CA Intermediate · Taxation

Place of Supply for CA Intermediate GST (Paper 3, Section B)

Place of supply fixes where a supply is taxed, and so whether it is intra-State (CGST + SGST/UTGST) or inter-State (IGST). For goods use Section 10, or Section 11 for imports and exports. For services use Section 12 (both parties in India) or Section 13 (a party outside India). Apply the rules in order.

What this chapter covers

Place of Supply (POS) is the rule set in the IGST Act, 2017 that fixes where a supply is deemed to take place. It works together with the location of the supplier. If the location of the supplier and the place of supply are in the same State, the supply is intra-State. If they are in different States or Union territories, it is inter-State. This one decision decides whether the tax is CGST plus SGST/UTGST, or IGST.

This simple comparison has important exceptions. Under Section 7 of the IGST Act, a supply of goods in the course of import into India is inter-State (Section 7(2)), and so is a supply of services imported into India (Section 7(4)). Under Section 7(5)(a), a supply where the supplier is located in India and the place of supply is outside India (an export) is inter-State. Under Section 7(5)(b), a supply to or by an SEZ developer or SEZ unit is also inter-State. These supplies attract IGST whatever the States involved, so do not stop at comparing the supplier's State with the place of supply.

The chapter has four main parts. Section 10 covers goods other than imports and exports. Section 11 covers goods imported into or exported from India. Section 12 covers services where both the supplier and the recipient are located in India. Section 13 covers services where the location of the supplier or the location of the recipient is outside India, that is, cross-border services. Each section starts with a general rule and then lists special cases that override it. Your job is to learn the order: check the special cases first, and fall back on the general rule only if none fits.

The place of supply determines the tax type: CGST plus SGST/UTGST, or IGST. The tax type in turn decides which ledger is used for ITC set-off and which table of the return the supply is reported in. If you get the tax type wrong here, the computation after it goes wrong. The chapter also links to the definitions of intra-State and inter-State supply, and to export and import of services. Keep those definitions fresh while you study.

Place of supply questions are short, rule-based and very scoreable once you know the order of the rules. They appear as MCQs where one fact decides the answer, and as descriptive questions where you must name the provision, apply the facts and state the tax type. Many computation questions in GST also begin with a place of supply decision, so an error here costs marks in later steps too. The effort needed is mainly memory and practice, which makes this a good chapter to master early.

Place of Supply: topics in the order to study them

1Place of Supply: Basics and Sections 10, 11, 12 and 13This is the only topic in the chapter. Start with the basics (location of supplier, location of recipient, intra-State vs inter-State, including import, export and SEZ supplies under Section 7), then learn Section 10 for goods, then Section 11 for imported and exported goods, then Section 12 for services within India, then Section 13 for cross-border services, and finish by comparing them side by side.

How to prepare Place of Supply

Treat this chapter as a decision tree, not a list to memorise. Practise by asking the same questions in the same order every time.

Learn the core terms first: location of supplier, location of recipient, place of supply, and the tests for intra-State and inter-State supply, including the rule that imports, exports and supplies to or by an SEZ developer or SEZ unit are inter-State under Section 7.
Read Section 10 for goods other than imports and exports. Note the main clauses 10(1)(a) to (c): movement of goods, delivery to the recipient or to another person on the direction of a third person, and no movement. Then learn 10(1)(d), goods assembled or installed at site, and 10(1)(e), goods supplied on board a conveyance.
Read Section 11 for goods imported into or exported from India. Do not apply Section 10 to these supplies.
Read Section 12 for services. Note that Section 12(2) is the general rule for all services not covered by the special rules in sub-sections (3) to (14). For a registered recipient, the place of supply is the location of the recipient. For an unregistered recipient, it is the location of the recipient where the address is on record, otherwise the location of the supplier. Then learn the special cases such as immovable property, restaurant services, training, admission to events, and transportation.
Read Section 13 for services where the supplier or the recipient is outside India. Note its general rule and its special cases, and check the facts to see which party is outside India before choosing between Section 12 and Section 13.
Build a one-page comparison chart with the columns: type of supply, section, rule, place of supply. Rewrite it from memory twice.
Solve small fact patterns. For each, write the steps: supply of goods or services, relevant section, place of supply, location of supplier, intra-State or inter-State, tax charged.
Do MCQs in timed sets. Underline the one fact that decides the answer, such as whether goods move, whether the recipient is registered, or where the property is.
For descriptive answers, use this format: provision, facts, conclusion. Name the section, apply the facts in one or two lines, and end by stating the tax type.

