# Key Definitions: Supplier, Recipient, Person

## 1. Supplier [Section 2(105)]

A supplier is the person supplying goods/services/both and includes an agent acting on his behalf.

### Special Rule for Specified Actionable Claims

The person who organises or arranges (directly or indirectly) the supply — including one who owns, operates, or manages a digital/electronic platform — is deemed the supplier, irrespective of:

Whether actionable claims are supplied by him or through him
Whether consideration in money/money's worth (including virtual digital assets) is paid to him/through him/placed at his disposal in any manner

> Why this matters: Brings online gaming/betting platforms squarely within the GST net.

## 2. Recipient [Section 2(93)]

Scenario	Who is the Recipient?
Consideration is payable	The person liable to pay the consideration
No consideration (goods)	Person to whom goods are delivered/made available, OR to whom possession/use of goods is given
No consideration (services)	Person to whom the service is rendered

Inclusion: Recipient includes an agent acting on behalf of the actual recipient.

## 3. Person [Section 2(84)] — Comprehensive List

The term 'person' includes:

#	Type of Person
a	Individual
b	Hindu Undivided Family (HUF)
c	Company
d	Firm
e	Trust
f	Limited Liability Partnership (LLP)
g	Local authority
h	AOP/BOI (incorporated or not, in or outside India)
i	Corporation/Government company
j	Body corporate incorporated outside India
k	Central / State Government
l	Co-operative society
m	Society under Societies Registration Act, 1860
n	Every artificial juridical person not falling above

### Memory Anchor

Note: 'Person' is wider than Income Tax Act's definition — it specifically includes foreign body corporates and government bodies as taxable entities.

Worked example

### Example 1

Example 1 – Recipient identification: A company gifts a laptop (ITC availed) to its employee without charging. Who is the recipient?

No consideration is payable for the laptop
Goods delivered to the employee
Recipient = Employee

### Example 2

Example 2 – Person classification: A foreign company (incorporated in Singapore) provides software services to an Indian client. Is the Singapore company a 'person' under GST?

Yes, per Section 2(84)(j) — any body corporate incorporated outside India is a 'person'

### Example 3

Example 3 – Supplier in online gaming: Mr. X plays on online betting platform 'BetX'. Real money is wagered. Who is the supplier liable for GST on specified actionable claims?

BetX (platform owner/operator) is deemed the supplier
BetX must discharge GST liability as if it were the supplier

⚠️ Common exam mistakes

Assuming 'recipient' is always the person paying — when consideration is absent, the focus shifts to delivery/rendering
Forgetting that an AGENT is included as both supplier and recipient when acting on behalf of another
Overlooking that 'person' under GST is wider than Income Tax — it includes foreign body corporates and trusts

Bare-Act text Sections 2(84), 2(93), 2(105) · CGST Act, 2017 · click to expand

Section 2(105): 'supplier' in relation to any goods or services or both, shall mean the person supplying the said goods or services or both and shall include an agent acting as such on behalf of such supplier. Section 2(93): 'recipient' of supply of goods or services or both, means — (a) where consideration is payable, the person liable to pay; (b) where no consideration is payable for goods, the person to whom goods are delivered or made available; (c) where no consideration is payable for service, the person to whom service is rendered. Section 2(84): defines 'person'.

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Definitions - Supplier, Recipient and Person

Worked example

⚠️ Common exam mistakes