and discuss about his querries. Mr A gives reply to the querries. Mr B gets very happy and so he
himself pays consideration to Mr A. Mr A issues invoice to Mr B

Answer
Location of Supplier : Karnataka (Even though Mr A was in Maharashtra)
Location of Receiver : Maharashtra
GST : IGST
VII. Supply of Services_General Rule Registered to
Registered
e) Mr A, a registered dealer in Karnataka is on a holiday in Kerela. Mr B a
registered taxable person of Maharashtra is also in Kerela on Holiday. Mr A and
Mr B become goods friends in Kerela. Mr B discusses his office querries and Mr A
gives opinion about querries to Mr B. Mr B love the solutions for querries and
hence pay Rs 10,000 to Mr A in Kerela. Mr A later issues invoice to Mr B

Answer
Location of Supplier : Karnataka (Even though Mr A was in Kerela for Holiday)
Location of Receiver : Maharashtra (Even though Mr B was in Kerela for
Holiday)
GST : IGST
VII. Supply of Services_General Rule_Registered to
Un – Registered Person and Address available on
record
ILLUSTRATIONS
a) Mr. Ajay (Karnataka) provides consultancy services to Mr. Vijay (unregistered
but address on record shows Tamil Nadu).
Answer
Place of supply: Tamil Nadu (address of unregistered person is available on
record)

GST: IGST
VII. Supply of Services_General Rule_Registered to
Un – Registered Person and Address not available on
record
ILLUSTRATIONS

a) Mr. Ajay (Karnataka) provides consultancy services to Mr. Anand


(unregistered and address is not available).

Answer
Place of supply: Karnataka (Location of Service Provider)

GST: CGST + SGST


VII. Supply of Services_General Rule_Registered to
Un – Registered Person but change in Address not
intimated
ILLUSTRATIONS

a)MrA, C.A. of Mumbai provides Services to his client Mr X who is un-registered


under GST. Address of Mr X available with C.A. is of Mumbai. Mr X shifts to
Rajasthan but does not inform it to C.A.

Answer
Mr X is unregistered and address on record with Mr A is of Maharashtra
Mr X has not informed Mr A for change in Address.
Place of Supply : Mumbai
GST : CGST + SGST
VIII.Supply of Services_Specific Services

Specific Services covers


Restaurant and Catering Services
Personal Grooming Services
Fitness Services
Beauty Treatment Services
Health Services including Cosmetic and Plastic Surgery
VIII.Supply of Services_Specific Services
Specific Service Recipient Place of Supply Example

1) Restaurant and Any At the PlaceMr A, a caterer based in Maharashtra


Catering Services Person of Location provides catering services for an event in
of RenderingMaharashtra. Place of Supply shall be
the Servicesplace where services are actually
performed. Place of Supply shall be
Maharashtra and GST shall be CGST &
SGST.
2) Services Any At the Place 1) Mr A has beauty clinic in Mumbai. Mr B
pertaining to Person of Location visits clinic and receive beauty services.
personal grooming, of Rendering Place of Supply shall be Location of
fitness, beauty the Services Rendering Services ie Maharashtra.
treatment and 2) Mr A is service provider of Beauty
health services, Treatment. He visits Mr B in Tamil Nadu
(this also includes and provide services at house of Mr B.
cosmetic and Place of Supply shall be Location of
plastic surgery) Rendering Services ie Tamil Nadu.
 
VIII.Supply of Services_Specific
Services
Illustration : Restaurant and Catering
Q . Raj Caterers in Mumbai, Maharashtra, provides catering services to ABC Ltd. (registered in Gujarat) for their annual sales event in
Mumbai.

Ans
Supply of service: Catering
Place of supply: Maharashtra ie place where Catering Services are actually performed
GST to be charged : CGST + SGST by Raj Caterers to ABC Ltd.

