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Query on POS in GST

Alka Sahani (Student) (59 Points)

25 June 2025

Let's say if the supplier and buyer are both registered in UP and the buyer wants goods to be delivered in MP.

Should supplier treat it as interstate transaction or intra state transaction or their implementation on e-invoice and e-way bill?

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Manish Nair (Articled Assistant) (16 Points)
Replied 26 June 2025

This is a typical "Bill to – Ship to" transaction covered under Section 10(1)(b) of the IGST Act, 2017, which deals with situations where the supplier delivers goods to the recipient on the instruction of a third person.

In this case:

The seller (supplier) is located in Uttar Pradesh (UP).

The buyer (third person) is also located in UP, and

The goods are being shipped to Madhya Pradesh (MP) on the instructions of the buyer.

As per Section 10(1)(b):

When goods are delivered by the supplier to a recipient on the direction of a third party (buyer), the place of supply is deemed to be the location of the third party (buyer).

Therefore:

Place of Supply = Uttar Pradesh (location of the buyer)

Location of Supplier = Uttar Pradesh

Since both the location of the supplier and the place of supply are in the same state (UP), this transaction qualifies as an intra-state supply.

Tax implication:

➡️ CGST and SGST will be applicable on this supply (not IGST), even though the goods are physically shipped to MP.

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