Place of Supply – Passenger Transportation [Section 12(9)] including Right to Passage
## Place of Supply – Passenger Transportation Services [Section 12(9)]
### Rule for Passenger Transportation
Recipient
Place of Supply
Registered person
Location of such registered person
Unregistered person
Place where the passenger embarks on the conveyance for the continuous journey
### Right to Passage for Future Use
Where the right to passage is given for future use and the embarkation point is not known:
Recipient
Place of Supply
Registered person
Location of such registered person
Unregistered – address on record
Location of the recipient (address on record)
Unregistered – no address on record
Location of the supplier
### Key Concepts
Continuous journey = Single ticket/journey with no stopover, even if multiple legs.
Stopover = Stopping at a place for some duration.
Each separate journey is assessed separately.
Worked example
### Example 1
Example 1: An unregistered passenger boards a flight from Delhi to Mumbai.
Embarkation point: Delhi
Place of Supply = Delhi
### Example 2
Example 2: A registered company in Bangalore books a flight ticket for its director from Delhi to Chennai.
Recipient registered in Bangalore
Place of Supply = Karnataka (Bangalore)
### Example 3
Example 3: Mr. P (unregistered) buys a prepaid travel voucher (worth Rs.50,000) with no specific journey. Address on record: Lucknow.
Place of Supply = Lucknow (UP) (address on record)
### Example 4
Example 4: A returning passenger from Mumbai to Delhi with no stopover constitutes a continuous journey. Place of supply = Mumbai (embarkation point) for an unregistered passenger.
⚠️ Common exam mistakes
Missing the special rule for 'right to passage for future use' – different from regular ticket sale.
Forgetting the definition of 'continuous journey' – a stopover breaks it.
Treating each leg as a separate journey when there is no stopover – incorrect.
Bare-Act text Section 12(9) · IGST Act, 2017 · click to expand
Section 12(9) of IGST Act, 2017 – 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 – 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.