Q. Raj Caterers in Mumbai, Maharashtra, provides catering services to ABC Ltd. (registered in Gujarat) for their annual sales event in
Ahmedabad

Ans
Supply of service: Catering
Place of supply: Gujarat ie place where Catering Services are actually performed
GST to be charged : IGST by Raj Caterers to ABC Ltd.

IMPORTANT NOTE
WHETHER RAJ CATERER CHARGES IGST OR OBTAIN NUMBER IN GUJARAT AND CHARGES CGST AND SGST, IN BOTH
CASES, GST STATE COMPONENT WILL GO TO STATE OF GUJARAT.
VIII.Supply of Services_Specific
Services
Illustration : Personal Grooming
Personal Grooming means how people take care of their body and appearances. It includes make up,
hair removal, dressing etc.
As per Cambridge Dictionary it means things that you do to make your appearance clean and neat.

Q.Miss A, from Karnataka visits Mr B’s Saloon for Personal Grooming in Kerala.
Ans
Supply of service: Personal Grooming
Place of supply: Kerala, place where Services are performed
GST to be charged : CGST + SGST of Kerela

Q. Miss A, from Karnataka invites Mr B of Kerela for her personal grooming in state of Karnataka
Ans
Supply of service: Personal Grooming
Place of supply: Karnatka, place where Services are performed
GST to be charged : IGST
VIII.Supply of Services_Specific
Services : Fitness, Beauty Treatment
Illustration
and Healthcare Services
Meaning of Fitness Services shall be the activities carried for physical well being of the individual.

Q. Mr A has opened a Fitness centre in state of Maharashtra. Mr B a registered taxable person of Gujarat visits
Fitness centre in Maharashtra to obtain Fitness Services.
Ans
Supply of Service : Fitness Services
Placeof Supply : Maharashtra, place where Fitness Services are performed. Location of Service Receiver is
immaterial
GST to be charged : CGST & SGST of Maharashtra.

Q. Mr A is a consultant of Beauty Treatment in state of Maharashtra. Mr B of Gujarat invites Mr A to Gujarat to


obtain Fitness Services
Ans
Supply of Service : Beauty Treatment Services
Place of Supply : Gujarat, place where Fitness Services are performed. Location of Service Receiver is immaterial
GST to be charged : IGST.
IX. Supply of Services_Training &
Performance Appraisal.
Training & Performance Recipient is Location of Place of Business of
Appraisal Service Registered Person Registered Recipient

Training and Performance Recipient is Un- Location where Services are performed
Appraisal Service Registered Person
IX. Supply of Services_Training &
Performance Appraisal.
Example 1 – Training to Registered Person
Q. K Ltd of Gujarat hires A Ltd Consultancy registered in Maharashtra to impart
soft-skills training to its employees. The training will be conducted in Mumbai.
Ans
Supply of service: Training
Place of supply: Gujarat (since the recipient is a registered person, location of
place of business of recipient is the place of supply)
GST: IGST (inter-state as supplier is in Maharashtra & recipient is in Gujarat)
IX. Supply of Services_Training &
Performance Appraisal.
Example 2 – Training to Registered Person
Q. Mr X residing in Maharashtra has a factory in state of Gujarat. He hires Mr P
of Mumbai, Maharashtra to provide Training on working of Plant and Machinery
to workers of factory in Gujarat. Workers came to Mumbai for training at office
of Mr P.

Ans
Supply of service: Training
Place of supply: Gujarat (since the recipient is a registered person, location of
place of business of recipient is the place of supply)
GST: IGST (inter-state as supplier is in Maharashtra & recipient is in Gujarat)
IX. Supply of Services_Training &
Performance Appraisal.
Example 3 – Training to Un-Registered Person
Q. Ms. Anita (unregistered person based in Bangalore) signs up with A Ltd
Consultancy (Mumbai) for a training on public speaking. She attends the training
in Mumbai.

Ans
Supply of service: Training
Place of supply: Maharashtra (since the recipient is unregistered person,
location where services are provided is the place of supply)
GST: CGST + SGST of Maharashtra
X. Supply of Services_Admission to an
Event/Park.
Place of Supply shall be Location where Event is held or park is located.

