CS Professional · Goods and Services Tax (GST) and Corporate Tax Planning · Time of Supply
Sunrise Retail Pvt Ltd, Pune, sells prepaid gift vouchers. On 5 March it issues a voucher to a customer, and the goods or services for which it can be redeemed are not identifiable at the time of issue. The customer redeems it on 20 May. Under section 12(4) of the CGST Act, 2017, the time of supply of the goods is:
The time of supply is 20 May, the date of redemption. The supply was not identifiable when the voucher was issued, and the law fixes the date of redemption for all voucher cases other than those where the supply is identifiable at issue.
- A5 March, the date of issue of the voucher
- B20 May, the date of redemption of the voucherCorrect
- CThe date on which the supplier files the periodical return
- DThe date on which the supplier pays the tax
Explanation
For vouchers, the time of supply is the date of issue if the supply is identifiable at that point. In all other cases it is the date of redemption. Here the supply is not identifiable on issue, so the date of redemption (20 May) applies. Choosing 5 March wrongly treats every voucher as taxable on issue.
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