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CA Final · Indirect Tax Laws · Place of Supply

A Rajdhani-type train leaves Mumbai (Maharashtra) for Delhi. The railway's caterer loads packaged snacks at Mumbai station, and further stocks of the same type are loaded at Bhopal (Madhya Pradesh). A passenger buys snacks loaded at Bhopal while the train is in Rajasthan. Under Section 10, what is the place of supply of those snacks?

The place of supply is Madhya Pradesh. For goods supplied on board a conveyance such as a train, the place of supply is where the goods are taken on board. These snacks were loaded at Bhopal, not where the train was when sold or where the journey began or ends.

  1. ARajasthan, where the sale took place
  2. BMadhya Pradesh, where the snacks were taken on boardCorrect
  3. CMaharashtra, where the journey began
  4. DDelhi, where the journey terminates

Explanation

Section 10(1)(e) states that for goods supplied on board a conveyance, including a train, the place of supply is the location at which the goods are taken on board. The snacks were taken on board at Bhopal, so the place is Madhya Pradesh. The location of the train when sold or the journey's start and end points are irrelevant.

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