Example 1- Admission to Amusement Parks / Event


Q. A person in Karnataka buys Admission Tickets for Cultural, Artistic, Sporting,
Scientific, Educational, Entertainment etc Event in Kolkata, West Bengal.
Ans
Supply of service: Admission to an Event / Park.
Place of supply: West Bengal (Location of the Event).
GST: CGST+SGST of West Bengal.

Q. A Person of USA buys admission tickets for Imagica in Maharashtra.


Ans
Supply of service: Admission to an Event / Park.
Place of supply: Maharashtra (Location of the park).
GST: CGST+SGST of Maharashtra.
XI. Supply of Services_Organising an
Event
Organizing Events include Cultural, Artistic, Sporting, Scientific, Educational, Entertainment etc.

Case of Registered Person


Place of Supply shall be Location of Recipient.

Case of Un-Registered Person


Place of Supply shall be Location of the Event

Case if Event is Organised outside India


Place of Supply shall be location of recipient irrespective of fact that event is organized outside

India.

Case where Event is organized in more than 1 state


Supply will be treated as made in each of the states, in terms of the contract or agreement and
in
absence of a contract, on such other reasonable basis as may be prescribed.
XI. Supply of Services_Organising an
Event
Example 1- Events managed for registered persons
Y LTD (Mumbai) is hired by A LTD (Gujarat) to organize their annual sales event in Mumbai.
Ans
Supply of service: Organizing an Event
Place of supply: Gujarat
The recipient is a registered person, location of RECEIPIENT is the place of supply. Location of
an Event is immaterial.
GST to be charged : IGST

Example 2- Events managed for unregistered persons


Y LTD (Mumbai) is hired by Mr A (Unregistered based in Bangalore) to manage her sister’s
wedding (held in Mumbai).

Ans
Supply of service: Event management
Place of supply: Mumbai
The recipient is unregistered person, location of EVENT is the place of supply
GST: CGST+SGST
XI. Supply of Services_Organising an
Event
Example 3- Events managed outside India for registered persons
Q. Y LTD (Mumbai) is hired by A LTD (Gujarat) to organize their annual business collaboration event
in Singapore.

Ans
Supply of service: Event management
Place of supply: Gujarat
The recipient is a registered person, location of RECEIPIENT is the place of supply. Location of event
is immaterial.
GST: IGST

Example 4- Events managed outside India for unregistered persons


Q. J LTD (Mumbai) is hired by Ms. Malini (based in Bangalore) to manage her sister’s wedding (held in
Dubai).

Supply of service: Event management


Place of supply: Bangalore
The location of event is outside India, the location of RECIPIENT is the place of supply
GST: IGST
XII. Supply of Services_Immovable Property
What is an immovable property?
An immovable property is an immovable object, a property that cannot be moved without
destroying or altering it. It is fixed to the earth, such as a piece of land or a house.
Immovable property includes premises, property rights (for example, inheritable building
right), houses, land and associated goods, and chattels if they are located on, or below, or
have a fixed address.

Situation for place of supply of services in relation to Immovable Property.


directly in relation to an immovable property, including services provided by architects,
interior decorators, surveyors, engineers and other related experts or estate agents, any
service provided by way of grant of rights to use immovable property or for carrying out or co-
ordination of construction work; or
by way of lodging accommodation by a hotel, inn, guest house, home stay, club or campsite,
by whatever name called, and including a house boat or any other vessel; or
by way of accommodation in any immovable property for organizing any marriage or
reception or matters related thereto, official, social, cultural, religious or business function
including services provided in relation to such function at such property; or
any services ancillary to the services referred to in clauses (a), (b) and (c),
XII. Supply of Services_Immovable Property
XII. Supply of Services_Immovable Property
Input Tax Credit in above

