Place of Supply of Goods — Section 10 of IGST Act (Domestic Supplies)
# Place of Supply of Goods — Section 10 of IGST Act
Section 10 lays down rules for determining the place of supply of goods (other than goods imported into / exported from India). Five different scenarios are covered:
## 10(1)(a) — Supply Involves Movement of Goods
Where the supply involves movement of goods (whether by supplier, recipient, or any other person), place of supply = location where the movement of goods terminates for delivery to the recipient.
## 10(1)(b) — Bill-to / Ship-to Model (Three-party transaction)
When goods are delivered by the supplier to a recipient on the direction of a third person (whether as an agent or otherwise), before or during movement:
It is deemed that the third person has received the goods.
Place of supply = principal place of business of the third person (i.e., the location of the third person).
This prevents double taxation and applies the 'bill-to' party's location as the place of supply.
## 10(1)(c) — No Movement of Goods
Where the supply does not involve movement of goods (e.g., supply over a counter or by transfer of documents of title without physical movement):
Place of supply = location of goods at the time of delivery to the recipient.
Example: Sale of a machine that is leased in situ.
## 10(1)(ca) — Supply to Unregistered Person
Where goods are supplied to an unregistered person:
If the address of the recipient is recorded in the invoice → Place of supply = address of the recipient.
If no address is recorded → Place of supply = location of the supplier.
## 10(1)(d) — Goods Assembled or Installed at Site
Where goods are assembled or installed at site:
Place of supply = place of such installation or assembly.
## 10(1)(e) — Goods Supplied on Board a Conveyance
Where goods are supplied on board a conveyance (vessel, aircraft, train, or motor vehicle):
Place of supply = location at which such goods are taken on board the conveyance.
## Summary Table
Sub-clause
Situation
Place of Supply
10(1)(a)
Movement involved
Where movement terminates
10(1)(b)
Bill-to / Ship-to
Location of third person
10(1)(c)
No movement
Location of goods at delivery
10(1)(ca)
Unregistered recipient
Address on invoice / location of supplier
10(1)(d)
Installation / Assembly
Place of installation/assembly
10(1)(e)
Goods on conveyance
Place where loaded on board
Worked example
### Example 1
Movement of Goods [10(1)(a)]: A registered person in Delhi orders goods from a supplier in Mumbai. Goods move from Mumbai to Delhi. Place of supply = Delhi (where movement terminates). Inter-State supply.
### Example 2
Bill-to / Ship-to [10(1)(b)]: X in Punjab instructs Y (supplier in Haryana) to deliver goods directly to Z in Rajasthan. As per Bill-to/Ship-to rule, deemed receipt by X → Place of supply = Punjab (location of third person X).
### Example 3
No Movement [10(1)(c)]: A leases a machine located in Gujarat to B without moving the machine. Place of supply = Gujarat (where goods are made available).
### Example 4
Installation at Site [10(1)(d)]: A supplier in Tamil Nadu sells and installs a generator at the buyer's factory in Karnataka. Place of supply = Karnataka (site of installation).
### Example 5
On-board Conveyance [10(1)(e)]: Snacks supplied on a train. The snacks were loaded at New Delhi station. Place of supply = Delhi, regardless of where actually sold.
⚠️ Common exam mistakes
In Bill-to/Ship-to model, mistakenly taking the place of supply as the location of the actual recipient (ship-to party) instead of the third person (bill-to party).
Confusing 10(1)(a) 'movement terminates' with 'location of recipient' — they may differ if goods are delivered elsewhere.
For installation/assembly cases, defaulting to place of supplier instead of the installation site.
For goods on a conveyance, taking the destination of the conveyance instead of where goods were loaded on board.
Ignoring the special clause 10(1)(ca) for unregistered recipients — applying registered-person rules by default.
Bare-Act text Section 10(1) · IGST Act, 2017 · click to expand
Section 10(1) of IGST Act: The place of supply of goods, other than supply of goods imported into, or exported from India, shall be as under: (a) where the supply involves movement of goods, whether by the supplier or the recipient or by any other person, the place of supply of such goods shall be the location of the goods at the time at which the movement of goods terminates for delivery to the recipient; (b) where the goods are delivered by the supplier to a recipient or any other person on the direction of a third person, whether acting as an agent or otherwise, before or during movement of goods, either by way of transfer of documents of title to the goods or otherwise, it shall be deemed that the said third person has received the goods and the place of supply of such goods shall be the principal place of business of such person; (c) where the supply does not involve movement of goods, whether by the supplier or the recipient, the place of supply shall be the location of such goods at the time of delivery to the recipient; (ca) where the supply of goods is made to a person other than a registered person, the place of supply shall be the location as per the address of the said person recorded in the invoice and the location of the supplier where the address of the said person is not recorded in the invoice; (d) where the goods are assembled or installed at site, the place of supply shall be the place of such installation or assembly; (e) where the goods are supplied on board a conveyance, including a vessel, an aircraft, a train or a motor vehicle, the place of supply shall be the location at which such goods are taken on board.