When a rate changes — as it did across most goods on 22.09.2025 — section 14 decides whether a transaction straddling the change bears the old or the new rate. It overrides sections 12 and 13 and works on three events: the supply, the invoice and the payment.
Key points
- Section 14 of the CGST Act, 2017 overrides sections 12 and 13 to fix the time of supply where the rate changes.
- Where any two of the three events — supply, invoice and payment — fall after the change, the new rate applies; where two fall before, the old rate applies.
- For this purpose, a payment credited to the bank more than four working days after the change is taken at the date of the bank credit.
The provisions
14Change in rate of tax
Statutory text
Notwithstanding anything contained in section 12 or section 13, the time of supply, where there is a change in the rate of tax in respect of goods or services or both, shall be determined in the following manner, namely:-
(a) in case the goods or services or both have been supplied before the change in rate of tax,-
(i) where the invoice for the same has been issued and the payment is also received after the change in rate of tax, the time of supply shall be the date of receipt of payment or the date of issue of invoice, whichever is earlier; or
(ii) where the invoice has been issued prior to the change in rate of tax but payment is received after the change in rate of tax, the time of supply shall be the date of issue of invoice; or
(iii) where the payment has been received before the change in rate of tax, but the invoice for the same is issued after the change in rate of tax, the time of supply shall be the date of receipt of payment;
(b) in case the goods or services or both have been supplied after the change in rate of tax,-
(i) where the payment is received after the change in rate of tax but the invoice has been issued prior to the change in rate of tax, the time of supply shall be the date of receipt of payment; or
(ii) where the invoice has been issued and payment is received before the change in rate of tax, the time of supply shall be the date of receipt of payment or date of issue of invoice, whichever is earlier; or
(iii) where the invoice has been issued after the change in rate of tax but the payment is received before the change in rate of tax, the time of supply shall be the date of issue of invoice:
Provided that the date of receipt of payment shall be the date of credit in the bank account if such credit in the bank account is after four working days from the date of change in the rate of tax.
Explanation.-For the purposes of this section, "the date of receipt of payment" shall be the date on which the payment is entered in the books of account of the supplier or the date on which the payment is credited to his bank account, whichever is earlier.
*Enforced w.e.f. 1st July, 2017.
Statutory text as published on the CBIC tax information portal, as on 03.10.2026; the numbered notes record each amendment. Official source
Common questions
- Which GST rate applies when the rate changes between invoice and payment?
- Under section 14 of the CGST Act it depends on when the supply was made: in general, the rate on the side of the change on which two of the three events — supply, invoice, payment — fall.
Commentary and case notes checked against the judgments and CBIC sources on 04.10.2026.
What it means
The six combinations in clauses (a) and (b) reduce to a "two out of three" rule: