CA InterGST › Ch 4

Place of Supply

Goods and Services Tax Paper 3, Sec B ~22 min revision Sections & RulesDefinitionsCirculars

AI-assisted · review in progress · last updated 25 July 2026 · jump to quick revision

In 30 seconds

  1. GST is a destination-based tax — place of supply (PoS) read with location of supplier (LOS) decides inter-State (IGST) vs intra-State (CGST + SGST/UTGST).
  2. Intermediate scope is Section 10 (goods) and Section 12 (services) of the IGST Act, domestic supplies only — Sections 11 and 13 (cross-border) are Final-level.
  3. Goods mnemonic MTNAI: Movement (a), Third person/bill-to-ship-to (b), No movement (c), Address of unregistered recipient (ca), Install/on-board (d)/(e).
  4. Services: always check the specific rules in 12(3)–(14) first; the general rule 12(2) is residual — B2B → LOR, B2C → LOR if address on record, else LOS.
  5. Section 9 territorial-waters deeming applies before the Section 7/8 classification; wrong classification means paying the correct tax and refund-claiming the wrong one — no interest.
Quick-revision mode is on. Prose is hidden — definitions, key lists and tables only.

Based on GST law as on 30.04.2025 (May 2026 exams onwards). Place of supply lives in Chapter V of the IGST Act — section numbers are IGST Act unless stated.

How the chapter fits together

GST is a destination-based tax: it should land where the goods or services are consumed. Place of supply (PoS), read with the location of the supplier (LOS), decides whether a supply is inter-State (IGST) or intra-State (CGST + SGST/UTGST). Section 2(86) of the CGST Act simply points to Chapter V of the IGST Act (Sections 10–14). Intermediate scope: Section 10 (goods) and Section 12 (services), domestic only — Section 11 (import/export of goods) and Section 13 (cross-border services) are Final-level.

Key points
  • Sec 9 first — territorial-waters deeming (“notwithstanding anything in the Act”) →
  • Sec 10 / Sec 12 fix the place of supply →
  • Sec 7 / Sec 8 classify: LOS & PoS in different States/UTs → inter-State (IGST); same State/UT → intra-State (CGST + SGST/UTGST).

Two mnemonics carry the whole chapter:

  • Goods — “MTNAI” (Sec 10): Movement (a) → Third person/bill-to-ship-to (b) → No movement (c) → Address of unregistered recipient (ca) → Install (d) / on board (e).
  • Services — “GRAPES-TIC” (Sec 12): General (2), immovable pRoperty (3), restAurant/grooming (4), Performance/training (5), Event admission (6), organiSation of event (7), Transport of goods (8), passenger transport (9), on-board conveyance (10), telecom (11) — then mentally run the sub-sections in order 2-3-4-5-6-7-8-9-10-11-12-13-14.

Why services need proxies: goods are tangible and easily located, but services are not, so PoS is fixed through proxies — (a) LOS, (b) LOR, (c) place of performance, (d) place of consumption, (e) the place where the benefit flows. The design logic: B2B → LOR (the tax just passes through as ITC), B2C → the actual consumption point (the tax truly lands there).

Two comforting facts: this chapter has no compliance deadlines (the only number worth memorising is 12 nautical miles) and no specific penalties — a wrong PoS classification means the correct tax is still payable plus a refund claim for the wrongly paid tax, with no interest, only procedural and working-capital pain.

Definitions that drive everything

Definition

Location of recipient of services [Sec 2(14) IGST]

A 4-limb cascade: (a) registered place of business → (b) fixed establishment elsewhere → (c) establishment most directly concerned → (d) usual place of residence. Applies to services only — no such definition exists for goods. Sec 2(15) is the mirror cascade for the supplier, keyed to “provision” of the service.

Definition

Fixed establishment [Sec 2(7) IGST]

A place other than the registered place of business, with sufficient permanence plus human AND technical resources, used to supply or to receive/use services. An employee alone is not a fixed establishment without technical resources.

Definition

Continuous journey [Sec 2(3) IGST]

Single or simultaneously issued tickets, from a single supplier or an agent acting for multiple suppliers, with no stopover (= disembarking to transfer or break the journey). A return journey is always a separate journey, even if booked together.

Definition

Recipient [Sec 2(93) CGST]

Consideration payable → the payer; no consideration: goods → to whom delivered, services → to whom rendered; includes an agent. Bill-to-ship-to trap: the person physically collecting the goods is not the “recipient” for Sec 10(1)(b) — the third person is the deemed recipient.

