Time of Supply
AI-assisted · review in progress · last updated 25 July 2026 · jump to quick revision
In 30 seconds
- Time of supply (ToS) fixes when the GST liability arises — the tax itself is paid later, by the due date reckoned with reference to that ToS. Section 20 of the IGST Act borrows the same rules for IGST.
- Map the chapter as GIVE PAY VRA: Goods s.12 / serVices s.13 → Vouchers (4) → Residual (5) → Addition in value (6), each split into FCM (sub-section 2) and RCM (sub-section 3).
- Goods golden rule: NO GST on advances (Notif 66/2017 CT) — ToS is the invoice date / last date to issue alone. Services contrast: an advance DOES trigger ToS.
- RCM flips the direction: FCM tests watch the supplier's acts, RCM tests watch the recipient's — with backstops on the 31st day (goods) / 61st day (services) from the supplier's invoice.
- Section 31 is the twin invoice-timing section, with Rules 47/47A supplying the actual day counts; s.14 (rate change) is Final level and not tested from this chapter.
Based on GST law as on 30.04.2025 (May 2026 exams onwards). Section numbers are CGST Act unless stated.
How the chapter fits together
Time of supply answers one question: at what point in time does the GST liability arise? The tax is actually paid later, by the due date reckoned with reference to the ToS. The whole chapter is two mirror sections with identical skeletons:
- Goods → s.12; Services → s.13 — parallel sections, same structure.
- Within each: (2) forward charge → (3) reverse charge → (4) vouchers → (5) residual → (6) addition in value.
- Mnemonic — “GIVE PAY VRA”: Goods s.12 / serVices s.13 → Voucher (4) → Residual (5) → Addition-in-value (6); each split FCM (2) / RCM (3).
- s.31 (invoice) is the twin section — always read together; the actual day counts come from Rules 47/47A, not the Act.
- s.20 IGST Act applies the s.12/13 CGST ToS rules to IGST too.
Two golden rules run through every question:
- Goods, FCM: NO GST on ADVANCE (Notif 66/2017 CT) — the biggest exam contrast vs services, where an advance DOES trigger ToS.
- RCM: the direction flips — FCM tests look at the supplier’s acts (invoice issued, payment received); RCM tests look at the recipient’s acts (receipt, payment recorded) plus a backstop tied to the supplier’s invoice (31 days goods / 60 days services).
Scope note: s.14 (change in rate of tax) is Final level — it fixes ToS when the tax rate changes mid-supply, and is only referenced, not tested at Inter from this chapter. s.148 (the enabling provision behind Notif 66/2017) is likewise Final-level detail.
| Situation | Goods [s.12] | Services [s.13] |
|---|---|---|
| FCM — statutory rule | Earlier of [invoice date / last date to issue u/s 31] vs [payment — books entry or bank credit, earlier] [12(2)] | Invoice in time (Rule 47): earlier of invoice date vs payment [13(2)(a)]; invoice late: earlier of provision date vs payment [13(2)(b)]; neither ascertainable: recipient’s books entry [13(2)(c)] |
| FCM — practical rule | Notif 66/2017 CT: invoice date / last date to issue ONLY — advance ignored (excl. composition & specified actionable claims) | Advance DOES trigger ToS if earlier |
| RCM | Earliest of receipt of goods / payment (books or bank debit, earlier) / 31st day from supplier’s invoice [12(3)] | Earlier of payment / 61st day from supplier’s invoice (or date of recipient’s invoice) [13(3)] |
| RCM — undeterminable | Recipient’s books-entry date [proviso to 12(3)] | Recipient’s books-entry date [proviso 1 to 13(3)]; AE import from abroad: earlier of books entry / payment [proviso 2] |
| Vouchers | Issue (identifiable) / redemption (otherwise) [12(4)] | Same [13(4)] |
| Residual | Return due date / date tax paid [12(5)] | Same [13(5)] |
| Addition in value | Date supplier receives interest/late fee/penalty [12(6)] | Same [13(6)] |
Time of supply
The point in time when the GST liability arises. Trap: the tax is actually paid later, by the due date reckoned with reference to the ToS.
Reverse charge [Sec 2(98)]
Liability to pay tax falls on the recipient instead of the supplier, under s.9(3)/9(4) CGST or s.5(3)/5(4) IGST. Both notified-category RCM and URD-purchase RCM trigger s.12(3)/13(3).
