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Sections 12(4) and 12(5): Performance-Based and Training Services

One rule looks only at where the service is performed; the other splits on whether the recipient is registered. Two adjacent sub-sections, two different tests.

Vikas Sharma Tax & Compliance Expert
6 min read 7 views Updated Sep 17, 2026 Expert Reviewed Medium Complexity
Sections 12(4) and 12(5): Performance-Based and Training Services
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Last updated: September 2026Applies to: FY 2026-27Verified against: Government sources
Quick Answer

One rule looks only at where the service is performed; the other splits on whether the recipient is registered. Two adjacent sub-sections, two different tests.

Two sub-sections side by side, covering services that are physically delivered to a person — and applying different tests to them.

Section 12(4): performance, and only performance

The services listed:

  • restaurant and catering services;
  • personal grooming;
  • fitness;
  • beauty treatment;
  • health service including cosmetic and plastic surgery.

The common feature: each is delivered to a person physically present, and each is consumed where it is delivered.

The test: "the location where the services are actually performed." There is no split by registration status — unlike almost every other sub-section in s.12.

What follows.

A corporate customer gets no choice. A company registered in Delhi holding an event catered in Mumbai receives a supply with its place of supply in Maharashtra. The caterer charges CGST and SGST of Maharashtra, and the Delhi registration cannot use that credit — it sits in a State where the company is not registered.

Hotel restaurant billing. A meal in a hotel restaurant is a s.12(4) supply performed at the restaurant. The accommodation in the same hotel is a s.12(3)(b) supply at the hotel's location. Both land in the same State here, but the analysis is different — and it diverges where catering is supplied away from the hotel.

Health services. The clause names health service including cosmetic and plastic surgery. Many health services are exempt, so the place of supply question often does not arise on tax — but it does arise for reporting and for determining whether a supply is inter-State for the purposes of registration and returns.

Section 12(5): training, with a registration split

"Training and performance appraisal."

To a registered person: the location of that person.

To an unregistered person: the location where the services are actually performed.

Why the split matters.

For B2B training, the place of supply follows the customer's registration — so a trainer in Karnataka conducting a programme physically held in Maharashtra, for a customer registered in Karnataka, has a place of supply in Karnataka. The venue is irrelevant.

That is the opposite of s.12(4), where the venue decides everything.

And it makes B2B training credit usable. The customer takes the credit against the registration that engaged the trainer, wherever the session was held — which is why corporate training is one of the few venue-based services whose credit does not strand.

For B2C training — an individual attending a course — the place of supply is where it is performed.

Online training: which sub-section?

The recurring question, and it is not answered in terms by either sub-section.

Two possibilities.

If it is "training and performance appraisal" within s.12(5), the B2B answer is the customer's location — and for online delivery, that is a workable and stable answer.

If it is an OIDAR service, the position differs. Section 2(17) of the IGST Act defines online information and database access or retrieval services as services mediated by information technology over the internet or an electronic network, the nature of which renders their supply impossible in the absence of information technology, and it includes a list of electronic services. Whether a live, instructor-led online session meets the "impossible without information technology" test — as against a pre-recorded, automated course — is the dividing question.

Why it matters: for a domestic online course the difference is modest, since s.12(5)(a) and the OIDAR analysis both tend towards the recipient. For a cross-border supply the difference is substantial, because s.13(12) places OIDAR at the recipient's location with a deemed-location Explanation based on seven indicators. Section 13(12) OIDAR →

The practical approach: characterise the service on its actual delivery mechanics — automated and content-driven, or instructor-led and interactive — document the reasoning, and apply it consistently. When to seek an advance ruling →

The pattern across sub-sections 12(4) to 12(7)

Four adjacent sub-sections, and it is worth seeing them together because the tests differ:

Sub-sectionServiceRegistered recipientUnregistered recipient
12(4)Restaurant, catering, grooming, fitness, beauty, healthWhere performedWhere performed
12(5)Training and performance appraisalLocation of the personWhere performed
12(6)Admission to an event or parkWhere the event is heldWhere the event is held
12(7)Organisation of an event, sponsorshipLocation of the personWhere the event is held; if abroad, recipient's location

The pattern: where the recipient is physically present and consuming — 12(4) and 12(6) — the venue governs regardless. Where the service is procured by a business — 12(5) and 12(7) — the registered recipient's location governs.

Which produces a practical planning point for corporate events. The venue hire falls under s.12(3)(c), the catering under s.12(4), the organisation under s.12(7), and delegate admission under s.12(6). A single event can generate supplies with place of supply in different States depending on which element is being invoiced — and the credit position differs for each. Section 12(6) and 12(7) →

Key takeaways

  • Section 12(4) applies where the service is performed, with no registration split.
  • So catering, restaurant, grooming, fitness, beauty and health services strand credit for an out-of-State corporate customer.
  • Section 12(5) splits: registered — the person's location; unregisteredwhere performed.
  • B2B training credit therefore does not strand, whatever the venue.
  • Online training requires a characterisation decision against the OIDAR definition in s.2(17).
  • A corporate event generates supplies under 12(3)(c), 12(4), 12(6) and 12(7), with different places of supply.

Read next

Disclaimer: Positions stated as on 5 September 2026, based on the IGST Act as amended to 31 March 2026 (ICAI Bare Law, 12th edition). The characterisation of online education services depends on the facts of the particular offering.

Key Facts About Sections 12

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

What is the place of supply for catering?

The location where the services are actually performed, under section 12(4) — regardless of whether the recipient is registered.

Can a company registered elsewhere use the credit on out-of-State catering?

No. The place of supply is where the catering was performed, so the CGST and SGST of that State are not creditable to a registration in another State.

Over 90% of compliance penalties in India arise from missed due dates — timely handling can save businesses thousands of rupees each year.

— TaxClue Compliance Desk

Sections 12: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Frequently Asked Questions
What is the place of supply for catering?
The location where the services are actually performed, under section 12(4) — regardless of whether the recipient is registered.
Can a company registered elsewhere use the credit on out-of-State catering?
No. The place of supply is where the catering was performed, so the CGST and SGST of that State are not creditable to a registration in another State.
What is the place of supply for corporate training?
The location of the registered recipient, under section 12(5)(a) — the venue is irrelevant.
And for training supplied to an individual?
Where the services are actually performed, under section 12(5)(b).
How is online training treated?
It depends on whether it is training and performance appraisal within section 12(5) or an OIDAR service under section 2(17), which turns on whether supply is impossible without information technology.
Why do event supplies land in different States?
Because venue hire, catering, organisation and admission fall under different sub-sections with different tests.

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Vikas Sharma VERIFIED EXPERT
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Experienced in company registration, GST, trademark, and compliance. Helping Indian businesses stay compliant.
Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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