Place of supply of services provided in relation to an immovable property is the


location of the immovable property which means GST will be CGST and SGST.
CGST and SGST credit of one state cannot be used to set-off the liability of
another state. 
In the cases of Mr P (Registered in Gujarat) visits Taj Hotel (Mahar) (cases of
hotel accommodations). Mr P is paying CGST & SGST (Maharashtra) although it
is registered in Gujarat. Therefore, it cannot claim ITC of Maharashtra
SGST & CGST against output Gujarat SGST & CGST.
XIII. Supply of Services_Transportation of Goods
 Transportation of Goods
RECEIVER PLACE OF SUPPLY
 

i) Service Receiver is Registered Person Location of Place of Business of Such Person


(Receiver)
i) Service Receiver is Un-Registered Person Location at which such goods are handed over for
transportation.

Example 1: Goods Transported


XYZ, a goods transportation company based in Karnataka, is hired by A Ltd registered in Karnataka to transport 50
tv sets to Mumbai.
Ans
 Supply of service: Transporting goods
 Place of supply: Karnataka (the location of registered person)
 GST: CGST+ SGST (intra-state)
XIII. Supply of Services_Transportation of Goods
 Transportation of Goods

Example 2 : Goods Transported


XYZ, a goods transportation company based in Karnataka, is hired by V Ltd (registered in Maharashtra)
to transport 200 saris from Bangalore to Mumbai.
Answer
 Supply of service: Transporting goods
 Place of supply: Maharashtra (the location of registered person)
 GST: IGST (inter-state)

Example 3- Goods transportation by unregistered person


Mr. Sharma (in Bangalore) is transferring his car by rail freight to Mumbai. He puts up the car in
Bangalore station.
Answer
 Supply of service: Transporting goods
 Place of supply: Karnataka (Location at which such goods are handed over for their transportation)
 GST: CGST+SGST (Indian railways have a pan-India presence and are registered in all states)
XIII. Supply of Services_Transportation of Goods
 Transportation of Goods

Example 4
Mr X a transporter having registered office in Maharashtra is hired by a person
Mr Y registered in Gujarat. Mr Y stock of goods are in Mumbai and asks Mr X
to transport goods from Mumbai to Nagpur. What will be Place of Supply??
Answer
 Goods are supplied from Mumbai to Nagpur ie Maharashtra to Maharashtra.
 Supplier of Services ie Mr X : Located in Maharashtra.
 Receiver of Services ie Mr Y : Located in Gujarat
 In case Receiver of Services is Registered, Place of Supply of Services for
Transportation of Goods will be Location of Recipient of Services
 Hence Place of Supply shall be Gujarat even though goods are supplied within
the State. Mr X needs to charge IGST.
XIII. Supply of Services_Transportation of Goods
 Transportation of Goods

Example
Mr X a transporter having registered office in Maharashtra is hired by a person Mr Y
Un - registered in Gujarat. Mr Y stock of goods are in Mumbai and asks Mr X to
transport goods from Mumbai to Nagpur. What will be Place of Supply??
Answer
 Goods are supplied from Mumbai to Nagpur ie Maharashtra to Maharashtra.
 Supplier of Services ie Mr X : Located in Maharashtra.
 Receiver of Services ie Mr Y : Located in Gujarat
 In case Receiver of Services is Un-Registered than Place of Supply of Services for
Transportation of Goods will be Location where goods have been handed over for
Transportation ie Mumbai Maharashtra
 Hence Place of Supply shall be Maharashtra and Mr X shall charge CGST & SGST.
XIV.Supply of Services_Transportation of
Passengers
 Transportation of Passengers

Supply of service Place of supply

a) To a registered person Location of Place of Business of registered recipient

b) To an unregistered person Location where the passenger embarks on the conveyance.

Note: For the purposes of passenger transport, the return journey shall be treated as a separate
journey, even if the tickets for onward and return journeys are issued at the same time.

