'XYZ', a statutory body, deals with the all the advertisement and publicity of the Government. It has issued a release order to 'Buzz Box' TV…

As per section 12(14) of the IGST Act, 2017, the place of supply of advertisement services to the Central Government, a State Government, a statutory body or a local authority meant for the States or Union territories identified in the contract or agreement is taken as being in each of such States or Union territories (where the advertisement is broadcasted/ run /played/disseminated). Therefore, in the given case, the place of supply of advertisement service is in the States of 'A', 'B', 'C', 'D' and 'E'. The value of the supply of such advertisement services specific to each State/Union territory is in proportion to the amount attributable to the services provided by way of dissemination in the respective States/Union territories determined in terms of the contract or agreement entered into in this regard. In the absence of such a contract or agreement between the supplier and recipient of services, the proportionate value of advertisement services attributable to different States/Union territories (where the advertisement is broadcasted/run/played/ disseminated) is computed in accordance with rule 3 of the IGST Rules, 2017. As per rule 3(f) of the IGST Rules, 2017, in the case of advertisement on television channels, the amount attributable to the value of advertisement service disseminated in a State shall be calculated on the basis of the viewership of such channel in such State, which in turn, shall be calculated in the following manner, namely: - (i) the channel viewership figures for that channel for a State or Union territory shall be taken from the figures published in this regard by the Broadcast Audience Research Council; (ii) the figures published for the last week of a given quarter shall be used for calculating viewership for the succeeding quarter; (iii) where such channel viewership figures relate to a region comprising of more than one State or Union territory, the viewership figures for a State or Union territory of that region, shall be calculated by applying the ratio of the populations of that State or Union territory, as determined in the latest Census, to such viewership figures; (iv) the ratio of the viewership figures for each State or Union territory as so calculated, when applied to the amount payable for that service, shall represent the portion of the value attributable to the dissemination in that State or Union territory. Therefore, value of supply attributable to 'A', 'B', 'C', 'D' and 'E', will be computed as under: States Viewership figures of 'Buzz Box' TV channel as provided by the Broadcast Audience Research Council in the last week of June Viewership ratio of 'Buzz Box' TV channel in the States 'A', ('B' + 'C') and ('D' + 'E') Proportionate value of advertisement services for States 'A', ('B' + 'C') and ('D' + 'E') A 50,000 50,000 10,00,000 x 1/4 = 2,50,000 B + C 1,00,000 1,00,000 10,00,000 x 2/4 = 5,00,000 D + E 50,000 50,000 10,00,000 x 1/4 = 2,50,000 50,000 : 1,00,000 : 50,000 = 1:2:1 States Population as per latest census (in crores) Population ratio in the States 'B' & 'C' and 'D' & 'E' Proportionate value of advertisement services in the States 'A', 'B', 'C', 'D' & 'E' A 50 2,50,000 B 180 B:C = 180:20 = 9:1 5,00,000 x 9/10 = 4,50,000 C 20 5,00,000 x 1/10 = 50,000 D 100 D:E = 100:25 = 4:1 2,50,000 × 4/5 = 2,00,000 E 25 2,50,000 x 1/5 = 50,000 Since there are five different places of supply in the given case, 'Buzz Box' channel will have to issue five separate invoices for each of the States namely, 'A', 'B', 'C', 'D' & 'E' indicating the value pertaining to that State. The GST liability of 'Buzz Box' channel will, therefore, be worked out as under: Computation of GST liability of ‘Buzz Box' TV channel States Proportionate value of advertisement services (₹) CGST @ 9% (₹) SGST @ 9% (₹) IGST @ 18% (₹) A 2,50,000 22,500 22,500 B 4,50,000 81,000 C 50,000 9,000 D 2,00,000 36,000 E 50,000 9,000 Only in case of supply of services in State 'A', the location of supplier (State 'A') and the place of supply are in the same State, hence the same is an intra-State supply in terms of section 8(1) of the IGST Act, 2017 and is thus, liable to CGST and SGST. In all the remaining cases of supply of services, the location of the supplier (State 'A') and the places of supply (States 'B', 'C', 'D' & 'E') are in two different States, hence the same are inter-State supplies liable to IGST [Section 7(1)(a) of the IGST Act, 2017 read with section 5(1) of that Act].