Text
The text below is 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.
Section 10, verbatim (show)
section 10
Section 10. Place of supply of goods other than supply of goods imported into, or exported from India. -
(1) The place of supply of goods, other than supply of goods imported into, or exported from India, shall be as under,-
(a) where the supply involves movement of goods, whether by the supplier or the recipient or by any other person, the place of supply of such goods shall be the location of the goods at the time at which the movement of goods terminates for delivery to the recipient;
(b) where the goods are delivered by the supplier to a recipient or any other person on the direction of a third person, whether acting as an agent or otherwise, before or during movement of goods, either by way of transfer of documents of title to the goods or otherwise, it shall be deemed that the said third person has received the goods and the place of supply of such goods shall be the principal place of business of such person;
(c) where the supply does not involve movement of goods, whether by the supplier or the recipient, the place of supply shall be the location of such goods at the time of the delivery to the recipient;
1[(ca) where the supply of goods is made to a person other than a registered person, the place of supply shall, notwithstanding anything contrary contained in clause (a) or clause (c), be the location as per the address of the said person recorded in the invoice issued in respect of the said supply and the location of the supplier where the address of the said person is not recorded in the invoice.
Explanation.—For the purposes of this clause, recording of the name of the State of the said person in the invoice shall be deemed to be the recording of the address of the said person;]
(d) where the goods are assembled or installed at site, the place of supply shall be the place of such installation or assembly;
(e) where the goods are supplied on board a conveyance, including a vessel, an aircraft, a train or a motor vehicle, the place of supply shall be the location at which such goods are taken on board.
(2) Where the place of supply of goods cannot be determined, the place of supply shall be determined in such manner as may be prescribed.
1. Inserted by s. 4 of the Integrated Goods and Services Tax (Amendment) Act, 2023 (No. 31 of 2023) - Brought into force w.e.f. yet to be notified.
Sub-section (1)
10(1)(a)Movement destination
shall be the location of the goods at the time at which the movement of goods terminates for delivery to the recipientSection 10(1)(a)
Movement may be by the supplier, recipient or another person. The delivery-termination event determines the place.
Questions to answer on the fileMovement terminating for delivery5 questions
Questions to answer on the fileInteraction between simultaneously relevant clauses3 questions
10(1)(b)Third-person direction
it shall be deemed that the said third person has received the goodsSection 10(1)(b)
Direction must precede or occur during movement, with delivery to the recipient or another person. The directing person's principal place of business becomes the place of supply.
Questions to answer on the file5 questions
10(1)(c)No movement
the place of supply shall be the location of such goods at the time of the delivery to the recipientSection 10(1)(c)
The supply must involve no movement by supplier or recipient. Delivery fixes the goods-location event.
Questions to answer on the file5 questions
10(1)(ca) and ExplanationPending recipient-address rule
the place of supply shall, notwithstanding anything contrary contained in clause (a) or clause (c), be the locationSection 10(1)(ca) and Explanation
Footnote 1 marks the insertion pending. Its proposed rule uses the unregistered recipient's invoice address or supplier location if absent, with State-name entry deemed an address. It expressly overrides only clauses (a) and (c); the law does not settle ordering among overlapping clauses (b), (d), (e) and (ca).
Questions to answer on the file9 questions
10(1)(d)Installation or assembly
the place of supply shall be the place of such installation or assemblySection 10(1)(d)
The goods must be installed or assembled at site. That site supplies the location.
Questions to answer on the file5 questions
10(1)(e)On-board goods
the place of supply shall be the location at which such goods are taken on board.Section 10(1)(e)
The conveyance examples include vessels, aircraft, trains and motor vehicles. The taking-aboard location determines the place.
Questions to answer on the file3 questions
10(2)Prescribed fallback
the place of supply shall be determined in such manner as may be prescribed.Section 10(2)
The fallback requires inability to determine the place. It applies within section 10's scope excluding imports and exports.
Questions to answer on the file4 questions
Other 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.
Scope and law state 10(1)
Questions to answer on the file6 questions
Frequently asked questions
Whose business place applies to third-person-directed delivery?
The directing third person's principal place of business applies under clause (b). Receipt by that person is deemed.
Section 10(1)(b)
Does an on-board supply use the final destination?
Clause (e) uses where the goods are taken aboard. It identifies that event rather than final destination.
Section 10(1)(e)
How are overlapping special clauses ordered?
The law does not settle the general ordering involving clauses (b), (d) or (e), including overlap with clause (ca). The proposed clause (ca) expressly overrides only (a) and (c).
Section 10(1)
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 |
|---|
| 1 |
Relationship with other provisions
| Provision | Connection | Words that tie them |
|---|---|---|
| Section 2 of the CGST Act, 2017 | IGST section 10(1)(b) defined by Section 2 of the CGST Act, 2017, principal place of business, via IGST section 2(24), compiled and reviewed | 10(1)(b) "the principal place of business of such person" |
| Section 2 of the CGST Act, 2017 | IGST section 10(1)(ca) defined by Section 2 of the CGST Act, 2017, registered person, via IGST section 2(24), compiled and reviewed | 10(1)(ca) "a person other than a registered person" |
| Section 77 of the CGST Act, 2017 | Section 77 of the CGST Act, 2017 requires IGST sections 7/8 classification using section 10, pending wiring | CGST 77(1) "considered by him to be an intra-State supply, but which is subsequently held to be an inter-State supply" |
Circulars and notifications
Circulars and notifications in the CBIC repository that cite this section, newest first, by number, date and subject. A listing here does not say what an instrument decides; read the instrument.
Circulars (3)
| Number | Date | Subject |
|---|---|---|
| Circular No. 209/03/2024-GST | 26 June 2024 | Clarification on the provisions of clause (ca) of Section 10(1) of the Integrated Goods and Service Tax Act, 2017 relating to place of supply |
| Circular No. 90/09/2019-GST | 18 February 2019 | Seeks to clarify situations of compliance of rule 46(n) of the CGST Rules, 2017 while issuing invoices in case of inter- State supply. |
| Circular No. 38/12/2018-GST | 26 March 2018 | Clarifications on issues related to Job Work. |
Notifications (2)
| Number | Date | Subject |
|---|---|---|
| Notification No. 30/2018-Integrated Tax (Rate) | 31 December 2018 | Seeks to amend notification No. 10/2017- Integrated Tax (Rate) so as to specify services to be taxed under Reverse Charge Mechanism (RCM) as recommended by Goods and Services Tax Council in its 31st meeting held on 22.12.2018. |
| Notification No. 09/2017-Integrated Tax (Rate) | 28 June 2017 | To notify the exemptions on supply of services under IGST Act rescinded by a later instrument |
Unsettled questions
The words of section 10 do not answer this question. Where one decides a matter on the file, the answer depends on the position taken on it.
- What ordering resolves simultaneously applicable section 10 clauses involving (b), (d) or (e), including their overlap with (ca), when the text expressly makes (ca) override only (a) and (c) and supplies no general ordering among those remaining cases?
See also
- Section 11 of the IGST Act, 2017: place of supply of goods imported into, or exported from India
- Section 9 of the IGST Act, 2017: supplies in territorial waters
- Section 77 of the CGST Act, 2017: tax wrongfully collected and paid to Central Government or State Government
References
- Central Board of Indirect Taxes and Customs. "Section 10. Place of supply of goods other than supply of goods imported into, or exported from India". Integrated Goods and Services Tax Act, 2017, CBIC tax information portal, with amendment footnotes 1 to 1. Retrieved 17 September 2026.
External links
- IGST Act, 2017, Section 10 on the CBIC tax information portal