Indirect Tax Laws and Practice · Place of Supply

Place of Supply of Goods under Section 10 IGST Act

Updated 11 October 2026 · Fact-checked

Section 10 of the IGST Act fixes the place of supply for goods moving within India. If goods move, the place of supply is where the movement ends for delivery to the recipient. Other clauses cover third-person direction, no movement, unregistered recipients, installation and goods supplied on board a conveyance.

Understand Place of Supply of Goods Other Than Imports and Exports

Place of supply decides which State or Union territory gets the tax. If the place of supply is in the same State as the supplier's location, the supply is intra-State (CGST + SGST/UTGST). If it is in a different State, the supply is inter-State (IGST). So you must find the place of supply before you can name the tax.

Section 10 applies to supplies of goods other than goods imported into, or exported from India. Imports and exports are handled by a separate section.

The main rule is in section 10(1)(a). Where the supply involves movement of goods, the place of supply is the location of the goods at the time the movement terminates for delivery to the recipient. It does not matter who moves the goods: the supplier, the recipient or any other person. Think of it as: where do the goods end up?

The other clauses are exceptions or special cases. Clause (b) deals with delivery on the direction of a third person (bill to ship to). Clause (c) deals with supplies with no movement. Clause (ca) deals with supplies to unregistered persons and overrides (a) and (c). Clause (d) deals with goods assembled or installed at site. Clause (e) deals with goods supplied on board a conveyance. If none can fix the place, section 10(2) says it is determined as prescribed.

Key rules to remember

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.

How to solve Place of Supply of Goods Other Than Imports and Exports questions

Use the same order every time. It stops you from picking the wrong clause. Clause (ca) says it applies "notwithstanding anything contrary contained in clause (a) or clause (c)". It does not name clauses (b), (d) or (e). So check those first, and treat (b), (d) and (e) as taking priority on the text.

1Check that the supply is of goods and that it is not an import into or export from India. If it is, section 10 does not apply.
2Check whether a third person directs delivery (bill to ship to). If yes, apply clause (b): the place is the third person's principal place of business. Clause (ca) overrides only clauses (a) and (c) by its own words and does not name clause (b). So on the text, clause (b) is applied first. This is the reading of the text, not a separate rule.
3Check for special facts: assembly or installation at site, or goods supplied on board a conveyance. If present, apply clause (d) or (e). Clause (ca) does not name these clauses.
4If none of clauses (b), (d) and (e) applies, check whether the recipient is a registered person. If the recipient is unregistered, clause (ca) applies in place of (a) or (c): use the address recorded in the invoice, or the supplier's location if none is recorded.
5If the recipient is registered, ask whether the goods move. If yes, clause (a) applies and the place is where the movement terminates. If no, clause (c) applies and it is where the goods are located at delivery.
6Compare the place of supply with the supplier's location. Same State means CGST + SGST/UTGST. Different State means IGST.
7Write the conclusion with the clause number and the reason in one line.

Quickest way: Four-question filter

When to use it: Use it for MCQs and for short case parts where you have about two minutes. Ask the questions in this order. Clause (ca) is expressly "notwithstanding" clauses (a) and (c) only, so the special clauses are checked before it.

Is there a third person who directs delivery? Then it is that person's principal place of business. Clause (ca) does not name clause (b), so the text is read this way.
Is it installed, assembled or sold on board? Then it is the site or the point of boarding.
If neither applies, is the buyer unregistered? Then it is the address on the invoice (or the supplier's location if none is recorded).
Otherwise, the buyer is registered. It is where the goods end up (movement) or where they are at delivery (no movement).

