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Indirect Tax Laws and Practice · Place of Supply

Place of Supply Where No Movement of Goods Takes Place

Updated 11 October 2026 · Fact-checked

When a supply of goods does not involve movement by the supplier, the recipient or anyone else, section 10(1)(c) of the IGST Act makes the place of supply the location of the goods at the time of delivery to the recipient. You find where the goods are when delivered, then compare that State with the supplier's location.

Understand Supply Where No Movement of Goods Takes Place

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, it is an intra-State supply (CGST + SGST/UTGST). If it is in a different State, it is inter-State (IGST).

Most supplies of goods involve movement, such as a truck taking goods from Pune to Chennai. For those, section 10(1)(a) applies and the place of supply is where the movement ends. But some supplies involve no movement at all. The goods stay where they are, and ownership passes to the buyer.

For such supplies, section 10(1)(c) says the place of supply is the location of such goods at the time of the delivery to the recipient. The key words are "does not involve movement of goods, whether by the supplier or the recipient". If nobody moves the goods, you look at where they sit when delivered.

Typical cases: a buyer purchases machinery that stays in the seller's factory, or goods lying in a warehouse are sold and delivered there, or stock in a godown is sold by way of transfer of title while the goods remain in place. The supplier may be registered in one State and the goods may lie in another. The goods' location then fixes the place of supply, not the supplier's registered address.

One overriding rule matters. Clause (ca) applies to supplies to a person who is not registered. It applies notwithstanding clauses (a) and (c). The place of supply is then the location as per the recipient's address recorded in the invoice, or the supplier's location if no address is recorded. Recording only the name of the State counts as recording the address.

Key rules to remember

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.

How to solve Supply Where No Movement of Goods Takes Place questions

Use this order for any question on a supply of goods where the goods do not move.

  1. 1Confirm the supply is of goods and is not an import or export, because section 10 excludes those.
  2. 2Check whether the goods are moved by the supplier, the recipient or anyone else. If no movement is involved, clause (c) is the candidate rule.
  3. 3Check whether the recipient is a registered person. If not, clause (ca) overrides and you read the address on the invoice.
  4. 4For a registered recipient, find where the goods are located when delivered to the recipient.
  5. 5Name that State or Union territory as the place of supply.
  6. 6Note the supplier's location and compare. Same State means CGST + SGST/UTGST; different State means IGST.
  7. 7Write the conclusion with the section reference and one line of reasoning.

Quickest way: Three-question check

When to use it: Use it in MCQs and short case scenarios where you have about two minutes.

  1. Do the goods move? If no, think clause (c).
  2. Is the buyer unregistered? If yes, go to the address on the invoice (clause ca).
  3. Otherwise, place of supply is where the goods sit at delivery. Compare with the supplier's State to choose IGST or CGST + SGST.

Common mistakes in Supply Where No Movement of Goods Takes Place

  • Taking the supplier's registered State as the place of supply.

    Students link tax to the seller's office, as in some service rules.

    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.

    The question mentions a sale from a warehouse and students assume no movement.

    Fix: Read the facts. If anyone transports the goods to the buyer, clause (a) applies and the place is where movement ends.

  • Ignoring clause (ca) for unregistered buyers.

    Clause (ca) was inserted from 1 October 2023 and older notes omit it.

    Fix: Check the recipient's registration status first. For an unregistered person, use the address recorded on the invoice.

  • Using the location of goods at the time of the contract instead of at delivery.

    Students read the date of order rather than the delivery point.

    Fix: Use the words of the section: location at the time of delivery to the recipient.

  • Concluding the tax type without comparing both States.

    Students stop after naming the place of supply.

    Fix: Always compare supplier's location with the place of supply before choosing IGST or CGST + SGST.

Worked examples

Example 1

Sharma Traders, registered in Jaipur (Rajasthan), sells a lot of machinery to Kaveri Industries, registered in Bengaluru (Karnataka). The machinery lies in the seller's warehouse at Surat (Gujarat), and Kaveri Industries takes delivery there by transfer of the warehouse receipt. Nobody moves the goods. Determine the place of supply and the tax applicable.

Show the solution
  1. The supply is of goods within India, so section 10 applies.
  2. No movement of goods is involved, so clause (c) applies.
  3. The recipient is registered, so clause (ca) does not override.
  4. Location of goods at the time of delivery to the recipient is Surat, Gujarat.
  5. Place of supply is Gujarat.
  6. Supplier's location is Rajasthan and place of supply is Gujarat. They differ, so the supply is inter-State.

Answer: Place of supply is Gujarat (section 10(1)(c) IGST Act). The supply is inter-State, so IGST is charged.

Example 2

Mehta Steels, registered in Nagpur (Maharashtra), sells a stock of steel sheets lying in its Nagpur godown to Ravi, an unregistered individual. The sheets stay in the godown for Ravi's later use. Ravi's address recorded on the invoice is in Indore (Madhya Pradesh). Find the place of supply and the nature of the supply.

Show the solution
  1. No movement is involved, so clause (c) would point to Nagpur.
  2. The recipient is not a registered person, so clause (ca) applies notwithstanding clause (c).
  3. The invoice records Ravi's address in Indore, Madhya Pradesh.
  4. Place of supply is Madhya Pradesh.
  5. Supplier's location is Maharashtra. The two differ, so the supply is inter-State.

Answer: Place of supply is Madhya Pradesh under section 10(1)(ca). The supply is inter-State and attracts IGST. Had no address been recorded, the place of supply would be Maharashtra, the supplier's location.

Exam tips

  • In case scenarios, underline whether the buyer is registered. This one fact decides between clause (c) and clause (ca).
  • Quote the exact phrase: location of the goods at the time of delivery to the recipient. It earns marks in written answers.
  • State the final tax type, IGST or CGST + SGST/UTGST, because examiners test the consequence, not just the place.
  • In MCQs, look for distractors using the supplier's address or the contract date. Both are wrong for clause (c).
  • Remember clause (ca) applies from 1 October 2023, so answers for the June 2027 term should include it.

Practice questions from Place of Supply

Supply Where No Movement of Goods Takes Place in other exams

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

Supply Where No Movement of Goods Takes Place: frequently asked questions

Which section governs place of supply when goods are not moved?

Section 10(1)(c) of the IGST Act. It says the place of supply is the location of the goods at the time of delivery to the recipient, where the supply involves no movement by the supplier or recipient.

Does section 10(1)(c) apply to imports and exports?

No. Section 10 covers supplies of goods other than goods imported into, or exported from, India. Those are handled by a separate section.

What if the buyer is not registered?

Clause (ca) overrides clause (c). The place of supply is the buyer's address recorded on the invoice, or the supplier's location if no address is recorded.

How is this different from section 10(1)(a)?

Clause (a) applies when goods are moved and fixes the place where the movement ends. Clause (c) applies when there is no movement and fixes the place where the goods are at delivery.