Time Limit for Issue of Invoice - Goods (Section 31)
# Time Limit for Issue of Invoice — Goods (Section 31)
Under GST, the time within which a tax invoice must be issued for goods depends on the nature of the supply. Issuance of invoice is one of the key triggers used to determine the Time of Supply (TOS).
## Rules at a Glance
Situation
Time limit for issue of invoice
Supply involves movement of goods
On or before removal of goods
Other cases (no movement)
On or before delivery of goods or making available to recipient
Goods sent on approval / sale or return
Earlier of — (a) Time supply is confirmed, or (b) 6 months from removal
Continuous supply of goods (involving successive statements of account or successive payments)
On or before issue of each such successive statement / receipt of each successive payment
## Key Concepts
Removal means dispatch of goods either by the supplier or by the recipient.
For approval supplies, if the recipient does not confirm acceptance within 6 months, the supply is deemed to have taken place — invoice must be issued at that point.
For continuous supply of goods, the invoice cycle is tied to billing/payment milestones, not physical movement.
## Why This Matters for TOS
The date of invoice (or the last date by which invoice should have been issued) is one of the two limbs of the TOS test under forward charge. So mis-identifying the correct invoice deadline directly distorts TOS computation.
Worked example
### Example 1
Example 1 — Movement involved: Goods removed from factory on 10 May; delivered to buyer on 14 May. Invoice must be issued on or before 10 May (date of removal).
### Example 2
Example 2 — No movement (over-the-counter sale): Customer collects goods from shop on 20 June. Invoice must be issued on or before 20 June (date of delivery / making available).
### Example 3
Example 3 — Approval basis: Goods sent on 1 Jan on approval basis. Buyer confirms acceptance on 15 May. Invoice must be issued on 15 May (earlier than 6-month deadline of 1 July).
### Example 4
Example 4 — Approval, no confirmation: Goods sent on approval on 1 Jan. Buyer neither accepts nor returns by 1 July. Invoice must be issued on 1 July (6 months from removal — deemed supply).
⚠️ Common exam mistakes
Confusing 'removal' with 'delivery' — for movement cases the invoice trigger is removal, NOT delivery to the customer.
Forgetting the 6-month deemed-supply rule for approval basis, leading to late invoice and interest exposure.
Treating continuous supply of goods like a one-shot supply — each statement of account / payment is its own invoice trigger.
Issuing one invoice for the whole approval supply instead of confirming whether acceptance has occurred within 6 months.
Bare-Act text Section 31(1), 31(4), 31(7) · CGST Act, 2017 · click to expand
Section 31(1): A registered person supplying taxable goods shall issue a tax invoice — (a) before or at the time of removal of goods for supply to the recipient, where the supply involves movement of goods; (b) delivery of goods or making available thereof to the recipient, in any other case. Section 31(4): In case of continuous supply of goods, where successive statements of accounts or successive payments are involved, the invoice shall be issued before or at the time each such statement is issued or, as the case may be, each such payment is received. Section 31(7): Where goods being sent or taken on approval for sale or return are removed before the supply takes place, the invoice shall be issued before or at the time of supply or six months from the date of removal, whichever is earlier.