Place of Supply - Transportation of Passengers [Section 12(9) IGST Act]
# Place of Supply: Passenger Transportation
## Rule
Recipient's Status
Place of Supply
Registered
Location of recipient
Unregistered
Place where the passenger embarks on the journey for continuous travel
Future journey, boarding point unknown (e.g., Delhi Metro card, prepaid tokens)
Location of recipient on record; if not available, location of supplier
## Return Journey Rule
A return journey is treated as a separate journey — analyse each leg independently.
## Why This Matters
For registered recipients (e.g., a corporate booking flights for staff), PoS pins to the company so ITC is available in the right State. For unregistered passengers (individuals), the embarkation point captures the State where service began.
Worked example
### Example 1
Example — Round trip by air
Mr. Ron (Registered in Pune) takes a round-trip with Air India: Mumbai → Amritsar → Mumbai.
Solution (Ron registered): PoS for both legs = Pune (location of recipient).
Variation (Ron unregistered): Each leg is a separate journey.
Treating round trip as a single journey for unregistered recipients — each leg is separate.
Using destination as PoS — it's the embarkation point, not destination.
Forgetting the prepaid/future-journey exception (Metro card etc.) where embarkation is unknown.
Bare-Act text Section 12(9) · IGST Act, 2017 · click to expand
Section 12(9), IGST Act: The place of supply of passenger transportation service to,— (a) a registered person, shall be the location of such person; (b) a person other than a registered person, shall be the place where the passenger embarks on the conveyance for a continuous journey. Provided that where the right to passage is given for future use and the point of embarkation is not known at the time of issue of right to passage, the place of supply of such service shall be determined in accordance with the provisions of sub-section (2). Explanation.— For the purposes of this sub-section, the return journey shall be treated as a separate journey, even if the right to passage for onward and return journey is issued at the same time.