Distinct person & regular person POS

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This discussion clarifies the Place of Supply (POS) for transportation services under GST, differentiating between distinct persons and regular customers. For regular customers, the POS is generally their location, not necessarily where the invoice is billed. For distinct persons (like branches of the same company), the POS is the location of that distinct entity. If a single vehicle carries goods for both types of recipients, the POS will be split accordingly, meaning Gujarat is often not the correct POS for all scenarios.

Rajkumar Gutti

Rajkumar Gutti (Querist)
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19 November 2025 Goods transported to other than distinct person means general regular customer in one vehicle

Goods transported to only distinct person in one vehicle

Goods transported to genera regular customer & also distinct person in one vehice.

Transporter is in Maharashtra
Person who despatched goods in Gujrat
Ony Distinct persons goods delivered address is in orisa, M. P. Punjab, Hariyana, Rajasthan.

Regular customer ( other than distinct person ) goods delivered address accross India

Regular customer & distinct person goods delivered address accross India

Goods transporter ( Maharashtra) raised his invoice in the name of Gujrat unit ( Goods despatch party )
So in above 3 situation place of supply of service is in Gujrat is it ok or wrong , or distinct person supply POS is different.
Pl. Guide.

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)
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20 November 2025 Place of supply (POS) for transportation services in your scenarios is not always Gujarat. It depends on whether the recipient is a distinct person or a regular customer.

Under Section 12(8) of the IGST Act (for domestic transactions):
- POS = Location of the recipient of service, if the recipient is a registered person.
- POS = Location where goods are handed over for transportation, if the recipient is unregistered.

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)
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20 November 2025 1. Goods transported to regular customer (not distinct person)
- Recipient: Regular customer (not a branch of the Gujarat unit).
- Invoice raised to Gujarat unit: Gujarat is not the recipient.
- POS: Location of the actual recipient (i.e., wherever the regular customer is located across India).
- Conclusion: POS is not Gujarat. It should be the location of the regular customer.

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)
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20 November 2025 2. Goods transported only to distinct persons (branches of Gujarat unit)
- Recipient: Distinct persons (Orissa, MP, Punjab, Haryana, Rajasthan units of Gujarat entity).
- Invoice raised to Gujarat unit: Acceptable, as distinct persons are part of the same legal entity.
- POS: Location of the recipient, i.e., the respective state of the distinct person.
- Conclusion: POS is the state of each distinct person, not Gujarat.

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)
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20 November 2025 3. Goods transported to both regular customers and distinct persons in one vehicle
- Mixed recipients: Some are distinct persons, some are regular customers.
- Invoice raised to Gujarat unit: Not valid for regular customers.
- POS:
- For distinct persons → their respective states.
- For regular customers → their own locations.
- Conclusion: POS is split. Gujarat is not the correct POS for all.

Rajkumar Gutti

Rajkumar Gutti (Querist)
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20 November 2025 Thanks sir,
There is a one query - is only billing address is treated as service recipient or actual goods delivered destination by transportation address is treated as service recipient. There is our confusion.

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)
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20 November 2025 Goods recipient if registered under GST...

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