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Microlesson · 5-min read

Time of Supply of Vouchers

# Time of Supply of Vouchers

A voucher is an instrument that the recipient can use as consideration (wholly or partly) for a future supply of goods or services. The time of supply (ToS) rule for vouchers depends on whether the underlying supply is identifiable at the time of issue.

## The Two-Case Rule

SituationTime of Supply
Supply is identifiable at the time of issue of voucher (e.g., a KFC voucher redeemable only at KFC for food)Date of issue of the voucher
Supply is NOT identifiable at the time of issue (e.g., a general gift card usable at many merchants)Date of redemption of the voucher

## Why the distinction matters

  • When the supply is identifiable, the nature of the goods/services, the rate of tax, and the supplier are all known up front. GST can therefore be charged at the moment the voucher is issued.
  • When the supply is not identifiable, the rate of tax and even the supplier may differ depending on what the holder ultimately buys. Tax must therefore wait until the voucher is actually redeemed.

## Key trigger words

  • Identifiable → issue date
  • Not identifiable / general purpose → redemption date

Worked example

### Example 1

Example 1 — Identifiable supply

KFC issues a meal voucher on 5 April redeemable only against KFC food items. The customer redeems it on 20 May.

Time of supply = 5 April (date of issue), because the supply (KFC food) is identifiable at the time of issue.

### Example 2

Example 2 — Non-identifiable supply

A shopping mall issues a ₹2,000 gift voucher on 1 April that can be redeemed at any store in the mall (apparel, electronics, food, etc.). The holder redeems it at an electronics store on 15 June.

Time of supply = 15 June (date of redemption), because at the time of issue it was not known what would be purchased or at what GST rate.

⚠️ Common exam mistakes

  • Treating every voucher as taxable on the date of issue — this is wrong when the supply is not identifiable.
  • Confusing 'identifiable supply' with 'identifiable supplier'. The supply itself (goods/services and rate) must be identifiable, not merely the issuer of the voucher.
  • Forgetting that a multi-purpose / open-loop voucher is taxed only on redemption.
  • Applying voucher rules to discount coupons that are not 'vouchers' under the CGST Act.
Bare-Act text Section 12(4) / 13(4) · CGST Act, 2017 · click to expand
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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