Determine the place of supply in the following independent cases: (i) Mr. Ramesh, residing in Kolkata (West Bengal), has a postpaid mobile…
CA Intermediate · Taxation · MTP · January 2026
Determine the place of supply in the following independent cases: (i) Mr. Ramesh, residing in Kolkata (West Bengal), has a postpaid mobile connection from XYZ Telecom Ltd. (registered office in Mumbai, Maharashtra). The billing address of Mr. Ramesh on the records of XYZ Telecom Ltd. is Kolkata, West Bengal. (ii) Mr. Premanand subscribed a prepaid internet connection from M/s PQR Distributors, a registered distributor of recharge vouchers of XYZ Telecom Ltd., is located in Bengaluru, Karnataka. It sells prepaid recharge vouchers to final subscribers in Chennai, Tamil Nadu. (iii) Buland Machine Ltd., registered in the State of Andhra Pradesh, supplied a machinery to Reyan Wind Farms Ltd., registered in the State of Karnataka. However, this machinery was assembled and installed at the wind mill of Reyan Wind Farms Ltd., which was located in the State of Tamilnadu.
Suggested Answer and Working Notes:
(i) In case of postpaid mobile connections, the place of supply shall be the billing address of the recipient of services as per the records of the supplier. Since the billing address of Mr. Ramesh on the records of XYZ Telecom Ltd. is Kolkata (West Bengal), the place of supply will be West Bengal. (ii) In case of prepaid mobile connections supplied through a distributor, the place of supply shall be the address of the distributor as per the records of the supplier of services. Here, PQR Distributors is located in Bengaluru (Karnataka) as per the supplier's records. Accordingly, the place of supply will be Karnataka, even though the vouchers are sold in Tamil Nadu. (iii) Section 10 (1) (d) of the IGST Act, 2017 provides that if the supply involves goods which are to be installed or assembled at site, the place of supply is the place of such installation or assembly. Thus, the place of supply is the site of assembly of machine, i.e. Tamilnadu.
Topics: Paper 3A: Income Tax Laws, Paper 3B: Goods and Services Tax
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