Section 10 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
The default rule for goods, and the one that decides most inter-State determinations. It turns on a single phrase.
Section 10(1)(a) of the IGST Act: "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."
The three elements
"Involves movement of goods." The clause applies where the supply involves movement — it does not matter who moves them.
"Whether by the supplier or the recipient or by any other person." So an ex-works sale, where the buyer arranges and pays for transport, is still within clause (a). This is the point most often got wrong: the incoterm allocates cost and risk, not the place of supply.
"The location of the goods at the time at which the movement terminates for delivery to the recipient."
Three things this is not:
- not the place of despatch;
- not the billing address;
- not the recipient's registered office or head office.
It is where the movement ends, for delivery to the recipient.
The recurring situations
Ex-works sales. Goods handed to the buyer's transporter at the supplier's gate in Maharashtra, moved to the buyer's plant in Gujarat. The movement terminates in Gujarat, so the place of supply is Gujarat and the supply is inter-State. The fact that title and risk passed at the gate does not change it.
Delivery to a site rather than the office. A buyer registered in Karnataka takes delivery at a project site in Tamil Nadu. The movement terminates in Tamil Nadu.
Delivery to the buyer's warehouse in a third State. Same analysis — the State where the movement ends.
Goods collected by the buyer at the supplier's premises, with no onward movement. Where the supply does not involve movement, clause (a) does not apply and clause (c) does: the place of supply is the location of the goods at the time of delivery to the recipient.
The invoice must follow the analysis. Where the place of supply is a different State from the supplier's location, the supply is inter-State under s.7 of the IGST Act and IGST is charged. Charging CGST and SGST instead produces a wrong-head payment, correctable under s.77 of the CGST Act and s.19 of the IGST Act — but with the practical difficulty that the recipient's credit is affected in the meantime. Section 77 wrong head →
The interaction with clause (ca)
Clause (ca), inserted by the IGST (Amendment) Act, 2023, notified through Notification No. 2/2023-IT dated 29.09.2023, w.e.f. 01.10.2023, overrides clauses (a) and (c) for supplies to an unregistered person:
"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, and the location of the supplier where the address is not recorded in the invoice."
The Explanation: recording the name of the State of that person in the invoice shall be deemed to be the recording of the address.
So for B2C supplies of goods, the address on the invoice governs — not where the movement terminates. And recording just the State name is enough to engage it. Section 10(1)(ca) →
Where clause (a) is displaced
| Situation | Clause | Place of supply |
|---|---|---|
| Delivery on the direction of a third person | 10(1)(b) | Principal place of business of that third person |
| Supply not involving movement | 10(1)(c) | Location of the goods at delivery |
| Supply to an unregistered person | 10(1)(ca) | Address recorded in the invoice; else supplier's location |
| Goods assembled or installed at site | 10(1)(d) | Place of installation or assembly |
| Goods supplied on board a conveyance | 10(1)(e) | Where the goods are taken on board |
| Import | s.11(a) | Location of the importer |
| Export | s.11(b) | Location outside India |
| Cannot be determined | 10(2) | As may be prescribed |
Building the determination into the process
The place of supply is decided at invoicing, and it cannot sensibly be reconstructed later. Three controls:
Capture the delivery State, separately from the billing State. Most ERP masters hold a single address. Where the ship-to and bill-to differ, both must be recorded, and the tax determination must run off the ship-to for clause (a) — subject to clause (b) where a third person directs delivery. Section 10(1)(b) →
Test the incoterm separately. Ex-works, FOR destination, delivered-at-place — none of them changes the clause (a) analysis. The question is only where the movement terminates for delivery to the recipient.
Reconcile the e-way bill to the invoice by State. The e-way bill records the actual movement, so a difference between the e-way bill destination State and the place of supply on the invoice is a determination error visible in the data — and it is exactly the difference an audit will find. Recurring audit findings →
Key takeaways
- Clause (a) applies wherever the supply involves movement, whoever arranges it.
- The test is where the movement terminates for delivery to the recipient — not despatch, not billing.
- Ex-works does not change the analysis; the incoterm allocates cost and risk, not place of supply.
- Clause (ca), from 01.10.2023, overrides clauses (a) and (c) for unregistered recipients.
- Recording the State name on the invoice is deemed to record the address for clause (ca).
- Reconcile the e-way bill destination to the place of supply on the invoice.
Read next
- Section 10(1)(b): Bill-to Ship-to and the Third Person
- Section 10(1)(ca): Supplies to Unregistered Persons
- Section 77: Refund of Tax Paid Under the Wrong Head
- Place of Supply of Goods Within India — Section 10 IGST
Disclaimer: Positions stated as on 5 September 2026, based on the IGST Act as amended to 31 March 2026 (ICAI Bare Law, 12th edition).