CORAA University · GST tool

Place of Supply Determiner

Answer a few structured questions — goods or services, who's where, what kind of supply — and get the place of supply with the exact IGST Act section and whether the invoice carries IGST or CGST + SGST. Covers the bill-to-ship-to deeming, the Section 10(1)(ca) B2C rule and the Section 13(8)(b) intermediary trap.

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What are you supplying, and how?

Step 1 · Nature of supply

Step 2 · Which scenario matches the transaction?

Supplier's state

State where the movement of goods terminates for delivery

Why this matters

A place-of-supply error is not a rounding difference. wrong tax head, real cash cost

Charging CGST + SGST where IGST was due (or the reverse) means paying the correct tax again and claiming a refund of the wrong one under Section 77 CGST / Section 19 IGST — with the ITC chain broken in between. Getting the place of supply right the first time is cheaper than any rectification.

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How the place of supply is determined under GST

GST is a destination-based tax, and the "place of supply" is the legal fiction that fixes the destination. Sections 10 and 11 of the IGST Act 2017 set the rules for goods (domestic and import/export respectively); Sections 12 and 13 set the rules for services — Section 12 when both supplier and recipient are in India, Section 13 when either of them is outside India. Once the place of supply is known, Sections 7 and 8 decide the tax head: supplier's state and place of supply in different states → inter-state supply → IGST; same state → intra-state supply → CGST + SGST (CGST + UTGST in union territories without a legislature).

For goods, the default is movement-based: where the movement terminates for delivery (Sec 10(1)(a)). Overrides exist for bill-to-ship-to deliveries (Sec 10(1)(b) — the place of supply is the BILL-TO party's principal place of business, not where the goods land), goods supplied without movement (10(1)(c)), goods installed or assembled at site (10(1)(d)), goods sold on board a conveyance (10(1)(e)), and — since 1 October 2023 — supplies to unregistered persons, where clause (ca) fixes the place of supply at the address recorded on the invoice (delivery address if billing and delivery differ, per Circular 209/3/2024-GST).

For services, each section opens with a default (Sec 12(2): registered recipient's location, else address on record, else supplier's location; Sec 13(2): recipient's location) and then lists specific overrides — immovable property, performance-based services, events, transport, services on board conveyances, banking, and, under Section 13(8), three categories where the place of supply is the SUPPLIER'S location: banking to account holders, intermediary services, and short-term hiring of means of transport. The Finance Act 2023 (effective 1 October 2023) omitted Section 13(9), so cross-border transportation of goods now follows the Section 13(2) default — the recipient's location.

Worked example — bill-to-ship-to under Section 10(1)(b)

A manufacturer in Maharashtra receives an order from a dealer registered in Karnataka, with instructions to deliver the goods directly to the dealer's customer site in Tamil Nadu.

Inputs

Supplier (manufacturer)Maharashtra

Bill-to party (dealer, third person)Karnataka

Ship-to (delivery) locationTamil Nadu

Output

Leg 1 place of supply (manufacturer → dealer)Karnataka — Sec 10(1)(b)

Leg 1 taxIGST (Maharashtra → Karnataka)

Leg 2 place of supply (dealer → customer)Tamil Nadu — Sec 10(1)(a)

Leg 2 taxIGST (Karnataka dealer, Tamil Nadu PoS)

Section 10(1)(b) deems the third person who ordered the delivery (the Karnataka dealer) to have received the goods, so the first leg's place of supply is Karnataka even though the goods never enter Karnataka. The dealer takes ITC of the IGST on leg 1 and charges IGST on leg 2 to the Tamil Nadu customer. Two invoices, one physical movement, one e-way bill showing both parties.

Common mistakes

Billing the ship-to state instead of the bill-to state

In a bill-to-ship-to supply, the first leg's place of supply is the bill-to party's state — Section 10(1)(b)'s deeming fiction. Suppliers who charge tax based on where the truck went break the bill-to party's ITC chain: the credit belongs to the bill-to party, and the ship-to recipient gets its credit only on the second invoice from the bill-to party.

Treating an intermediary's foreign commission as an export

Under Section 13(8)(b), the place of supply of intermediary services is the SUPPLIER'S location — in India. Commission from a foreign principal, received in convertible forex, is still not an export of services because Section 2(6) requires the place of supply to be outside India. It is taxed as an intra-state supply (CGST + SGST) in the intermediary's state. Whether you are an "intermediary" at all turns on Circular 159/15/2021-GST: facilitating a supply between two other persons, not supplying on your own account.

Missing the 1 October 2023 transport-of-goods changes

Two rules changed on the same day: the proviso to Section 12(8) (destination-based PoS for goods transported outside India) was omitted, and Section 13(9) (destination of goods for cross-border freight) was omitted entirely. Freight is now recipient-location based in both sections. Working papers and invoice logic written before October 2023 give the wrong answer.

