GST place of supply examples

Use the right rule family

Distinguish goods from services and domestic transactions from cases involving a supplier or recipient outside India. The IGST Act uses different provisions for these situations. The customer’s billing address is an input, not a universal answer.

After determining place of supply, assess the supplier’s location and the provisions governing interstate or intrastate treatment, including special cases such as SEZ supplies. Keep registration, tax rate and credit eligibility as separate decisions.

Example: ordinary domestic movement of goods

Assume a Karnataka supplier sells goods to a registered Maharashtra customer, delivery ends in Maharashtra and no special bill-to/ship-to, installation or other rule applies. The ordinary movement rule points to the place where movement terminates for delivery. Retain the order, invoice and delivery evidence supporting that fact.

Do not extend this simplified example to every goods transaction. Supplies to unregistered persons, installation, imports, exports and third-party delivery instructions require review of the relevant provisions.

Example: third-party delivery instructions

A buyer instructs a supplier to deliver goods directly to another person. Identify both transactions and the person giving the instruction before applying the bill-to/ship-to provision. The physical delivery address alone may not determine the place of supply for the supplier’s transaction with the instructing buyer.

Keep the purchase order, delivery instruction, invoice chain and transport records together. Do not assume that one e-way bill or one delivery acknowledgement explains the tax treatment of every supply in the chain.

Example: ordinary domestic B2B services

Assume both supplier and recipient are in India and the service falls under the general rule in section 12(2), rather than a specified exception. For a supply to a registered person, that rule uses the recipient’s location. Confirm the relevant recipient registration and establishment from the actual arrangement.

A general consulting engagement may fit that starting point, but the label “consulting” should not hide a service directly related to property or another specially treated activity. Read the scope and deliverables.

Example: services related to immovable property

For services covered by section 12(3), the property-related rule can displace the general recipient-location rule. A domestic hotel stay or qualifying architectural service needs the property facts, not merely the address of the company paying the bill.

If the property spans jurisdictions or lies outside India, examine the applicable wording and allocation provisions. This example does not establish the supplier’s registration obligation or the customer’s entitlement to credit.

Example: a customer outside India

An overseas customer does not automatically produce export treatment. Identify the applicable cross-border service rule, any special provision and all export conditions. Establish the actual recipient and relevant establishments before relying on an overseas invoice address.

Keep payment evidence and the export-condition assessment separate from the place-of-supply conclusion. A place of supply outside India is one part of the analysis, not proof that every other condition has been satisfied.

Document the decision before-invoicing

• Description of the actual goods or services and the relevant period.
• Supplier, recipient and establishment locations with supporting records.
• Movement, delivery, property or performance facts relevant to the chosen rule.
• Applicable provision and reasons a special rule does or does not apply.
• Resulting tax-head treatment and any separate registration or credit questions.
• Review trigger when the contract, delivery route or recipient changes.

Resolve inconsistent records

If an invoice, contract and delivery record point to different locations, investigate before changing the tax head. Preserve the original documents and document the correction process where needed. A matching total tax amount does not cure use of an incorrect tax head.

Kosha.Services can help organise the transaction facts and invoice review. Bring contracts, orders, GSTIN details, delivery evidence and earlier treatment notes so the assessment follows the actual supply.