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CA Intermediate · Taxation · Place of Supply

Rohan, an unregistered individual residing in Lucknow (Uttar Pradesh), books a tour of Kerala with Coastal Journeys, a registered travel firm in Kochi (Kerala), and takes a passenger transport service by a hired cab from Kochi airport to Munnar, boarding at Kochi. Separately, he also buys from the same firm a hotel booking for a stay at a resort in Munnar. Which pair correctly states the places of supply of (i) the passenger transportation service and (ii) the hotel accommodation service?

Both places of supply are in Kerala. Passenger transport to an unregistered person is supplied where the passenger embarks, here Kochi. Hotel accommodation relates to immovable property, so the place of supply is where the resort is located, Munnar. Lucknow, the recipient's home, is not relevant to either.

  1. A(i) Uttar Pradesh; (ii) Kerala
  2. B(i) Kerala, where passenger embarks; (ii) Kerala, location of the immovable propertyCorrect
  3. C(i) Kerala, where passenger embarks; (ii) Uttar Pradesh
  4. D(i) Uttar Pradesh; (ii) Uttar Pradesh

Explanation

For passenger transportation to an unregistered recipient, the place of supply is where the passenger embarks on the conveyance, which is Kochi, Kerala. Accommodation in a hotel is a service relating to immovable property, so the place of supply is where the property is located, Munnar, Kerala, irrespective of recipient status. Using Lucknow wrongly applies the recipient-location rule.

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