destination of supply

As per Section 12(2) of IGST Act 2017, POS is 

If supply is made to a registered person shall be the location of such person;
(b) made to any person other than a registered person shall be,––
(i) the location of the recipient where the address on record exists; and
(ii) the location of the supplier of services in other cases.

Yes mahesh ji...IGST needs to be charged

Mahesh ji, I think you are asking about section 140(3) of CGST act 2017 ?? am i right ?

it is enabling the assesee who is not registered under the Central excise act and service tax, to avail the unavailed credit of excise duty on the stock which is held on the appointed day...

for example : dealer who is not registered under excise, has stock of A material of Rs. 100000. He has availed only VAT credit on that purchase but not availed the excise duty paid ( for example Rs. 10000 ). Now he can avail that unavailed excise credit on that stock as follows.

If he has the excise invoice for the total stock value then he can take the Rs. 10000 as credit through TRAN-1. 

If he does't has the excise invoice then, If the GST rate on " A " is equal to more than 18% then 60% of CGST payable on that stock sale is given as refund. Otherwise 40% of CGST payable will be given as refund

NO mahesh ji, He can't avial that benefit..because he has not paid any excise duty on that stock..

TRAN-2 has to be filed by a dealer or trader at the end of every month, when stock is sold reporting the details to claim input tax credit. He must meet the following conditions –

1. Such goods were not unconditionally exempt fully from excise/VAT or were not nil rated goods under Excise/VAT.
2. This scheme is operative only for 6 months from the 1st of July 2017 which means that the stock must be cleared by the end of December to claim the credit.
3. You have a document that shows procurement of such goods.
4. The stock of goods on which the credit is being claimed is stored such that it can be easily identified.

So The first condition is not satisfying in your case .. so you are nor eligible for refund under section 140(3) of CGST

Yes mahesh Ji,