When people first hear about GST’s “place of supply,” they think it’s just about whether a sale is inside the state or across states. And for many cases, that’s true — goods move, tax follows. But GST isn’t always that clean. Real life throws up odd situations that don’t fit the regular mold, and for those, the law quietly added extra rules.
The funny part? These “special cases” actually show up a lot more than you’d expect — hotels, concerts, bus tickets, SIM cards, even your bank account. Miss the fine print, and suddenly your invoice is wrong and the tax department isn’t amused.
Let’s walk through them, with stories instead of legal jargon.
Property-Based Services
This one’s easy to remember: if it’s tied to a piece of land or a building, GST doesn’t care where you or your customer are located. The tax sticks to where the property is.
I remember a Delhi architect who designed a luxury hotel in Goa for a Mumbai client. The client’s address said Mumbai, the architect sat in Delhi, but the property was in Goa. So Goa was the place of supply, not Delhi or Mumbai. The rule is simple: follow the property.
Services That Must Be Performed in Person
Think about services like haircuts, gyms, or car repairs. You can’t “ship” these — they happen where you physically are. GST says the place of supply is wherever the work is actually done.
So if a Rajasthan guy drives his car to Gujarat for servicing, the garage doesn’t bother about his home address. GST doesn’t either. The spanner turned in Gujarat, so Gujarat gets the tax.
Training, Workshops, and Events
This one has a little twist. If the client is a registered business, GST ties it back to their registered location. But if it’s for the general public, the place of supply is wherever the event physically takes place.
A Bangalore company sends its staff to a training program in Delhi? Even though the event is in Delhi, the place of supply is Bangalore, because that’s where the company is registered.
But a rock concert in Hyderabad with tickets sold to anyone? Hyderabad gets the tax — it’s about the venue, not the audience’s addresses.
Moving Goods Around
For transporting goods, GST splits it again:
- If the recipient is registered → place of supply = their location.
- If they’re not registered → it’s wherever the goods were handed over to the transporter.
So if a logistics company in Kolkata moves goods for a registered firm in Patna, GST points to Patna. But if they move goods for an unregistered customer who dropped them off in Kolkata, then Kolkata gets the tag.
Passenger Transport
Thankfully, this one’s simpler. The place of supply is always where the trip begins.
A bus from Delhi to Agra? Place of supply = Delhi. Even if the passenger only travels half the route, the journey started in Delhi, so Delhi’s tax applies. Same with flights — the starting airport decides it.
Services on Board
Here’s a quirky one: when you buy something on a plane, train, or bus, the place of supply is tied to where that vehicle began its journey.
So if you’re on a Mumbai–Pune flight and buy a sandwich mid-air, GST says the supply happened in Mumbai, because that’s where the plane took off.
Telecom, Internet, and Data
This one catches a lot of people. For telecom:
- Fixed lines → where the line is installed.
- Postpaid mobile → customer’s billing address.
- Prepaid → wherever you bought the recharge, or your location if it was online.
So if you bought a prepaid SIM in Delhi, GST pins it to Delhi. Even if you travel to Chennai and use the same SIM, the supply still sticks to Delhi.
Banking and Financial Services
Banks keep it simple. The place of supply is wherever your account is registered.
So, if you opened your savings account in Mumbai but are living in Pune, the services still count as Mumbai supply.
Insurance
Insurance services follow the insured person’s address.
Take a Kolkata resident who buys health insurance while working in Delhi. GST still counts it as Kolkata, because that’s the address on the policy.
Government Services
And yes, even government services can fall under GST if they’re taxable — like renting out property. In those cases, the place of supply is usually where the service is delivered.
So if a state government rents out an office space in Bengaluru, Karnataka is the place of supply.
Why These Exceptions Matter
These aren’t just tiny technicalities. If you misapply the rule, you could:
- End up paying tax to the wrong state.
- Deny your client input tax credit.
- Face penalties during an audit.
I’ve seen businesses lose months fighting refund claims simply because they tagged the wrong state as place of supply on invoices.
Wrapping It Up
Special cases of place of supply sound like rare “corner cases,” but honestly, they’re part of daily business life. Hotels, concerts, telecom bills, insurance policies — these rules affect ordinary transactions every single day.
A quick mental checklist:
- Property = property’s location.
- Services delivered in person = where performed.
- Events = client’s state if registered, venue if not.
- Passenger transport = where the trip starts.
- Telecom = billing or recharge location.
- Banks/insurance = account or policy address.
- Government = where service is delivered.
In the end, GST’s place of supply rules always circle back to one simple question: where is the benefit really landing? Once you answer that, you usually land in the right state — both literally and tax-wise.