Common mistakes in Place of Supply of Goods Other Than Imports and Exports

Taking the place of supply as the supplier's location or the place where goods are dispatched from.
Students confuse the location of the supplier with the place of supply, or think the starting point of movement matters.
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).
Clause (ca) was inserted later and students remember only the older clauses.
Fix: Check the recipient's registration status first. Clause (ca) applies notwithstanding clauses (a) and (c).
Treating the buyer as the recipient in a bill to ship to case.
Students look at who is invoiced or who receives the goods physically.
Fix: Where delivery is on a third person's direction, that third person is deemed to have received the goods. Use the third person's principal place of business. Clause (ca) names only clauses (a) and (c), so read clause (b) first.
Applying section 10 to imports and exports.
The section heading is read loosely.
Fix: Section 10 is for goods other than those imported into, or exported from India. Read the facts for any foreign element first.
Stating the tax wrongly after finding the place of supply.
Students stop at the place and forget to compare it with the supplier's location.
Fix: Always finish by comparing the place of supply with the supplier's location. Same State: CGST + SGST/UTGST. Different State: IGST.

Worked examples

Example 1

Sharma Traders, Jaipur (Rajasthan) and registered in Rajasthan, sells machine parts worth ₹2,00,000 to Kaveri Engineering, Coimbatore (Tamil Nadu), registered in Tamil Nadu. The goods are sent by a transporter arranged by Kaveri and delivered at Kaveri's factory in Coimbatore. Determine the place of supply and the tax applicable.

Show the solution

The recipient is registered, so clause (ca) does not apply. There is no third person directing delivery and no installation.
The goods move from Jaipur to Coimbatore. It does not matter that the recipient arranged the transporter, because clause (a) applies whoever moves the goods.
Under section 10(1)(a), the place of supply is the location of the goods when the movement terminates for delivery to the recipient: Coimbatore, Tamil Nadu.
The supplier's location is Rajasthan and the place of supply is Tamil Nadu. The States are different, so the supply is inter-State.

Answer: The place of supply is Tamil Nadu (Coimbatore). The supply is inter-State, so IGST is charged.

Example 2

Mehta Textiles, Surat (Gujarat), registered in Gujarat, receives an order from Anand Garments, Mumbai (Maharashtra), a registered person. On Anand's direction, Mehta delivers the goods directly to Rao Retail, Hyderabad (Telangana), whose principal place of business is in Hyderabad. Mehta invoices Anand. Find the place of supply of Mehta's supply to Anand.

Show the solution

Anand is registered, so clause (ca) is not in play. Clause (ca) also names only clauses (a) and (c), not clause (b).
Mehta (the supplier) delivers the goods to Rao Retail, the person to whom the goods are physically delivered, on the direction of Anand Garments. Anand is the invoiced buyer and also the person who directs the delivery. In the words of clause (b), Anand is the third person who directs delivery. Rao Retail is the person to whom the goods are delivered. So clause (b) applies.
Under clause (b), the third person who directs delivery (Anand) is deemed to have received the goods. The place of supply is therefore Anand Garments' principal place of business: Mumbai, Maharashtra.
The supplier's location is Gujarat and the place of supply is Maharashtra. The States are different, so the supply is inter-State.

Answer: The place of supply of Mehta's supply to Anand is Maharashtra (Mumbai), and the supply attracts IGST. The physical delivery in Hyderabad does not decide the place of supply of this supply.

Exam tips

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.
Do not mix up the roles in bill to ship to. Name each party and say who directs delivery.
Do not apply section 10 to imports and exports. State that in one line if the facts mention a foreign element.

Practice questions from Place of Supply

Place of Supply of Goods Other Than Imports and Exports 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 of Goods Other Than Imports and Exports: frequently asked questions

What is the place of supply of goods when goods are moved?

Under section 10(1)(a) of the IGST Act, it is the location of the goods when the movement terminates for delivery to the recipient. It makes no difference whether the supplier, the recipient or another person moves the goods.

What is the place of supply if the buyer is not registered?

Under section 10(1)(ca), it is the address of the buyer recorded in the invoice. If no address is recorded, it is the supplier's location. Recording the name of the buyer's State is treated as recording the address.

What happens in a bill to ship to transaction under section 10?

The third person who directs delivery is deemed to have received the goods. The place of supply is that person's principal place of business, as per section 10(1)(b).

Does section 10 apply to imports and exports of goods?

No. Section 10 applies to goods other than goods imported into, or exported from India. Those supplies are covered by a separate provision of the IGST Act.