Common mistakes in Place of Supply

Using the supplier's State as the place of supply by default
Fix: Identify the place of supply with the section's rules first. Then compare it with the supplier's location to decide the tax type.
Applying Section 10 to services or Section 12 to goods
Fix: Begin every answer with labelling the supply as goods or services. Then choose the section.
Using the general rule when a special rule applies
Fix: Scan the facts for triggers such as immovable property, installation, a restaurant, an event, or a conveyance before falling back on the general rule.
Ignoring whether the recipient is registered in services questions
Fix: Underline the recipient's registration status in the question. It changes the general rule under Section 12(2).
Using Section 12 when one party is outside India
Fix: Check the locations of both parties first. If either is outside India, use Section 13, not Section 12.
Stopping at the place of supply and not stating the tax
Fix: Finish each answer with one line: intra-State, so CGST and SGST/UTGST, or inter-State, so IGST.

Last-day revision: Place of Supply

Place of supply decides whether a supply is intra-State (CGST + SGST/UTGST) or inter-State (IGST).
Compare the location of supplier with the place of supply. Same State means intra-State. Different States means inter-State.
Under Section 7 of the IGST Act, a supply of goods in the course of import into India is inter-State (Section 7(2)), and so is a supply of imported services (Section 7(4)). A supply where the supplier is in India and the place of supply is outside India (export) is inter-State under Section 7(5)(a). A supply to or by an SEZ developer or SEZ unit is also inter-State under Section 7(5)(b).
Section 10 of the IGST Act covers the place of supply of goods other than imports and exports.
Section 11 of the IGST Act covers the place of supply of goods imported into or exported from India.
Section 12 applies to services where both supplier and recipient are located in India.
Section 13 applies to services where the location of the supplier or the location of the recipient is outside India.
Always check the special rules before using the general rule.
For goods that move, the place of supply is where the movement ends (Section 10(1)(a)).
Where goods are delivered by the supplier to a recipient or any other person on the direction of a third person (whether acting as agent or otherwise), before or during movement, it is deemed that the third person has received the goods. The place of supply is then the principal place of business of the third person (Section 10(1)(b)).
For goods with no movement, the place of supply is where the goods are at the time of delivery (Section 10(1)(c)).
For goods assembled or installed at site, the place of supply is the place of installation or assembly (Section 10(1)(d)).
For goods supplied on board a conveyance, the place of supply is the location where the goods are taken on board (Section 10(1)(e)).
Section 12(2) is the general rule for all services not covered by the special rules in sub-sections (3) to (14). Registered recipient: the location of the recipient. Unregistered recipient: the location of the recipient where the address is on record, otherwise the location of the supplier.
For services linked to immovable property, the place of supply is where the property is located.
Write the section number, the facts and the tax type in descriptive answers.

Place of Supply practice questions

Place of Supply in other exams

The same ground in other exams, if you are preparing for more than one or want another angle on it.

Place of Supply: frequently asked questions

Is Place of Supply an important chapter for CA Intermediate GST?

Yes, because it is rule-based and easy to score once you know the order of the rules. It also feeds into other GST computations, since the tax type depends on it. Practise it with both MCQs and short fact patterns.

What is the difference between Section 10, Section 11, Section 12 and Section 13 of the IGST Act?

Section 10 deals with place of supply of goods other than imports and exports. Section 11 deals with goods imported into or exported from India. Section 12 deals with place of supply of services where both the supplier and recipient are located in India. Section 13 deals with services where the supplier or the recipient is located outside India. Decide first whether the supply is goods or services, then check where the parties are, then pick the section.

How do I decide if a supply is intra-State or inter-State?

Find the location of the supplier and the place of supply. If both are in the same State or Union territory, the supply is intra-State. If they differ, it is inter-State. Under Section 7 of the IGST Act, a supply in the course of import into India, a supply where the supplier is in India and the place of supply is outside India (export), and a supply to or by an SEZ developer or SEZ unit are inter-State.

How should I write a place of supply answer for the descriptive part?

Use provision, facts, conclusion. Name the relevant section, apply the key facts in a line or two, and state the place of supply and the tax type. This format earns step marks even if one fact is misread.