CMA Final · Indirect Tax Laws and Practice

Place of Supply: formula sheet

Full chapter guide

Key formulas

Inter-State test for goods (Section 7(1)): Location of supplier ≠ place of supply (different State/UT) → inter-State → IGST; Section 7(1) is subject to Section 10. Place of supply, not the movement of goods alone, decides the result.
Inter-State test for services (Section 7(3)): Location of supplier ≠ place of supply (different State/UT) → inter-State → IGST; Section 7(3) is subject to Section 12. Same State or UT on both sides means intra-State.
Goods with movement (Section 10(1)(a)): Place of supply = location of goods when movement ends for delivery to the recipient; Applies whether the supplier, recipient or any other person moves the goods.
Goods to unregistered person (Section 10(1)(ca)): Place of supply = address in invoice; if none, location of supplier; Overrides clauses (a) and (c). Naming the State in the invoice counts as recording the address.
Services default rule (Section 12(2)): Registered recipient → recipient's location. Unregistered → recipient's location if address on record, else supplier's location; Applies only where no special rule in Section 12(3) to (14) fits.
Immovable property services (Section 12(3)): Place of supply = location of the immovable property, boat or vessel; If it is outside India, the place of supply is the location of the recipient. Covers lodging and event venues.
Banking and financial services (Section 12(12)): Place of supply = location of recipient on supplier's records; else supplier's location; Applies to any person, registered or not.
Imports (Section 7(2) and 7(4)): Imported goods till they cross the customs frontier, and imported services = inter-State supply; Always attract IGST.
Movement of goods: s.10(1)(a): Place of supply = location of goods when movement terminates for delivery to the recipient; Applies whether the supplier, recipient or any other person moves the goods.
Delivery on third person's direction: s.10(1)(b): Place of supply = principal place of business of the third person; The third person is deemed to have received the goods, whether by transfer of documents of title or otherwise, before or during movement.
No movement of goods: s.10(1)(c): Place of supply = location of goods at the time of delivery to the recipient; Applies where neither supplier nor recipient moves the goods.
Unregistered recipient: s.10(1)(ca): Place of supply = address of the recipient recorded in the invoice; if no address is recorded, location of the supplier; Applies notwithstanding clauses (a) and (c). Recording only the name of the State is deemed to be recording the address.
Assembly or installation at site: s.10(1)(d): Place of supply = place of installation or assembly; The goods are assembled or installed at the site.
Goods on board a conveyance: s.10(1)(e): Place of supply = location where the goods are taken on board; Conveyance includes a vessel, aircraft, train or motor vehicle.
Place cannot be determined: s.10(2): Place of supply = as prescribed; Fallback only when no clause fixes the place.
Rule of section 10(1)(b): Place of supply = principal place of business of the third person who directs the delivery; Applies when goods are delivered to a recipient or any other person on the direction of a third person, before or during movement of goods.
Deemed receipt: Third person is deemed to have received the goods; Applies whether the third person acts as an agent or otherwise, and whether by transfer of documents of title or otherwise.
Default movement rule (section 10(1)(a)): Place of supply = location of goods when movement terminates for delivery to the recipient; Used when no third person directs the delivery. Do not use it for a bill to ship to case.
Tax type test: Supplier's location and place of supply in same State → CGST + SGST/UTGST; in different States → IGST; Compare the supplier's location with the third person's principal place of business, not with the delivery point.
No-movement rule: Place of supply = location of goods at the time of delivery to the recipient; Section 10(1)(c) IGST Act. Applies when the supply does not involve movement of goods by the supplier, the recipient or any other person.
Movement rule (for contrast): Place of supply = location of goods when movement terminates for delivery to the recipient; Section 10(1)(a). Use this when goods are moved. Do not mix it with clause (c).
Unregistered recipient override: Place of supply = location per recipient's address on invoice; else supplier's location; Section 10(1)(ca), notwithstanding clauses (a) and (c). Naming only the recipient's State on the invoice is treated as recording the address.
Intra-State or inter-State test: Supplier's location and place of supply in same State/UT = intra-State; different = inter-State; Compare the two locations after you fix the place of supply.
Installation or assembly rule: Place of supply = place of installation or assembly of the goods at site; Section 10(1)(d), IGST Act, 2017. Applies to supplies of goods other than imports and exports.
Intra-State or inter-State test: Location of supplier and place of supply in same State/UT → intra-State (CGST + SGST/UTGST); in different States/UTs → inter-State (IGST); Compare the supplier's location with the site of installation.
Exclusion for imports and exports: Imports: location of importer. Exports: location outside India.; Section 11 covers these. Section 10 does not apply to them.
Goods on board a conveyance: Place of supply = location at which the goods are taken on board; Section 10(1)(e), IGST Act. Applies to a vessel, aircraft, train, motor vehicle and similar conveyances.
Services on board (contrast): Place of supply = location of the first scheduled point of departure of the conveyance; Section 12(10). Applies to services, not goods, where supplier and recipient are in India. Do not use it for goods.
Nature of supply: Place of supply in same State as supplier's location → intra-State; otherwise → inter-State; Use the place of supply, not the place of consumption, to choose CGST + SGST/UTGST or IGST.
Scope of section 10: Section 10 applies to goods other than goods imported into, or exported from, India; Imports and exports are dealt with by a different section of the IGST Act.
Movement of goods: Place of supply = location of goods when movement terminates for delivery to the recipient; Section 10(1)(a). Applies whoever arranges the movement.
Bill to Ship to: Place of supply = principal place of business of the third person who directed delivery; Section 10(1)(b). The third person is deemed to have received the goods.
No movement: Place of supply = location of goods at the time of delivery to the recipient; Section 10(1)(c).
Unregistered recipient: Place of supply = address in invoice; if none recorded, location of supplier; Section 10(1)(ca), overrides clauses (a) and (c). Naming the State counts as recording the address.
Installation or assembly: Place of supply = place of installation or assembly; Section 10(1)(d).
On board a conveyance: Place of supply = location where goods are taken on board; Section 10(1)(e): vessel, aircraft, train or motor vehicle.
Residual rule: If place cannot be determined, determine it as prescribed; Section 10(2). Use only after checking all of Section 10(1).
Inter-State test: Location of supplier ≠ place of supply (different State/UT) → inter-State → IGST; Section 7(1), subject to Section 10.
Intra-State test: Location of supplier = place of supply (same State/UT) → intra-State → CGST + SGST/UTGST; Section 8(1), subject to Section 10. SEZ supplies are not intra-State.

