# Clarifications on Place of Supply

## (1) Location of Recipient of Service

Where Supply Is Received	Treated as Location
At registered place of business	Registered place of business
At a fixed establishment other than registered place	Location of such fixed establishment

## (2) Location of Supplier of Service

Where Supply Is Made From	Treated as Location
Registered place of business	Registered place of business
Fixed establishment other than registered place	Location of such fixed establishment

## (3) Online Money Gaming / ECO / OIDAR

For supply of online money gaming and taxable services provided by e-Commerce Operators (ECO) or OIDAR service providers, the name, address, PIN code, and State of recipient must be mentioned on the invoice. So, per the general provision, PoS = location of recipient (as captured on the invoice).

## (4) Advertisement Sector — Two Distinct Vendor Roles

This is a tricky area. Distinguish:

Vendor's Role	Nature of Supply	Place of Supply
Vendor only provides space/right to use space on hoarding (immovable property) for client to display the ad	Service related to immovable property	Location of immovable property
Vendor is responsible for the actual display of advertisement (whether on own or rented hoarding)	Advertisement service	General provisions apply (typically location of recipient if registered)

The key question: Is the vendor giving you access to the space (immovable property rule), or are they delivering the advertising outcome (advertisement service rule)?

Worked example

### Example 1

Two-tier advertising chain — applying both rules

Coca Cola (Registered in Surat) avails advertisement services of ₹50 lacs from ABC Advertiser Agency (Pune) for displaying ads on hoardings at locations in Mumbai. ABC Advertiser, in turn, takes the right to use the hoarding space (attached to earth) from Tom Holdings for ₹10 lacs.

Solution:

Leg 1 — ABC Advertiser → Coca Cola (₹50 lacs): ABC is responsible for actually displaying the ad → this is an advertisement service. General provisions apply → PoS = Surat (location of recipient, Coca Cola).
Leg 2 — Tom Holdings → ABC Advertiser (₹10 lacs): Tom only granted rights to use the hoarding (immovable property attached to earth) → this is a service related to immovable property. PoS = Mumbai (location of the hoarding/property).

⚠️ Common exam mistakes

Treating all advertising services uniformly — distinguish between rental of hoarding space (immovable property) and the actual ad-display service.
Ignoring the fixed-establishment rule when supply happens at a branch different from the registered office.
Forgetting that for OIDAR/ECO/online money gaming, address-on-invoice fixes the PoS at recipient by default.

Reference:

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Clarifications on Place of Supply - Location of Recipient/Supplier and Advertisement Sector

Worked example

⚠️ Common exam mistakes