Section 10(1)(ca): Supplies of Goods to Unregistered Persons

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.

A clause inserted in 2023 that changed the determination for every business-to-consumer supply of goods — and made a single field on the invoice decisive.

Section 10(1)(ca) of the IGST Act, inserted by the IGST (Amendment) Act, 2023, notified through Notification No. 2/2023-IT dated 29.09.2023, w.e.f. 01.10.2023: "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." The Explanation: "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."

What changed

Before 01.10.2023, a B2C supply of goods was determined under clause (a) — where the movement terminated for delivery — or clause (c) where there was no movement.

From 01.10.2023, clause (ca) overrides both for supplies to an unregistered person, and the determination runs on the address recorded in the invoice.

The Explanation: the State name is enough

"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."

This is the practical heart of the clause. A full postal address is not required. Capturing the State is enough to fix the place of supply at the customer's location.

Two consequences.

For an e-commerce or retail seller, capturing the State at checkout — a single dropdown — is sufficient, and it produces the correct inter-State determination. The cost of compliance is one field.

Where no State is captured, the place of supply defaults to the location of the supplier, which makes the supply intra-State and produces CGST and SGST. That is not a penalty, but it is a determination the department can test — and where the department's data (an e-way bill, a shipping record) shows the goods went to another State, the question is why the address was not recorded.

Rule 46(f) requires the address of the recipient and the address of delivery, along with the State and its code, where a supply is made to an unregistered person and the value exceeds fifty thousand rupees. So above that threshold the address is required by the invoicing rules independently of clause (ca). Rule 46 →

Why the clause was inserted

Under the earlier position, the place of supply for B2C goods followed the physical movement. That produced two difficulties.

Revenue attribution. GST is a destination-based tax, and revenue on a B2C supply should accrue to the State of consumption. Where a customer bought goods and had them delivered to a temporary address — a hotel, a relative's home, a workplace in another State — the movement-based rule attributed the revenue to that State rather than to the customer's own.

Compliance practicality. A seller shipping to thousands of consumers had to determine the place of supply from the delivery address on each consignment. The invoice-address rule makes it a master-data question rather than a per-consignment one.

The result is a simpler rule with a clear default: capture the State, or the supplier's own location applies.

What it does not change

B2B supplies. Clause (ca) applies only to a supply "made to a person other than a registered person". A supply to a registered person remains within clauses (a), (b) or (c).

Bill-to ship-to. Clause (ca) overrides clauses (a) and (c) only. Clause (b) — delivery on the direction of a third person — is not displaced. Section 10(1)(b) →

Assembly or installation. Clause (d) — goods assembled or installed at site — is not among the overridden clauses either, so the place of installation or assembly continues to govern.

On-board supplies. Clause (e) is likewise untouched.

Import and export. Section 11 governs, not s.10.

Services. Clause (ca) is in s.10, which deals with goods. Services are governed by s.12 and s.13. Section 12(2) →

Implementing it

In the order-capture system:

1. A mandatory State field at checkout or at order entry for every unregistered customer.
2. Validation that the State is a valid State or Union territory code.
3. The tax determination driven off that field for goods supplies to unregistered persons — not off the delivery address.
4. Where the customer supplies a GSTIN, the determination reverts to clauses (a), (b) or (c) — so the system must branch on registration status.

In the invoice:

1. The State name at minimum; the full address and State code where Rule 46(f) requires it — supply to an unregistered person of value exceeding ₹50,000.
2. Place of supply stated, with the State code — required by Rule 46(n) for inter-State supplies.

In the reporting:

1. B2C supplies are reported State-wise in GSTR-1, and the State reported must match the place of supply determined. A mismatch between the B2C State-wise table and the shipping data is a visible difference. Recurring audit findings →

Key takeaways

• Clause (ca), from 01.10.2023, makes the invoice address the place of supply for goods supplied to unregistered persons.
• It overrides clauses (a) and (c) — not clause (b), (d) or (e).
• Recording the State name alone is deemed to record the address.
• Where no address is recorded, the place of supply is the location of the supplier.
• Rule 46(f) independently requires the address for B2C supplies exceeding ₹50,000.
• The determination must branch on registration status, since B2B supplies are unaffected.

Read next

• Section 10(1)(a): Where the Movement Terminates for Delivery
• Section 10(1)(b): Bill-to Ship-to and the Third Person
• Rule 46: Particulars of a Tax Invoice
• Section 12(2): The Default Rule for Services

Disclaimer: Positions stated as on 5 September 2026, based on the IGST Act and the CGST Rules as amended to 31 March 2026 (ICAI Bare Law, 12th edition).