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CA Final · Indirect Tax Laws · Time of Supply

Gulmohar Retail Ltd sells gift vouchers redeemable at any of its stores for any goods. On 3 May it issues a voucher of Rs 10,000 to a customer, who redeems it on 18 September for goods taxable at 18%. Under section 12(4) of the CGST Act, 2017, what is the time of supply, assuming the goods supplied are not identifiable at issue?

The time of supply is 18 September, the date of redemption. Under the voucher rule, the issue date applies only if the supply is identifiable at that point. A voucher redeemable for any goods does not identify the supply at issue.

  1. A3 May, the date of issue of the voucher
  2. B18 September, the date of redemptionCorrect
  3. CThe date the voucher money is deposited in bank
  4. DThe date the customer files a return

Explanation

Under the section on vouchers, if the supply is identifiable at issue the time of supply is the date of issue; otherwise it is the date of redemption. Since the voucher can be redeemed for any goods, the supply is not identifiable on 3 May, so redemption on 18 September is the time of supply. Choosing issue date ignores the identifiability condition.

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