Section 11 is the place-of-supply rule for goods crossing India's border. It is short because the heavy lifting is done elsewhere: imports are inter-State by section 7(2) and taxed at customs under the proviso to section 5(1); exports are zero-rated under section 16.
Key points
- Under section 11(a) of the IGST Act, 2017, the place of supply of goods imported into India is the location of the importer.
- Under section 11(b), the place of supply of goods exported from India is the location outside India.
The provisions
11Imports and exports of goods
Statutory text
The place of supply of goods,-
(a) imported into India shall be the location of the importer;
(b) exported from India shall be the location outside India.
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 imported goods?
- The location of the importer (section 11(a) of the IGST Act).
- What is the place of supply of exported goods?
- The location outside India (section 11(b)); the supply is zero-rated under section 16.
Commentary and case notes checked against the judgments and CBIC sources on 04.10.2026.
What it means
(a) Imports. The location of the importer. The tax itself is collected at customs under the proviso to section 5(1), and the import is inter-State by section 7(2), so section 11 does not change who pays or how; it fixes the State to which the import is attributed.
(b) Exports. The location outside India. With the supplier in India, the supply is inter-State under section 7(5)(a) and zero-rated under section 16.
Sales of goods while they are still on the high seas, or from a customs warehouse before clearance, are outside GST altogether under paragraph 8 of Schedule III to the CGST Act, so section 11 is not needed for them.