Place of Supply of Goods (domestic) [Section 10 IGST Act]
# Place of Supply of Goods — Domestic [Section 10 of IGST Act]
Five scenarios — apply the FIRST one that fits.
Sl. No.
Scenario
Place of Supply
(1)
Supply involves movement of goods (by supplier, recipient, or anyone else)
Location where movement of goods terminates (i.e., where delivery ends)
(2)
Supply does NOT involve movement ('as is where is')
Location where the goods are made available to the recipient
(3)
Notwithstanding (1) and (2): over-the-counter sale to an unregistered person
Address of the recipient on the invoice (state name suffices). If not recorded → location of supplier
(4)
Supply involves assembly or installation of goods
Location of such assembly or installation
(5)
Goods supplied on board a conveyance (vessel, aircraft, train, motor vehicle)
Location where the goods are taken on board
Note for (3): If the billing address and delivery address are different, the delivery address may be mentioned on the invoice for POS purposes.
## Bill-To / Ship-To Model (very important)
When a third party (Mr. A) instructs the supplier (Mr. B) to deliver goods directly to a recipient (Mr. C), there are two simultaneous supplies:
```
Mr. B (Supplier, Punjab) ──────── Supply X ────────► Mr. A (Third Party, Rajasthan)
│
└─ ships goods directly to ──► Mr. C (Recipient, Haryana) [Supply Y]
```
Supply X (B → A): POS = principal place of business of A → Rajasthan.
Supply Y (A → C): POS = where movement of goods ends → Haryana.
This ensures the credit chain works correctly even when goods skip the third party physically.
Worked example
### Example 1
(i) Movement of goods — Pappu (Jaipur, registered) sells & delivers a machine to Mohan in Pune.
POS = Pune (Maharashtra) — where movement terminates.
### Example 2
(ii) No movement — Kapu (Mumbai) sells a flat in Hisar to Sonu (Indore) along with a pre-installed AC.
POS for the AC = Hisar — where the goods are made available (no further movement).
### Example 3
(iii) Over-the-counter to unregistered — Pappu (unregistered, Jaipur) buys a laptop from Croma Delhi and gives state name 'Rajasthan' on invoice.
POS = Rajasthan — address of recipient on invoice.
### Example 4
(iv) Assembly / installation — Tipu (Chennai) sells a machine to Ram (Shimla), to be installed at Ram's factory in Jaipur.
POS = Jaipur — place of installation, regardless of where the parties are.
### Example 5
(v) On-board conveyance — Kapu (Pune) buys a power bank from Shyam (Mumbai) on a train to Jaipur; Shyam boarded at Mumbai.
POS = Mumbai — where the goods were taken on board.
### Example 6
(vi) Bill-to/Ship-to — B (Punjab) supplies to A (Rajasthan); A instructs B to ship goods directly to C (Haryana).
Supply 1 (B→A): POS = Rajasthan (place of business of A).
Supply 2 (A→C): POS = Haryana (where movement ends).
⚠️ Common exam mistakes
Treating installation cases under clause (1) (movement) — installation has its own rule (clause 4) and POS is where it's installed, not where it terminates as cargo.
Applying clause (1) origin (Mumbai → Pune as 'Mumbai'). POS is always the destination where movement ENDS, not where it starts.
Ignoring clause (3) for OTC sales to unregistered persons — even if goods move, the address on the invoice controls.
Forgetting that in on-board sales (clause 5), POS is where the goods are TAKEN on board, not where the conveyance ends its journey.
Identifying only ONE supply in a Bill-to/Ship-to chain — there are TWO deemed supplies, each with its own POS.
Bare-Act text Section 10 · IGST Act, 2017 · click to expand
(1) 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. (1A) [Bill-to / ship-to] 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. (2) 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 the delivery to the recipient. (3) Where the goods are assembled or installed at site, the place of supply shall be the place of such installation or assembly. (4) 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.