Time of supply of goods — Section 12
Forward charge [12(2)]: the statutory rule is the earlier of the invoice date (or the last date on which the invoice ought to be issued u/s 31) versus the date of payment (itself the earlier of books entry or credit in bank — Explanation 2 to 12(2)). But Notification 66/2017 CT (issued under s.148) rewrites the practical answer:
- For all registered persons except composition suppliers and suppliers of specified actionable claims, the advance is IGNORED — ToS = invoice date / last date to issue the invoice, only [12(2)(a)].
- The excluded categories (composition; specified actionable claims — where the platform operator is the deemed supplier u/s 2(105), incl. VDA) follow plain s.12(2), so the advance is relevant for them.
- Decision rule: check the invoice date / last date to issue u/s 31 FIRST — under Notif 66/2017 that alone is the ToS.
Reverse charge [12(3)]: ToS is the earliest of three dates — (a) receipt of goods, (b) payment (recorded in books or debited in bank, earlier), (c) the 31st day from the supplier’s invoice. Proviso: if none of the three is determinable, ToS = date of entry in the recipient’s books.
Time of supply of services — Section 13
Forward charge [13(2)] hinges on whether the invoice was issued in time — i.e. within the Rule 47 window of 30 days (45 days for an insurer/bank/FI/NBFC) from the date of supply of service:
- Method A — invoice in time [13(2)(a)]: earlier of invoice date vs payment date (books/bank, earlier).
- Method B — invoice late [13(2)(b)]: earlier of date of provision of service vs payment date.
- Fallback [13(2)(c)]: neither ascertainable → date the recipient shows receipt in their books.
Reverse charge [13(3)]: ToS is the earlier of the payment date (books entry or bank debit, earlier) and the 61st day from the supplier’s invoice (supplier-invoice cases) — or the date of the recipient’s invoice (recipient-invoice cases, i.e. URD purchases self-invoiced u/s 31(3)(f)). Two provisos:
- Proviso 1: none determinable → date of entry in the recipient’s books.
- Proviso 2 — Associated Enterprises import (supplier outside India): ToS = earlier of the recipient’s books-entry date or the payment date — the payment-date criterion is effectively bypassed by the books entry if earlier. Do not apply the general 60-day rule here.
₹1,000 excess-payment proviso [12(2)/13(2)]: where payment exceeds the invoice amount by up to ₹1,000, the supplier may optionally treat the invoice date as the ToS for the excess. Practically relevant for services only — for goods, Notif 66/2017 already fixes ToS by invoice date regardless.
Combo-question tip from the source: first identify who pays (FCM supplier vs RCM recipient — e.g. recovery agent → NBFC, advocate → business entity = RCM), then apply the matching ToS rule.
Associated enterprises [Sec 2(12)]
Meaning borrowed from s.92A of the Income-tax Act. Relevant only to the 2nd proviso to 13(3) — import of services from an AE located outside India.
Document [Sec 2(41)]
Written, printed or electronic record (per the IT Act, 2000). Trap: it triggers the 30/60-day RCM count even if not titled “invoice”.
Vouchers, residual and addition in value — common rules
These three rules are identical for goods and services.
Voucher [Sec 2(118)]
An instrument carrying an obligation to accept it as consideration, where the supply or suppliers are identified on it or in related documents. It is not “money”; the key test is whether the supply is identifiable at issue.
- Vouchers [12(4)/13(4)]: supply identifiable at issue (e.g. a pizza voucher) → ToS = date of issue; supply determined only on redemption (e.g. a general food coupon) → ToS = date of redemption. Note: both 12(4) and 13(4) are proposed for omission vide Finance Act 2025 — NOT effective as on 30.04.2025; they remain examinable until ICAI notifies otherwise.
- Residual [12(5)/13(5)]: due date of the periodical return, else the date the tax is paid. Invoked only when (2)/(3)/(4) ALL fail — a true evidentiary gap. Do not jump here prematurely: the s.31 “last date the invoice ought to be issued” can often fix the ToS first.
- Addition in value [12(6)/13(6)]: interest, late fee or penalty for delayed payment of consideration → ToS is always the date the supplier actually receives it, irrespective of the underlying supply’s own ToS.
Two cross-cutting principles:
- “Date of receipt of payment” = the earlier of the books entry and the bank credit — identical definition for goods [Expl. 2 to 12(2)] and services [Expl. to 13(2)]. Never take the later date.
- “To the extent” principle: a supply is deemed made only to the extent covered by the invoice/payment — apportion the ToS separately for each part on part-invoice/part-payment.
