Explore The Concept Of Place Of Supply Under GST

Explore the concept of Place Of Supply Under GST

A distinguishing factor of GST from the earlier Indirect Tax Regime is that GST is a Destination-based tax. This means that the goods & services will be taxed at the place where they are consumed and not where they originate. This gives the consuming state the right to collect GST.

In this article we are covering the provisions in relation with time of supply along with examples for clear understanding: –

Place of Supply under Previous Tax Regimes

The concept of Place of Supply held importance in the earlier indirect tax regimes as well. Here is a summary on the classification of Place of Supply under previous tax regimes:

  • EXCISE

Under Excise, duty was charged on excisable goods manufactured in India. As supply was never a chargeable event, determining the place of supply was also not crucial. The taxable event was ‘manufacture’ but the liability of Excise Duty was deferred up to the time of removal of goods from the factory.

  • SERVICE TAX

Under Service Tax, a similar concept could be found in Place of Provision of Services Rules, 2012 summarised as follows:

Sr. No. 

Service

Place of Provision

1

General Rule

B2B: Location of the recipient

B2C: Location of a service provider

2

Performance-based services for goods and physical presence of an individual The location where the services are actually performed

3

Immovable property Where immovable property is located or intended to be located

4

Events Where the event is actually held

5

At more than one location The taxable territory where the greatest proportion of the service is provided

6

Provider and receiver are located in the taxable territory Location of the recipient

7

Specified services Location of Service Provider

8

Goods transport services otherwise than by way of mail or courier Place of destination of the goods

9

Goods transport agency Location of the person liable to pay tax

10

Passenger transportation services Place where the passenger embarks on the conveyance for a continuous journey

11

Service provided on board a conveyance during the course of the passenger transport operation First schedule point of departure of that conveyance for the journey
  •  VAT/CST

If the sale was an Intra-state sale, VAT would be charged. On the other hand, if the sale was an Inter-state sale, CST would be charged. Thus, the Place of Supply concepts was not as relevant under VAT/CST since there was no need to distinguish or apportion supply based on states. However, Section 3 of the CST Act specified the scope of Inter-state sales on which CST would be levied as follows:

  1. Movement of goods from one state to another
  2. By transfer of document of title of goods during movement of goods from one state to another
  3. Included branch transfer, consignment transfer, and stock transfer from one state to another.

Relevance Of Place Of Supply Under GST?

  • Place of Supply provisions guides us to determine the nature of supply. If the Location of Supplier and Place of Supply are in the same state, the transaction is an Intra-state transaction, hence CGST & SGST shall be levied on the same. On the other hand, if the Location of Supplier and Place of Supply are in different states, the transaction becomes an Inter-state transaction, and IGST will be levied in this case.
    Hence, there are 2 key terms that determine the nature of any supply:

→ Location of Supplier &
→ Place of Supply

Tax is paid according to the nature of supply and Place of Supply provisions help us determine this nature of supply. To illustrate,

LOCATION OF SUPPLIERPLACE OF SUPPLYNATURE OF SUPPLYGST APPLICABLE
Maharashtra Maharashtra Intra-state CGST + SGST
Maharashtra Gujarat Inter-state IGST
  • If the tax is paid under any wrong head (eg. tax was to be paid as IGST but due to wrong determination the same had been paid in account of CGST and SGST), then there is no such provision in the GST to adjust such mistake with one another suo moto. The only remedy available with the person is to pay the tax under the correct head and get a refund of the tax which had been paid under the wrong head. Therefore, it is utmost necessary for the person to determine the correct nature of supply and pay tax accordingly in the correct head.

