Tax Part CGST SGST OR IGST

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When supplying goods to Pondicherry for a customer registered in Chennai who lacks a Pondicherry GST registration, you must charge IGST. This is because the 'bill-to, ship-to' transaction, as per Section 10(1)(b) of the IGST Act, 2017, determines the place of supply based on the final delivery location. Circular No. 90/09/2019-GST clarifies that inter-state supplies require IGST and proper invoicing, even if the customer isn't registered in the destination state.

K Kasiraman

K Kasiraman (Querist)

28 October 2025 Dear Sir,

We need to supply the goods to pondicherry the customer having registered office in chennai but they dont have GST Registration in Pondy. And they asked to supply to third party what tax i should incorporate in Taxable sale invoice like CGST + SGST OR IGST . Kindly provide the answer with Notification or Act or Circular.

Example : A is the Customer in chennai B is the third party in Pondy and A is not added the Pondicherry location in GST and they dont have registration in pondy.

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)

28 October 2025 According to Section 10(1)(b) of the IGST Act, 2017, in "bill-to, ship-to" transactions, the place of supply is determined by where the goods are eventually delivered, as per the instructions of the customer. If the goods are shipped directly to Pondicherry, even if the customer is registered in Chennai, IGST applies.

The CBIC and Ministry of Finance clarify in Circular No. 90/09/2019-GST dated 18th February 2019 that for inter-state supplies, the invoice must mention the place of supply and the state, and IGST must be charged. Not mentioning the place of supply could attract penalties under Sections 122 or 125 of the CGST Act.

Supply to a location (Pondicherry) where the customer is not registered still requires treatment as inter-state, with IGST payable, not CGST or SGST.

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)

28 October 2025 Referenced Sections, Notification, Circulars
Section 10(1)(b), Integrated Goods and Services Tax Act, 2017 ("Bill to Ship to" transactions).

Circular No. 90/09/2019-GST, dated 18th February 2019 (compliance for place of supply in invoice).

Rule 46(n) of the Central Goods and Services Tax Rules, 2017 (details of place of supply in invoices).

Place of Supply Examples and Table (IGST applies if location of supplier and supply are in different states).

So, you must charge IGST on the invoice to the Chennai customer for delivery to Pondicherry, as per the cited statutory provisions and official circulars.

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