Penalties: this chapter has no penalty section of its own — a late or incorrect ToS determination feeds the general interest/penalty consequences under the return-filing and payment-default provisions covered elsewhere.
Invoice timing — Section 31 with Rules 47 and 47A
Section 31 fixes when the invoice must be issued — which in turn feeds the “last date to issue” limb of s.12(2) and the in-time test of s.13(2).
| Provision | Situation | Invoice to be issued |
|---|---|---|
| 31(1) | Goods — general | Before/at removal (supply involves movement) or delivery (other cases) |
| 31(2) + Rule 47 | Services — general | Within 30 days of supply of service (45 days: insurer/banking co./FI/NBFC — Rule 47, 1st proviso) |
| Rule 47, 2nd proviso | Insurer/bank/FI/NBFC/telecom/notified suppliers — supplies between distinct persons (s.25) | Before/at the time of recording in books OR before expiry of the quarter |
| 31(3)(f) + Rule 47A | RCM — recipient self-invoices a URD purchase | Within 30 days from receipt of the goods/services (Rule 47A applies notwithstanding Rule 47) |
| 31(4) | Continuous supply of goods | Before/at each statement or each payment |
| 31(5) | Continuous supply of services | On/before the due date (ascertainable) / at receipt of payment (not ascertainable) / on/before event completion (event-linked) |
| 31(6) | Supply ceases before completion | At the time supply ceases, to the extent made |
| 31(7) | Goods sent on approval (sale-or-return) | Earlier of: before the supply, or 6 months from removal |
Continuous supply of goods vs services [Sec 2(32), 2(33)]
Goods: recurring/contract basis with periodic invoices — no fixed duration threshold. Services: recurring under a contract for more than 3 months with periodic payments — the 3-month test is unique to services.
Key timelines
| Count | What it is | Where |
|---|---|---|
| 30 days | Supplier’s invoice window for services (FCM) | 31(2) + Rule 47 |
| 45 days | Invoice window for insurer/banking co./FI/NBFC | Rule 47, 1st proviso |
| 30 days | Recipient’s self-invoice for a URD-RCM purchase, from receipt | 31(3)(f) + Rule 47A |
| 31st day from supplier’s invoice | Goods RCM backstop (day immediately after 30 days) | 12(3) |
| 61st day from supplier’s invoice | Services RCM backstop (day immediately after 60 days) | 13(3) |
| 6 months from removal | Goods sent on approval — outer invoice deadline | 31(7) |
| Expiry of the quarter | Distinct-person supplies by banks/insurers/telecom — invoice outer limit | Rule 47, 2nd proviso |
| ₹1,000 | Excess payment — optional invoice-date ToS for the excess | Proviso to 12(2)/13(2) |
| More than 3 months | Continuous-supply-of-services threshold | 2(33) |
- Taxing an advance for goods under FCM — Notif 66/2017 CT ignores it; ToS = invoice date / last date to issue only. For services, the advance DOES trigger ToS if earlier.
- Mixing the RCM backstops — goods: 31st day from the supplier’s invoice [12(3)(c)]; services: 61st day [13(3)(b)]. Different counts, easily confused.
- Treating the three 30/45/60-day rules as one — Rule 47 (FCM services invoice window, 30/45 days), Rule 47A (RCM recipient invoice, 30 days from receipt), and the 60-day RCM ToS countdown in s.13(3) operate at different stages.
- Transposing the voucher rules — identifiable supply → date of issue; non-identifiable → date of redemption.
- Taking the later of books entry and bank credit as the “date of receipt of payment” — it is always the earlier, for both goods and services.
- Jumping to the residual rule [12(5)/13(5)] prematurely — it applies only in a true evidentiary gap; the s.31 “last date the invoice ought to be issued” can often fix ToS first.
- Applying supplier-side tests to RCM — FCM watches the supplier’s acts, RCM the recipient’s acts (plus the supplier-invoice backstop).
- Answering rate-change questions from this chapter — s.14 is Final level; it is only referenced, not tested at Inter from Chapter 6.
Quick revision cards
Goods FCM — ToS?
Services FCM — ToS?
Goods RCM — ToS?
Services RCM — ToS?
RCM — nothing determinable?
AE import of service from abroad?
Voucher ToS?
Residual ToS [12(5)/13(5)]?
Interest/late fee/penalty on delayed payment?
Date of receipt of payment?
Rule 47 vs Rule 47A?
Part-invoice / part-payment?