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CA Intermediate · Taxation · Place of Supply

Ishaan, an individual in Delhi, books a train-based tour package from Voyage Pvt. Ltd. of Chennai. Separately, Voyage supplies a passenger transportation service in which Ishaan, an unregistered person, is issued a ticket in Delhi for a journey starting from Jaipur (Rajasthan) to Agra (Uttar Pradesh); the ticket is issued and paid for in Delhi. Which is the place of supply for this passenger transport service?

The place of supply is Jaipur, Rajasthan. For passenger transport supplied to an unregistered person, the place of supply is where the passenger embarks on the conveyance, not where the ticket is issued or paid for, nor the destination or the supplier's location.

  1. ADelhi, the place where the ticket was issued
  2. BChennai, the supplier's location
  3. CJaipur, Rajasthan, the place where the passenger embarks on the conveyanceCorrect
  4. DAgra, Uttar Pradesh, the destination

Explanation

For passenger transportation to an unregistered person, the place of supply is the place where the passenger embarks on the conveyance for the journey. The journey starts in Jaipur, so the place of supply is Rajasthan. Delhi (where the ticket was bought) is wrong because the ticket location is relevant only if the ticket is for a return or onward journey that is not yet fixed, which is not the case here. Since Ishaan is not registered, the registered-person default rule does not apply.

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