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Section 10 IGST Act: Place of Supply of Goods in India

Section 10 of the Integrated Goods and Services Tax Act, 2017 determines the place of supply of goods in cases other than imports into India and exports from India. The place of supply is important because it helps determine whether a transaction is an inter-State or intra-State supply and, consequently, whether IGST or CGST with State GST or Union Territory GST is generally applicable.

Updated: 27 September 2026 | Integrated Goods and Services Tax Act, 2017

Important current-law update: Clause (ca) of Section 10(1) applies from 1 October 2023 to supplies of goods made to a person other than a registered person. It overrides clauses (a) and (c) to the extent stated in the provision. The original version of this page did not contain this clause.
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What Section 10 of the IGST Act covers

Chapter V of the IGST Act contains the place-of-supply provisions. Section 10 deals with goods other than goods imported into India or exported from India. Imports and exports of goods are dealt with separately under Section 11 of the IGST Act.

In practical terms, Section 10 identifies the State or Union territory that is treated as the destination of a supply of goods. Different rules apply depending on whether the goods move, are delivered on the direction of a third person, do not move, are supplied to an unregistered person, are installed at a site, or are supplied on board a conveyance.

Related provisions: Section 7 deals with inter-State supplies and Section 8 deals with intra-State supplies. Both provisions operate subject to the applicable place-of-supply rules. See Section 7 and Section 8.

Section 10 - Current place-of-supply rules for goods

Section 10(1): For goods other than goods imported into or exported from India, the place of supply is determined under the following rules.

(a) Supply involving movement of goods: where the supply involves movement of goods by the supplier, recipient or any other person, the place of supply is the location of the goods when their movement terminates for delivery to the recipient.
(b) Delivery on the direction of a third person: where the supplier delivers goods to a recipient or another person on the direction of a third person, before or during movement of the goods, the law deems the third person to have received the goods. The place of supply is the principal place of business of that third person.
(c) Supply not involving movement: where the supply does not involve movement of goods by the supplier or recipient, the place of supply is the location of the goods at the time of delivery to the recipient.
(ca) Supply to a person other than a registered person: notwithstanding anything contrary in clauses (a) and (c), the place of supply is the location according to the address of that person recorded in the invoice. If the person's address is not recorded in the invoice, the place of supply is the location of the supplier. For this clause, recording the name of the person's State in the invoice is deemed to be recording the person's address.
(d) Goods assembled or installed at site: the place of supply is the place where the goods are installed or assembled.
(e) Goods supplied on board a conveyance: where goods are supplied on board a vessel, aircraft, train, motor vehicle or other covered conveyance, the place of supply is the location at which those goods are taken on board.

Section 10(2): Where the place of supply of goods cannot be determined under Section 10, it is to be determined in the manner prescribed.

The text above is a reader-friendly restatement. For legal use, refer to the current statutory text published by India Code and official GST sources.

Section 10 at a glance

Situation Relevant clause Place of supply
Goods move for delivery Section 10(1)(a) Location where movement terminates for delivery to the recipient
Goods delivered on direction of a third person Section 10(1)(b) Principal place of business of the third person
No movement of goods Section 10(1)(c) Location of goods at the time of delivery
Goods supplied to an unregistered person Section 10(1)(ca) Invoice address of that person; supplier's location if the address is not recorded
Goods assembled or installed at site Section 10(1)(d) Place of installation or assembly
Goods supplied on board a conveyance Section 10(1)(e) Location where the goods are taken on board

Supply of goods to an unregistered person - Section 10(1)(ca)

Clause (ca) was inserted into Section 10(1) with effect from 1 October 2023. It is specifically framed to override anything contrary in clauses (a) and (c). Therefore, when goods are supplied to a person who is not registered under GST, the invoice address rule in clause (ca) must be considered before applying the ordinary movement or no-movement rules in those clauses.

If the address of the unregistered person is recorded in the invoice, that location is the place of supply. The statutory explanation provides that recording only the name of the State of that person is sufficient to be treated as recording the address for this purpose. If no such address is recorded, the supplier's location becomes the place of supply.

Delivery address and billing address: CBIC has clarified the application of clause (ca) where goods are supplied to an unregistered person and the delivery address differs from the billing address. In such cases, the delivery address recorded on the invoice is relevant for determining the place of supply in accordance with the clarification. Businesses handling B2C and e-commerce orders should therefore capture the correct delivery details on the invoice.

Bill-to ship-to transactions under Section 10(1)(b)

Section 10(1)(b) covers the commonly described "bill-to ship-to" situation. A third person places an order and directs the supplier to deliver the goods to another recipient or person. The provision deems the third person to have received the goods, and the place of supply for the transaction covered by the clause is the principal place of business of that third person.

This rule can apply whether the third person acts as an agent or otherwise and whether the direction is given before or during movement of the goods. The statutory language also covers delivery through transfer of documents of title or otherwise.

Goods assembled or installed at site

Under Section 10(1)(d), the place where the goods are assembled or installed determines the place of supply. This rule is relevant to supplies such as machinery, equipment or systems that are installed or assembled at the customer's site. The place of installation or assembly, rather than merely the supplier's location or dispatch point, controls the place-of-supply determination under this clause.

Goods supplied on board a conveyance

Section 10(1)(e) applies when goods are supplied on board a conveyance such as a vessel, aircraft, train or motor vehicle. The place of supply is the location at which the goods are taken on board. This rule focuses on the loading location of the goods covered by the supply.

Why the place of supply matters for IGST, CGST and State GST

The place of supply must be read with the location of the supplier and the rules in Section 7 and Section 8. Broadly, where the supplier's location and the place of supply are in different States or Union territories, the supply is generally treated as inter-State and IGST applies. Where they are in the same State or Union territory, the supply is generally intra-State and CGST together with the applicable State GST or Union Territory GST applies, subject to statutory exceptions.

For an inter-State tax invoice, the CGST Rules require the place of supply along with the name of the State to be stated on the invoice. Correct determination of the place of supply therefore affects tax classification, invoicing and return reporting.

Section 10 and imported or exported goods

Section 10 does not determine the place of supply for goods imported into India or exported from India. Those transactions are governed by Section 11 of the IGST Act. Under Section 11, the place of supply of imported goods is the location of the importer, while the place of supply of exported goods is a location outside India.

Official legal and GST references

For the latest statutory text, notifications, circulars and compliance material, use the following official sources:

Practical check: Before issuing an invoice, identify the exact transaction pattern, determine the place of supply under the applicable clause of Section 10, compare it with the supplier's location, and then determine whether the supply is inter-State or intra-State. Special statutory rules and exceptions should be checked for the particular transaction.

This article is intended as a general guide to the statutory provision. The facts of a transaction, amendments, notifications, rules and binding judicial or advance-ruling decisions may affect the result.