The remaining definitions, table form:

TermCrisp meaningTrap / keyword
Conveyance [2(34) CGST]Vessel, aircraft, vehicleSec 10(1)(e)/12(10) explicitly add “train/motor vehicle”
Place of business [2(85) CGST]Inclusive: where business is ordinarily carried on / warehouse / godown; where books of account are kept; through an agentApplies to both goods & services (unlike 2(14)/2(15))
Supplier [2(105) CGST]Person supplying + agent; deemed supplier = platform owner/operator/manager of specified actionable claims (online money gaming), even if consideration passes “through”Deeming targets digital gaming platforms
Supply [2(21) IGST]Meaning per Sec 7 of the CGST ActCross-reference only
Sec 2(24) IGSTUndefined words take their CGST/UTGST/Compensation Act meaningResiduary cross-reference rule
Intra-State supplyLOS & PoS in the same State/UTCGST + SGST/UTGST
Inter-State supplyLOS & PoS in different States/UTs/State–UTIGST
Distinct persons [Expl. 1, Sec 8]Establishments of the same entity: (i) in a State/UT plus another outside it; (ii) in a State/UT plus another registered within that same State/UTTreated as separate persons
Establishment [Expl. 2, Sec 8]Includes branch, agency, representational office
Territorial watersBelt up to 12 nautical miles from the baseline (UNCLOS; Sec 3(2), Maritime Zones Act 1976)Not defined under GST law
SEZTreated as a place outside India; supplies to/by an SEZ developer/unit are zero-ratedKnowledge-only exception to Sec 8

Place of supply of goods — Section 10

ClauseSituationPlace of supplyTrap / keyword
10(1)(a)Movement of goods involvedWhere the movement terminates for deliveryNot linked to transfer of title
10(1)(b)Bill-to-ship-to (third person directs delivery)Leg 1: principal place of business of the third personDeemed receipt by the third person
10(1)(c)No movementLocation of the goods at the time of deliveryStatic — contrast with (a)
10(1)(ca)Unregistered recipientAddress on the invoice; no address → LOS“Notwithstanding” — overrides (a) & (c); recording only the State name suffices
10(1)(d)Installation / assembly at sitePlace of installation/assemblyComposite supply with goods as principal
10(1)(e)Goods on board a conveyanceLocation where the goods are taken on boardEven if sold by a passenger
10(2)ResidualManner to be prescribedNot yet prescribed

Bill-to-ship-to is really two deemed supplies:

Key points
  • Supply 1 (Supplier → Third person): PoS = the third person’s principal place of business — Sec 10(1)(b).
  • Supply 2 (Third person → Recipient): PoS = where the movement of goods terminates for delivery — Sec 10(1)(a).

Circular 209/3/2024 applies 10(1)(ca) to e-commerce: for an unregistered buyer whose billing address differs from the delivery address, PoS = the delivery address recorded on the invoice.

Place of supply of services — Section 12

Scope first — Sec 12(1): Section 12 applies only when both LOS and LOR are in India; if either is outside India, it is Section 13 territory (Final, not examinable).

General rule — Sec 12(2), residual only: B2B → LOR (the GSTIN is available); B2C → LOR if the address is on record, else LOS. It applies only when none of 12(3)–(14) covers the service — always check the specific list first.

Sub-secServicePlace of supplyProvisos / traps
12(3)Immovable property & lodging: architects, interior decorators, surveyors, engineers, estate agents; hotel/inn/guest house/home stay/club/campsite/houseboat; marriage/function accommodationLocation of the property/boat/vessel — even if only “intended to be located” (under construction)Property outside India → LOR; multi-State → apportion per contract, absent contract → Rule 4 IGST Rules (nights stayed = hotel; area = other property, incl. one property spanning contiguous States; time spent = houseboat)
12(4)Restaurant & catering, personal grooming, fitness, beauty treatment, health servicesPlace actually performedIncludes cosmetic/plastic surgery
12(5)Training & performance appraisalB2B: LOR; B2C: place performed
12(6)Admission to an event / amusement parkPlace the event is held / park is locatedNo B2B/B2C distinction
12(7)Organisation of events + sponsorshipB2B: LOR; B2C: place the event is heldB2C event outside India → LOR; multi-State event → apportion only if the recipient is unregistered, absent contract → Rule 5 (GAAP)
12(8)Transport of goods incl. mail/courierB2B: LOR; B2C: place the goods are handed over for transportApplies even if the destination is outside India, so long as both parties are in India
12(9)Passenger transportB2B: LOR; B2C: embarkation point for a continuous journeyReturn journey = separate journey; future-use right with embarkation unknown at issue → fall back to 12(2)
12(10)Services on board a conveyanceFirst scheduled point of departureNot where boarded; no B2B/B2C distinction
12(11)TelecomVaries by mode — see the ladder belowAddress unavailable → LOS; e-recharge → LOR
12(12)Banking, financial, stock brokingLOR on the supplier’s recordsNot on record → LOS (the classic walk-in bank customer)
12(13)InsuranceB2B: LOR; B2C: LOR on the supplier’s records
12(14)Advertisement to GovernmentEach State/UT covered by the contract, value apportionedAbsent contract → Rule 3 IGST Rules (apportionment detail non-examinable)

The telecom ladder under 12(11):

Key points
  • Fixed line / leased circuit / dish antenna → installation location.
  • Post-paid → billing address on record; else LOS.
  • Pre-paid via agent/reseller/distributor → that agent’s address on record.
  • Pre-paid direct to subscriber → location where payment is received / voucher is sold.
  • Pre-paid via e-payment/internet banking → LOR on record (Proviso 2).
  • Other cases → address on record, else LOS.
  • Leased circuit in more than one State → apportion per contract; absent contract → Rule 6 (number of points; start + end = 2 points; an intermediate point counts only if benefit is available there).

