Section 10 fixes the place of supply of goods bought and sold within India. With the supplier's location, it decides — through sections 7 and 8 — whether a sale is inter-State (IGST) or intra-State (CGST and SGST).
Key points
- Under section 10(1)(a) of the IGST Act, 2017, where a supply of goods involves movement, the place of supply is where the movement terminates for delivery to the recipient.
- In a bill-to-ship-to supply, the third person on whose direction goods are delivered is deemed to have received them, and the place of supply is that person's principal place of business (section 10(1)(b)).
- From 01.10.2023, for a supply of goods to an unregistered person, the place of supply is the address recorded in the invoice; recording the State's name is enough (section 10(1)(ca)).
- Goods assembled or installed at site have their place of supply at the site; goods supplied on board a conveyance, where they are taken on board.
The provisions
10(1)Place of supply of goods
Statutory text
(1) The place of supply of goods, other than supply of goods imported into, or exported from India, shall be as under,-
(a) where the supply involves movement of goods, whether by the supplier or the recipient or by any other person, the place of supply of such goods shall be the location of the goods at the time at which the movement of goods terminates for delivery to the recipient;
(b) where the goods are delivered by the supplier to a recipient or any other person on the direction of a third person, whether acting as an agent or otherwise, before or during movement of goods, either by way of transfer of documents of title to the goods or otherwise, it shall be deemed that the said third person has received the goods and the place of supply of such goods shall be the principal place of business of such person;
(c) where the supply does not involve movement of goods, whether by the supplier or the recipient, the place of supply shall be the location of such goods at the time of the delivery to the recipient;
1[(ca) where the supply of goods is made to a person other than a registered person, the place of supply shall, notwithstanding anything contrary contained in clause (a) or clause (c), be the location as per the address of the said person recorded in the invoice issued in respect of the said supply and the location of the supplier where the address of the said person is not recorded in the invoice.
Explanation.—For the purposes of this clause, recording of the name of the State of the said person in the invoice shall be deemed to be the recording of the address of the said person;]
(d) where the goods are assembled or installed at site, the place of supply shall be the place of such installation or assembly;
(e) where the goods are supplied on board a conveyance, including a vessel, an aircraft, a train or a motor vehicle, the place of supply shall be the location at which such goods are taken on board.
1. Inserted by s. 4 of the Integrated Goods and Services Tax (Amendment) Act, 2023 (No. 31 of 2023) - Brought into force w.e.f. yet to be notified.
CBIC note 1 says clause (ca) is "yet to be notified". It is in force: the IGST (Amendment) Act, 2023, which inserted it, was brought into force from 01.10.2023 by Notification 02/2023-Integrated Tax dated 29.09.2023.
10(2)Where the place of supply cannot be determined
Statutory text
(2) Where the place of supply of goods cannot be determined, the place of supply shall be determined in such manner as may be prescribed.
What it means
A residual power to prescribe the place of supply by rules when sub-section (1) does not yield an answer. Imports and exports of goods are dealt with separately in section 11.
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
- What is the place of supply of goods within India?
- Under section 10 of the IGST Act, where the movement of goods ends for delivery to the recipient; for bill-to-ship-to supplies, the principal place of business of the person on whose direction the goods are delivered.
- What is the place of supply for goods sold online to an unregistered buyer in another State?
- From 01.10.2023, the address of the buyer recorded in the invoice (section 10(1)(ca)); recording the name of the buyer's State is sufficient.
- How is a bill-to-ship-to transaction taxed?
- The person who directs delivery is deemed to have received the goods; the place of supply of the first sale is that person's principal place of business (section 10(1)(b)).
Commentary and case notes checked against the judgments and CBIC sources on 04.10.2026.
What it means