Example1-Registered person
A Ltd, registered in Bangalore, purchased corporate flight tickets from Bangalore to Delhi from ABC Air Travels
Ltd.’s Delhi branch

Answer
 Supply of service: Transporting passengers
 Place of supply: Karnataka (location of registered person)
 GST: IGST.
XIV.Supply of Services_Transportation of
Passengers
 Transportation of Passengers

Example 2-Unregistered person


Q. Ms. Anita books a 2-way air journey from Bangalore to Kolkata. She leaves
Bangalore on 1st Aug and lands in Kolkata the same day. She leaves Kolkata
on 7th Aug and comes back to Bangalore the same day. She booked the
return journey tickets in Bangalore at the same time.
Flight Ticket issued Place of supply GST
by

From Bangalore Bangalore CGST+SGST


Bangalore to branch of (Karnataka)
Kolkata airlines Since she is unregistered, the location where she
embarks the journey becomes place of supply

From Kolkata Bangalore Kolkata IGST


to Bangalore branch of
airlines
XV. Supply of Services_TELECOMMUNICATION
SERVICES
XV. Supply of Services_TELECOMMUNICATION
SERVICES
XVI. Supply of Services_Banking & Financial
Services
Banking & Financial Services: Place of Supply shall be :

•Location of the recipient of services on the records of the supplier of services. (Whether
Registered or Unregistered

Or

•Location of the supplier of services. (If Address is not available)

Insurance Services: Place of Supply shall be :


If Recipient is Registered : Location of Registered Recipient

If Recipient is Un-Registered : Location of Recipient as per Records of Service Provider.


XVI. Supply of Services_Banking & Financial
Services
Case Studies_Place of Supply
Q. Mr. A of Nasik, Maharashtra sells 10 refrigerators to Mr. B of Pune, Maharashtra
for delivery at Mr. B’s place of business in Pune. What will be Place of Supply

Ans : For Goods, Place of supply shall be location where there is termination of
delivery of goods. Hence Place of Supply shall be Pune. Mr A will charge CGST &
SGST.

Q. Mr. X (a supplier registered in Uttar Pradesh having principal place of business


at Noida) asks Mr. Y of Ahmedabad, Gujarat to deliver 50 washing machines to his
buyer Mr. Z at Jaipur, Rajasthan. In this case, how many supplies are involved and
what will be GST Liability.

Ans : It is concept of Bill to Ship to Model.


Sales by Mr Y to Mr X : IGST, Place of Supply is UP
Sales by Mr X to Mr Z : IGST, Place of Supply is Rajasthan
Case Studies_Place of Supply
Q. Mr. A (New Delhi) has leased his machine (cost Rs 8,00,000) to Mr. B (Noida, Uttar
Pradesh) for production of goods on a monthly rent of Rs. 40,000. After 14 months Mr.
B requested Mr. A to sell the machine to him for Rs 4,00,000, which is agreed to by Mr.
A. What will be Place of Supply for sale of Machine ?

Ans : Supply will be Inter State ie from New Delhi to UP and IGST to be charged.
Actually goods are with Mr B only at time of sale but still it will be deemed that goods
have moved from New Delhi to UP.

Q. XZ Ltd. (Mumbai, Maharashtra) opens a new branch office at Gurugram, Haryana.
It purchases a building for office from KTS Builders (Gurugram) along with pre-installed
office furniture and fixtures. What will be place of supply ?

Ans : Such Supply is case of supply without movement of goods. Hence Place of supply
shall be Location of Goods at time of Supply. Hence Supply shall be Gurugam. CGST &
SGST shall be charged.
Case Studies_Place of Supply
Q. P Ltd (Mumbai, Maharashtra) gives a contract to PQ Ltd. (Ranchi, Jharkhand) to
assemble a power plant in its Kutch, Gujarat refinery. What will be Place of
Supply ?

Ans: Place of Supply shall be location where installation is done. P LTD needs to
charge IGST since it is Inter State Sales.

