Transport service POS

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This discussion clarifies the Place of Supply (POS) for transport services under GST when dealing with distinct persons. If goods are transported from Tamil Nadu to Punjab, and the recipient in Punjab is registered, Punjab is the place of supply, making it an inter-state transaction subject to IGST. However, if the transporter bills the original sender in Tamil Nadu, it can be considered an intra-state supply. The consensus is that for distinct units, the place of delivery, not the billing address, determines the POS. Therefore, the invoice should ideally reflect the delivery location to ensure correct Input Tax Credit (ITC) distribution.

14 November 2025 A- in Tamilnadu, B- in Punjab, both are distinct person.
Named Express transporter is in Tamilnadu.
If A transport his goods to B , using Express transporter services.

Which place of supply of transport of service.

16 November 2025 Provision: Section 12(8) of IGST Act
“The place of supply of services by way of transportation of goods, including by mail or courier, to a registered person shall be the location of such person.”

- If B is a registered person under GST, then:
- Place of supply = Punjab (location of recipient)
- Since supplier is in Tamil Nadu and place of supply is Punjab → Inter-State supply → IGST applicable

16 November 2025 - If B had been an unregistered person, then:
- Place of supply = Location where goods are handed over for transportation (i.e., Tamil Nadu)
- Supplier and place of supply both in Tamil Nadu → Intra-State supply → CGST + SGST applicable

17 November 2025 But sir if transporter raise his bill in the name of A in Tamilnadu. In this situation is POS is Tamilnadu is it Ok or wromg.

17 November 2025 Correct - If the transporter is billing to A in Tamil Nadu, it’s an intra-state supply.

17 November 2025 But sir is it necessary in distinct person transaction, transporter bill should raise to whom goods actual delivered. Other wise ITC should transfer to punjab unit via isd ( Bcoz ITC is attributable to Punjab unit.
In distinct unit transaction,Billing unit location is place place of supply or to whom actual goods delivered by transporter, is place of supply. Here we puzzling.

17 November 2025 In a distinct person transaction under GST, the place of supply is determined based on the location of delivery, not the billing unit. Therefore, the transporter’s invoice should ideally be addressed to the Punjab unit (B) if the goods are delivered there.
Otherwise, ITC must be distributed via the ISD mechanism.

17 November 2025 - For services (like transportation):
- If supplier and recipient are in different states, place of supply = location of recipient (Section 12(8), IGST Act).
- If transporter invoices A (Tamil Nadu), but goods are delivered to B (Punjab), Punjab is the actual recipient.

17 November 2025 Ok sir, now I understand in distinct person transaction place of delivery, is the place of supply, not billing address. It means billing address must be actual delivered goods distinct unit.
Sir, lot of thanks for taking efforts for me.

17 November 2025 You are welcome..

18 November 2025 In distinct unit transaction instead of billing made for transport service to whom actual goods delivered, but billing made by transporter to distinct unit who despatch goods. This billing is right. This billing method is legaly identified place of supply of service.


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