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Microlesson · 5-min read

Time of Supply of Vouchers (Section 12(4) / 13(4))

# Time of Supply of Vouchers (Section 12(4) / 13(4))

A voucher is an instrument that creates an obligation to accept it as consideration for a supply.

## The Two-Test Rule

SituationTOS
Supply identifiable at the time of issue of voucher (e.g., KFC meal voucher — known goods, known GST rate)Date of ISSUE of voucher
Supply NOT identifiable at issue (e.g., generic ₹500 gift card usable across multiple stores/products)Date of REDEMPTION of voucher

## Why the Distinction

If at the time of issue the GST rate, place of supply, and nature of supply are all knowable, the GST liability can crystallize at issue. Otherwise, the law waits until the voucher is actually redeemed for a specific supply.

## Applies Equally to Goods and Services

The identical rule appears in Section 12(4) for goods-based vouchers and Section 13(4) for services-based vouchers.

Worked example

### Example 1

Example 1 — Identifiable: KFC issues a voucher on 1 May, redeemable only for a specific meal combo (rate and item known). TOS = 1 May (date of issue).

### Example 2

Example 2 — Not identifiable: Amazon issues a ₹1,000 e-gift card on 1 May, redeemable for any product on Amazon (rate unknown — books vs apparel vs electronics). Customer redeems on 10 July for a ₹1,000 book. TOS = 10 July (date of redemption).

### Example 3

Example 3 — Movie ticket voucher: Specific movie + show + seat known at issue → identifiable → TOS = date of issue.

⚠️ Common exam mistakes

  • Treating every voucher as 'date of issue' — generic multi-purpose vouchers are taxed only on redemption.
  • Treating every voucher as 'date of redemption' — single-purpose vouchers where the supply is clearly identifiable are taxed at issue.
  • Forgetting that the issue/redemption test depends on whether the supply (rate, item) is known — not whether the value is known.
Bare-Act text Section 12(4) and Section 13(4) · CGST Act, 2017 · click to expand
Section 12(4) / 13(4): In case of supply of vouchers by a supplier, the time of supply shall be — (a) the date of issue of voucher, if the supply is identifiable at that point; or (b) the date of redemption of voucher, in all other cases.
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