Quick revision

Section 10 applies to goods other than imports into or exports from India.
If goods move, place of supply is where movement terminates for delivery to the recipient.
Movement can be by the supplier, the recipient or any other person; the rule is the same.
Bill to ship to: the third person is deemed to have received the goods; place is that person's principal place of business.
If goods do not move, place of supply is the location of the goods at the time of delivery to the recipient.
Goods assembled or installed at site: place of supply is the place of installation or assembly.
Goods supplied on board a conveyance: place is where goods are taken on board.
Clause (ca): for supply to an unregistered person, place is the address recorded in the invoice, notwithstanding clauses (a) and (c).
If no address is recorded in the invoice, clause (ca) gives the supplier's location; the State name alone counts as the address.
If place cannot be determined, Section 10(2) says it is decided in the manner prescribed.
Inter-State or intra-State depends on supplier location versus place of supply.

Common mistakes

Treating the supplier's location and the place of supply as the same thing Fix: Always write both locations down. The Act can fix the place of supply somewhere other than where the supplier is or where work is done.
Deciding inter-State supply only by where goods physically travel Fix: Section 7(1) is subject to Section 10. Compare the supplier's location with the place of supply fixed by the Act, not with the route of the truck.
Taking the place of supply as the supplier's location or the place where goods are dispatched from. Fix: For movement cases, always use where the movement terminates for delivery to the recipient. Dispatch point only matters for the supplier's location.
Ignoring clause (ca) for unregistered recipients and applying clause (a). Fix: Check the recipient's registration status first. Clause (ca) applies notwithstanding clauses (a) and (c).
Taking the delivery address as the place of supply. Fix: When a third person directs delivery, use section 10(1)(b) and take the third person's principal place of business.
Using the registered address or any branch of the third person instead of the principal place of business. Fix: Use the principal place of business of the directing person. If the question names it, use that State.
Taking the supplier's registered State as the place of supply. Fix: For goods under clause (c), always use the location of the goods at delivery, not the supplier's address.
Applying clause (c) when goods are actually moved. Fix: Read the facts. If anyone transports the goods to the buyer, clause (a) applies and the place is where movement ends.
Using the place where the goods are dispatched from as the place of supply. Fix: Look for installation or assembly first. If present, the site is the place of supply under Section 10(1)(d).
Using the place where the movement ends under Section 10(1)(a) even when the goods are installed there. Fix: Name clause (d) because it is the specific rule for installation or assembly. Quote it in the answer.

Exam tips

Write the section and clause number next to the place of supply. Examiners give marks for naming the correct rule.
Always state both locations before concluding inter-State or intra-State. A one-line comparison earns the marks.
In case scenarios, check whether the buyer is registered. It changes the rule in several clauses, including Section 10(1)(ca) and Section 12(2).
Keep Section 7, Section 10 and Section 12 linked in your mind: Section 7 gives the test, Sections 10 and 12 supply the place of supply.
For MCQs, look for keywords such as hotel, training, bank or insurance. They point to the special rule in Section 12.
In MCQs, scan the facts for registration status of the buyer, a third person and installation before choosing a clause.
In case scenarios, write the clause number (for example section 10(1)(a)) and a one-line reason. Marks go to the reasoning, not only the State.
Always end with the tax consequence: IGST if the place of supply is outside the supplier's State, otherwise CGST + SGST/UTGST.