Q. Mr. X (New Delhi) boards the New Delhi-Kolkata train at New Delhi. He sells
the goods taken on board by him (at New Delhi), at Jaipur during the journey.
What is place of Supply?

Ans : Place of Supply shall be Location where goods are assembled on board a
conveyance. Since Mr X has loaded goods in new delhi place of supply shall be
New Delhi.
Case Studies_Place of Supply
Q. Ms. M imports electric kettles from China for her Kitchen Store in Noida, Uttar
Pradesh. Ms. M is registered in Uttar Pradesh. The place of supply is ?

Ans: In case of Import, Place of Supply shall be location (state) where we have
imported. Hence Place of Supply shall be UP.

Q. Mr. A (a Chartered Accountant registered in New Delhi) makes a supply of


service to his client Mr. B of Noida, Uttar Pradesh (registered in Uttar Pradesh).
What will be Place of Supply ?

Ans: Since supplier is registered Place of Supply shall be Location of Recipient ie


UP.
Case Studies_Place of Supply
Q. Mr. A, a barber in Haryana, (registered) provides hair cutting services to his
client Mr. C who is a resident of New Delhi but is not registered under GST. Mr C
had come to saloon of Mr A. What is Place of Supply ?

Ans : Services provided are specific services hence place of supply shall be
Location where Services are performed. Hence POS shall be Haryana. Mr A shall
charge CGST & SGST.

Q. S Ltd, an architectural firm at Kolkata, has been hired by MKF Builders of


Mumbai to draw up a plan for a high rise building to be constructed by them in
Ahmedabad, Gujarat. What is place of supply ?

Ans : Services provided are in relation to Immovable Property in Gujarat. Hence


Place of Supply shall be Location of Immovable Property ie Gujarat. IGST to be
charged.
Case Studies_Place of Supply
Q. Sometimes the immovable property may extend to more than one location, for
example, a railway line, a national highway or a bridge on a river may originate in
one State and end in the other State or a house boat stay may traverse more than
one State.

Ans : Place of Supply shall be each state as per terms of contract. The service is
deemed to have been supplied in each of the respective States/Union territories,
proportionately in terms of the value of the services.

Q. Mr. A, a business man from Delhi dines in a restaurant at Mumbai while on a


business trip. What will be Place of Supply ?

Ans : Restaurant Services are covered under Specific Services. Place of Supply
shall be Location where Services are performed ie location of Restaurant ie
Mumbai. Restaurant will charge CGST & SGST.
Case Studies_Place of Supply
Q. Mr P, a makeup artist at Kolkata, goes to Jaipur, Rajasthan for doing the makeup of Ms. Simran
Kapoor, a Bollywood actress registered in Mumbai.

Ans : Make up services are covered under Specific Services. Place of Supply shall be location
where Services are performed ie Rajashthan. IGST to be charged. It is immaterial that Mr P is of
Kolkata and Simran is of Maharashtra.

Q. Mr Pratik of Mumbai impart GST training to accounts and finance personnel of S Ltd. (Assam)
at the company ’s Kolkata office. S Ltd is Registered in Assam.

Ans : Such services are covered under Training. Since S Ltd is registered Place of Supply shall be
Location of Recipient ie Assam. It is immaterial that Services were provided in Kolkata. IGST to be
charged

Q. Mr Pratik of Mumbai impart GST training to accounts and finance personnel of S Ltd. (Assam)
at the company ’s Kolkata office. S Ltd is Un-Registered.

Ans : Such services are covered under Training. Since S Ltd is Un-Registered, Place of Supply shall
be Location where Services are performed. Hence Place of Supply shall be Kolkata. IGST to be
charged.
Case Studies_Place of Supply
Q. Mr. B of New Delhi buys a ticket for an amusement park located in UP. What will be
Place of Supply ?

Ans : Services are of Admission to an Event. Place of Supply for Admission shall always
be location where Event is held. Hence POS shall be UP.