Two more circulars complete Section 12:

  • Circular 242/36/2024: online/digital/OIDAR/online money gaming services to unregistered persons — the State name on the invoice is mandatory and is the deemed address on record, so PoS = LOR under 12(2)(b).
  • Circular 203/15/2023 (hoardings): sale/grant of the right to use the structure = 12(3)(a), property location; but if the vendor retains possession and displays the ad, it is a pure advertisement service under the 12(2) general rule, not 12(3).

Inter-State or intra-State — Sections 7, 8 and 9

ProvisionTestResult / trap
Sec 7(1)/(3)LOS & PoS in two different States / UTs / a State–UT combinationInter-State → IGST (subject to Sec 10/12)
Sec 7(5)(c)Supply in the taxable territory, not intra-State, not covered elsewhereResiduary inter-State catch-all
Sec 8(1)/(2)LOS & PoS in the same State/UTIntra-State → CGST + SGST/UTGST
Sec 8 provisos (knowledge-only)Supplies to/by SEZ developer/unit; goods supplied to a tourist (Sec 15 IGST); imported goodsNever intra-State, even when LOS = PoS State
Sec 9LOS or PoS in territorial watersDeemed to be the nearest coastal State/UT (from the baseline); “notwithstanding anything in the Act” — applied before the Sec 7/8 test

Watch for “notwithstanding” clauses — they signal overriding provisions: 10(1)(ca) over 10(1)(a)/(c), and Sec 9 over the whole Act.

Common mistakes
  • Mixing up 10(1)(a) and 10(1)(c): with movement, PoS = the termination point of movement; without movement, PoS = the goods’ location at the time of delivery (static).
  • Treating admission [12(6)] like organisation [12(7)]: admission is always the place the event is held (no B2B/B2C split); organisation splits — B2B → LOR, B2C → place held.
  • Confusing goods on board [10(1)(e)] with services on board [12(10)]: goods → location taken on board; services → first scheduled point of departure.
  • Sending a 12(3)-proviso case to Section 13: if LOS and LOR are both in India and only the property is abroad, PoS = LOR under 12(3) — Section 13 needs a party outside India (Final, not this chapter).
  • Reaching for the 12(2) general rule before checking 12(3)–(14) — 12(2) applies only when no specific sub-section covers the service.
  • Assuming B2C default PoS is always LOR — it is LOR only if the address is on record, else LOS.
  • Applying the Sec 2(14) four-limb cascade to goods — location of recipient of goods is not defined in the Act; 2(14)/2(15) are services-only.
  • Treating a return journey as part of one continuous journey — it is always a separate journey with its own PoS, even if booked together.

Quick revision cards

Goods mnemonic for Sec 10?

MTNAI — Movement (a), Third person/bill-to-ship-to (b), No movement (c), Address of unregistered recipient (ca), Install (d) / on board (e).

General rule 12(2)?

B2B → LOR; B2C → LOR if address on record, else LOS. Residual — applies only when 12(3)–(14) don’t.

Bill-to-ship-to — two supplies?

Supply 1 (supplier → third person): PoS = third person’s principal place of business [10(1)(b)]. Supply 2 (third person → recipient): PoS = movement termination point [10(1)(a)].

10(1)(ca) unregistered recipient?

Overrides (a)/(c) — PoS = invoice address (State name is enough); no address → LOS.

Admission vs organisation of an event?

Admission [12(6)]: always the place the event is held. Organisation [12(7)]: B2B → LOR; B2C → place held (outside India → LOR).

Goods on board vs services on board?

Goods [10(1)(e)]: location taken on board. Services [12(10)]: first scheduled point of departure.

Passenger transport B2C?

Embarkation point for a continuous journey; return leg = separate journey; future-use right with embarkation unknown → 12(2).

Telecom pre-paid via internet banking/e-mode?

PoS = LOR on record (Proviso 2 to 12(11)); pre-paid via agent → the agent’s address on record.

Walk-in bank customer, no address on record?

PoS = LOS [12(12) proviso].

Sec 9 territorial waters?

LOS/PoS in territorial waters (up to 12 nautical miles) → nearest coastal State/UT; applied before Sec 7/8, notwithstanding anything in the Act.

Immovable property in more than one State?

Apportion per contract; absent contract → Rule 4: nights (hotel), area (other property), time spent (houseboat).

Wrong PoS classification — consequence?

Pay the correct tax and claim refund of the wrong tax; no interest — only procedural/working-capital pain.