Text
The text below is these clauses of the section as served by the CBIC tax information portal on 17 September 2026, with the portal's own amendment footnote markers (shown as small numerals before a bracket) and its footnotes.[1] The Act as published in the Gazette of India is the legal source.
Clauses 2(5), 2(88), 2(93) and 2(105), verbatim (show)
(5) "agent" means a person, including a factor, broker, commission agent, arhatia, del credere agent, an auctioneer or any other mercantile agent, by whatever name called, who carries on the business of supply or receipt of goods or services or both on behalf of another;
(88) "principal" means a person on whose behalf an agent carries on the business of supply or receipt of goods or services or both;
(93) "recipient" of supply of goods or services or both, means-
(a) where a consideration is payable for the supply of goods or services or both, the person who is liable to pay that consideration;
(b) where no consideration is payable for the supply of goods, the person to whom the goods are delivered or made available, or to whom possession or use of the goods is given or made available; and
(c) where no consideration is payable for the supply of a service, the person to whom the service is rendered,
and any reference to a person to whom a supply is made shall be construed as a reference to the recipient of the supply and shall include an agent acting as such on behalf of the recipient in relation to the goods or services or both supplied;
(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 in relation to the goods or services or both supplied;
15[Provided that a person who organises or arranges, directly or indirectly, supply of specified actionable claims, including a person who owns, operates or manages digital or electronic platform for such supply, shall be deemed to be a supplier of such actionable claims, whether such actionable claims are supplied by him or through him and whether consideration in money or money's worth, including virtual digital assets, for supply of such actionable claims is paid or conveyed to him or through him or placed at his disposal in any manner, and all the provisions of this Act shall apply to such supplier of specified actionable claims, as if he is the supplier liable to pay the tax in relation to the supply of such actionable claims.]
* Enforced w.e.f. 22nd July 2017.
15. Inserted by s. 2 of Central Goods and Services Tax (Amendment) Act, 2023 (No. 30 of 2023) - Brought into force w.e.f. 01st October, 2023 vide Notification No. 48/2023-C.T., dated 29nd Sep, 2023.
2(5)agent
"agent" means a person, including a factor, broker, commission agent, arhatia, del credere agent, an auctioneer or any other mercantile agent, by whatever name called, who carries on the business of supply or receipt of goods or services or both on behalf of another;Section 2(5)
The person carries on the business of supply or receipt for another person. The definition includes the listed mercantile roles, whatever their name.
2(88)principal
"principal" means a person on whose behalf an agent carries on the business of supply or receipt of goods or services or both;Section 2(88)
The principal is the person for whom an agent carries on the business of supply or receipt.
2(93)recipient
"recipient" of supply of goods or services or both, means- (a) where a consideration is payable for the supply of goods or services or both, the person who is liable to pay that consideration; (b) where no consideration is payable for the supply of goods, the person to whom the goods are delivered or made available, or to whom possession or use of the goods is given or made available; and (c) where no consideration is payable for the supply of a service, the person to whom the service is rendered, and any reference to a person to whom a supply is made shall be construed as a reference to the recipient of the supply and shall include an agent acting as such on behalf of the recipient in relation to the goods or services or both supplied;Section 2(93)
Where consideration is payable, the recipient is the person liable to pay it. Without consideration, the recipient is the person receiving the goods, possession or use, or the service. References to the recipient include an agent acting on that person’s behalf for the supply.
2(105)supplier
"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 in relation to the goods or services or both supplied; Provided that a person who organises or arranges, directly or indirectly, supply of specified actionable claims, including a person who owns, operates or manages digital or electronic platform for such supply, shall be deemed to be a supplier of such actionable claims, whether such actionable claims are supplied by him or through him and whether consideration in money or money's worth, including virtual digital assets, for supply of such actionable claims is paid or conveyed to him or through him or placed at his disposal in any manner, and all the provisions of this Act shall apply to such supplier of specified actionable claims, as if he is the supplier liable to pay the tax in relation to the supply of such actionable claims.Section 2(105)
The supplier includes an agent acting on the supplier’s behalf. A person directly or indirectly organising or arranging specified actionable-claim supplies, including a platform owner, operator or manager, is deemed the supplier whether supply and consideration pass to or through that person or consideration is otherwise at their disposal. The Act applies as if that person is the supplier liable for the tax.
Questions to answer on the file
Questions a reviewer answers from the engagement file, grouped by the part of the section they come from. They describe what the section asks; they do not decide it.
Who supplies and who receives clauses (5), (88), (93) and (105) with its proviso
Questions to answer on the file6 questions
Amendment history
The CBIC text carries 1 footnote. The table gives each in the source's own terms. Effective dates are as the footnotes state them.[1]
| Note | Change | Instrument | Effective from |
|---|---|---|---|
| 15 | the proviso deeming the organiser of specified actionable claims to be the supplier inserted | s.2 of the Central Goods and Services Tax (Amendment) Act 2023, No. 30 of 2023, notified by Notification No. 48/2023-C.T. dated 29 September 2023[2][3] | 01.10.2023 |
References
- Central Board of Indirect Taxes and Customs. "Section 2. Who supplies and who receives". Central Goods and Services Tax Act, 2017, CBIC tax information portal, with amendment footnotes 1 to 1. Retrieved 17 September 2026.
- The Central Goods and Services Tax (Amendment) Act, 2023. Cited in CBIC footnote 15.
- Notification No. 48/2023-Central Tax, dated 29 September 2023: Seeks to notify the provisions of the Central Goods and Services Tax (Amendment) Act, 2023. Cited in CBIC footnote 15.
External links
- CGST Act, 2017, Section 2 on the CBIC tax information portal