1. Gianender & Associates
GST- Series -05/ Dec 2016
Time of Supply of Goods
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R K Aggarwal Email: gka_ma@yahoo.com gst@gacaindia.com
Mob: +91 9871229082 Tel: 011-287434942, 42412008
Provisions relating to determination of time of supply of goods have been
significantly amended by the revised GST Law. The revised provisions are much
better version of the old GST Law. New concepts of payment of tax under
reverse charge and supply in case of voucher for supply of goods have been
introduced. MGL provides for separate time of supply of goods and services. We
will discuss the revised provisions of time of supply of Goods as follows
Q 1. What is time of supply?
Ans. The time of supply fixes the point when the liability to charge GST
arises. It also indicates when a supply is deemed to have been made. The MGL
provides separate time of supply for goods and services.
Q 2. When does the liability to charge GST arise in respect of supply of
goods?
Ans. Section 12 of the revised MGL provides for time of supply of goods.
The time of supply of goods shall be the earliest of the following namely,
(a) the date of issue of invoice by the supplier or the last date on which he
is required, under section 28, to issue the invoice with respect to the
supply; or
(b) the date on which the supplier receives the payment with respect to
the supply:
PROVIDED that where the supplier of taxable goods receives an amount up
to one thousand rupees in excess of the amount indicated in the tax invoice,
the time of supply to the extent of such excess shall, at the option of the said
supplier, be the date of issue of invoice.
It is also clarified that ‘the date on which the supplier receives the
payment’ shall be the date on which the payment is entered in his books of
accounts or the date on which the payment is credited to his bank account,
whichever is earlier.
2. Gianender & Associates
GST- Series -05/ Dec 2016
Time of Supply of Goods
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R K Aggarwal Email: gka_ma@yahoo.com gst@gacaindia.com
Mob: +91 9871229082 Tel: 011-287434942, 42412008
Q 3. What is time of supply of continuous supply of goods?
Ans. There is no such provision in the revised GST law
Q 4. What is time of supply of goods sent on approval basis?
Ans. The provision specifying time of supply in case of goods sent on
approval basis has been deleted under revised GST law.
Q 5. What is time of supply of goods under reverse charge for supply of
goods?
Ans. A new concept of payment of tax under reverse charge has been
introduced in the revised GST law. According to the revised provisions, the time
of supply of goods under reverse charge shall be earliest of the following:-
a. The date of receipt of goods; or
b. The date on which payment is made; or
c. The date immediately following thirty days from the date of issue of invoice
by the supplier
If it is not possible to determine time of supply on the basis of above
parameters, the time of supply shall be the date of entry in the books of
accounts of the recipient of the supply.
Q 6. What is time of supply in case of voucher?
Ans. A new provision specifying the time of supply in case of voucher has
been introduced. The time of supply of voucher shall be
a. The date of issue of voucher, if the supply is identifiable at that time; or
b. The date of redemption of voucher, in all other cases.
This provision has been incorporated keeping in mind that there is
increasing trend of vouchers given on online purchasing.
Q 6. Where it is not possible to determine the time of supply in terms of
sub-section 2, 3, 5 or 6 of Section 12 or that of Section 13 of MGL, how will
time of supply be determined?
3. Gianender & Associates
GST- Series -05/ Dec 2016
Time of Supply of Goods
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R K Aggarwal Email: gka_ma@yahoo.com gst@gacaindia.com
Mob: +91 9871229082 Tel: 011-287434942, 42412008
Ans. In case it is not possible to determine the time of supply under the above
provisions, the time of supply shall
(a) in a case where a periodical return has to be filed, be the date on
which such return is to be filed, or
(b) in any other case, be the date on which the CGST/SGST is paid.
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