Ignoring Section 10(1)(ca) for B2C and e-commerce sales

Since 1 October 2023, a sale to an unregistered person takes its place of supply from the address recorded on the invoice — and where billing and delivery addresses differ, the DELIVERY address controls (Circular 209/3/2024-GST). Charging tax by the billing address on e-commerce orders shipped to another state is a systematic error, repeated on every order.

Using Section 12 rules for a cross-border service (or vice versa)

Section 12 applies only when BOTH supplier and recipient are in India; the moment either party is outside India, Section 13 applies — and its overrides differ (no B2B/B2C split, different event and transport rules, the 13(8) supplier-location list). Applying the wrong section is the most common structural error in PoS memos.

Frequently asked questions

What is place of supply under GST?+

The place of supply is the location the law treats as the destination of a supply. Together with the supplier's location it decides whether a transaction is inter-state (IGST) or intra-state (CGST + SGST). Sections 10–11 of the IGST Act 2017 fix it for goods; Sections 12–13 fix it for services.

What is the place of supply in a bill-to-ship-to transaction?+

Where goods are delivered to one person (ship-to) on the instruction of a third person (bill-to), Section 10(1)(b) deems the bill-to party to have received the goods — so the place of supply of the first leg is the bill-to party's principal place of business. The physical delivery state is irrelevant for the first invoice; it matters only for the second leg (bill-to party to ultimate recipient) under Section 10(1)(a).

How is the place of supply decided for services when both parties are in India?+

Section 12(2) sets the default: for a registered recipient, the recipient's location; for an unregistered recipient, the address on record with the supplier, and if there is none, the supplier's location. Sub-sections 12(3) to 12(14) override the default for specific services — immovable property (property location), restaurant and grooming (where performed), training (recipient if registered, else where performed), event admission (where held), goods transport (recipient if registered, else where handed over), passenger transport (recipient if registered, else embarkation point), and banking (recipient's location in the supplier's records).

Why is an intermediary's service to a foreign client not an export?+

Section 13(8)(b) fixes the place of supply of intermediary services at the supplier's (the intermediary's) location — in India. Export of services under Section 2(6) requires the place of supply to be outside India, so the definition fails even though the client is abroad and pays in forex. The supply is treated as intra-state in the intermediary's state, attracting CGST + SGST. Courts have upheld the provision. Whether you are actually an "intermediary" depends on Circular 159/15/2021-GST — facilitating a supply between two other persons, not providing the main service on your own account.

What changed in the place of supply for transportation of goods from 1 October 2023?+

The Finance Act 2023 omitted Section 13(9) of the IGST Act (which fixed the place of supply of cross-border goods transportation at the destination of the goods) and the proviso to Section 12(8). From 1 October 2023, cross-border freight follows the Section 13(2) default — the recipient's location — and domestic freight billed to a registered person is the recipient's location under Section 12(8)(a). An Indian forwarder billing a foreign customer can now treat the freight as a potential zero-rated export.

What is the place of supply for goods sold to an unregistered person?+

Since 1 October 2023, Section 10(1)(ca) of the IGST Act fixes it at the location per the address of the unregistered recipient recorded on the invoice; where no address is recorded, the supplier's location. Recording only the recipient's State name counts as recording the address. Where billing and delivery addresses differ, Circular 209/3/2024-GST clarifies that the delivery address on the invoice is the place of supply.

What happens if I charge CGST + SGST instead of IGST by mistake?+

The supply does not become invalid, but the tax was paid under the wrong head. Section 77 of the CGST Act / Section 19 of the IGST Act require you to pay the correct tax and claim a refund of the tax wrongly paid — no interest is charged on the correct tax if the wrong tax was originally paid (Rule 89(1A) sets the refund procedure and a two-year window from payment of the correct tax). The recipient's ITC also needs fixing, so the correction touches both sides.

What is the place of supply for OIDAR services?+

The recipient's location — Section 13(12) of the IGST Act. For B2C supplies by a foreign provider to unregistered persons in India, the foreign supplier itself must register under the simplified OIDAR scheme (Section 14, IGST Act) and pay IGST; reverse charge applies only when the Indian recipient is registered. From 1 October 2023 the "non-taxable online recipient" definition covers every unregistered recipient in India, business purpose or not.

Authoritative sources

Parliament

IGST Act 2017 — Chapter V (Sections 10–14), CBIC repository — Current text of Sections 10–14 as amended, including Sec 10(1)(ca) and the omission of Sec 13(9) effective 1 October 2023.

Circular No. 209/3/2024-GST — place of supply under Sec 10(1)(ca) — CBIC clarification: for unregistered buyers with different billing and delivery addresses, the delivery address on the invoice is the place of supply.

Circular No. 159/15/2021-GST — scope of "intermediary" — An intermediary arranges or facilitates a supply between two or more other persons; supplying the main service on one's own account, or sub-contracting, is not intermediary service.

Always confirm against the latest version of the source. Regulations evolve and amendments are common.

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Last reviewed: 2026-07-29 · For informational purposes only — not professional advice.