Q. Mega Events, an event management company at New Delhi, organizes an award


function for P Ltd of Ahmedabad (registered in Gujarat). Event was held in Mumbai

Ans : Services are of Organizing an Event. Place of Supply for Registered Recipient shall
be location of Recipient. Hence POS shall be Gujarat and IGST will be charged. It is
immaterial that Event was held in Mumbai.

Q. Mega Events, an event management company at New Delhi, organizes an award


function for P Ltd of Ahmedabad (registered in Gujarat). Event was held in Dubai.

Ans : Services are of Organizing an Event. Place of Supply for Registered Recipient shall
be location of Recipient. Hence POS shall be Gujarat and IGST will be charged. It is
immaterial that Event was held in Dubai.
Case Studies_Place of Supply
Q. Grand Wedding Planners (Chennai) is hired by Mr. Ramesh (unregistered person
based in Hyderabad) to plan and organise his wedding at New Delhi.

Ans : Services are of Organizing an Event. Since Recipient is URD hence POS shall be
Location where Event is held ie New Delhi. Hence IGST will be charged.

Q. PR Pvt. Ltd., a GTA Registered in Kanpur, Uttar Pradesh, is hired by P Ltd


(registered in Mah) to transport its consignment of goods to a buyer in New Delhi.
What will be POS ?

Ans : Services are of Transportation of Goods. POS shall be Location of Registered


Recipient ie Maharashtra. It is immaterial that goods are transported to Delhi.
Case Studies_Place of Supply
Q. Mr A (Un-Registered) is transferred from UP to Mumbai. He hires GTA which
transports his household goods and his family both to Mumbai. What will be POS ?

Ans : Services in above question are for Transportation of Goods as well as


Transportation of Passengers.
For Goods : Since Mr A is URD, POS shall be location where goods are loaded ie UP.
For Services : Since Mr A is URD POS shall be location where passenger embarks the
journey ie UP.

Q. A circus team from Russia organizes a circus in New Delhi. What will be POS ?

Since Circus Team is an NRI, they need to obtain GST Number on temporary basis.
Place of Supply shall be location of an event ie New Delhi.
Case Studies_Place of Supply
Q. Mr. A, CEO of XY Ltd., Mumbai (a company registered in Maharashtra buys
insurance cover for the inventory stored in company’s factory located at Mumbai,
from Excellent Insurers, Chennai (registered in Tamil Nadu). What is Place of
Supply ?

Ans : Case is of Insurance Services. Since Recipient is registered POS is Location of


Recipient. Since Supplier is of Tamil Nadu and Recipient is in Maharashtra hence
Insurancer will charge IGST.
Section 13 of (IGST Act, 2017) : Place of Supply
of Services (Supplier or Recipient located
Outside India)
SUPPLY RECEIVE PLACE OF
R SUPPLY
EXAMPLE

Services supplied in respect of Any Location A Ltd (UK) sends an


goods which are required to be Person where engineer to Delhi to repair
made physically available by Services are Air India Aircrafts. Place of
the recipient of services to the actually Supply shall be Delhi ie
supplier of services, or to a performed Place where Services are
person acting on behalf of the performed. IGST.
supplier of services in order to
provide the services
Services are provided from a Any Location A Ltd (UK) provides
remote location by way of Person where goods Services through Internet
electronic means are situated to Air India Aircrafts for
at time of Aircraft in Delhi. POS shall
Supply of be Delhi ie Location of
Services. Goods at time of Supply.
Services which require physical Individual Location A Gym Trainer from US
presence of the recipient (with (or person where came to Mumbai to train
Service Provider) on his services are actors for a movie. POS
Section 13 of (IGST Act, 2017) : Place of Supply
of Services (Supplier or Recipient located
Outside India)
SUPPLY RECEIVE PLACE OF
R SUPPLY
EXAMPLE

Services supplied in respect of Any Location An Architect from France


Immovable Property Person where was hired by Mr B to
Immovable design a Building on Pune.
Property is POS shall be PUNE hence
Located IGST under Reverse
Charge.

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