Location Of Recipient & Supplier (LOR & LOS)

Let us first understand a few important terms before understanding the Place of Supply Provisions under GST:
Sec 2(14): Location of the Recipient
a Where a supply is received at a place of business for which registration has been obtained Location of such Place of Business
b Where a supply is received at a place other than the place of business for which registration has been obtained (a fixed establishment elsewhere) The location of such a Fixed establishment. Sec 2(7): “Fixed establishment” means a place (other than the registered place of business) which is characterized by a sufficient degree of permanence and suitable structure in terms of human and technical resources to supply services or to receive and use services for its own needs.
c Where a supply is received at more than one establishment, whether the place of business or fixed establishment Location of the establishment most directly concerned with the receipt of the supply
d In the absence of such places The location of the usual place of residence of the recipient.
Sec 2(15): Location of the Supplier
A Where a Supply is made from a place of business for which registration has been obtained Location of such place of Business
B Where a supply is made from a place other than the place of business for which registration has been obtained (a fixed establishment elsewhere) The location of such a Fixed establishment
C Where a supply is made from more than one establishment, whether the place of business or fixed establishment Location of the establishment most directly concerned with the provision of the supply
D In the absence of such places The location of the usual place of residence of the supplier.
As discussed above, the tax to be paid is based on the nature of supply. If the supply is Inter-state, IGST is to be paid; whereas if the supply is Intra-state, CGST & SGST has to be paid. But how do we infer whether a Supply is Inter-state or Intra-state? For that, we need to understand the terms ‘Inter-State Supply’ and ‘Intra-State Supply’ as defined under the IGST Act.

Inter-State Supply

According to Section 7, the following Supplies shall be treated as supply in the course of Inter-state trade or commerce:

1. SUPPLY OF GOODS/ SERVICES:

Subject to the provisions of section 10 (for goods) or section 12 (for services), the supply of goods where the location of the supplier and the place of supply are in –

  • Two different States
  • Two different Union Territories or
  • The State and a Union Territory

2. IMPORT OF GOODS/ SERVICES:

Supply of goods or services imported into the territory of India till they cross the customs frontiers of India.

  • CBIC Clarification & Amendment: (Circular No. 91/10/2019 dated. 18.02.2019)

ISSUE

APPLICABILITY OF GST

BASIS OF PROVISION

CLARIFICATION AMENDMENT

Whether High Sea Sales of Imported Goods would be chargeable to IGST twice

Non-taxable By way of CBIC Clarification

From the date 01/02/2019, non-taxable as per Para 8b of Schedule III

Supply of Warehouse Goods to any person before clearance for home consumption

Non-taxable By way of CBIC Clarification

From the date 01/02/2019, non-taxable as per Para 8a of Schedule III

3. SUPPLY OF GOODS/ SERVICES OUTSIDE INDIA (EXPORTS & SEZ):

Supply of goods/services/both,

  • When the supplier is located in India and the place of supply is outside India
  • To or by a Special Economic Zone developer or a Special Economic Zone Unit (SEZ)
  • In the taxable territory, not being an intra-State supply and not covered elsewhere in this section.

Intra-State Supply

According to Section 8, a Supply is an Intra-State supply if, subject to the provisions of Section 10 (for Supply of Goods) and Section 12 (for Supply of Services), the Location of Supplier & Place of Supply is in –

  • The same State or
  • The same Union Territory

DETERMINATION OF PLACE OF SUPPLY UNDER GST
All these definitions refer to a recurring term called ‘Place of Supply’. We will use the Place of Supply provisions to determine the same. Now let us discuss the criteria and manner for determination of this place of supply.

Place of Supply

Supply In Territorial Waters

Notwithstanding anything contained in this Act,

  • Where the Location of the Supplier is in the territorial waters, the location of such supplier; OR
  • Where the Place of Supply is in the territorial waters,

the place of supply, shall, for the purposes of this Act, be deemed to be in the Coastal State or Union territory where the nearest point of the appropriate baseline is located.

As per Sec 10 (1), (a)Where the supply involves the movement of goods, whether by→  the supplier or→ the recipient or→ any other person location of the goods at the time at which, the movement of goods terminates for delivery to the recipient

Clause

Description of SupplyPlace of Supply

(b)

Where the goods are delivered by the supplier → to a recipient or any other person

→ on the direction of a third person whether acting as an agent or otherwise

→ before or during the movement of goods

→ either by way of transfer of documents of title to the goods or otherwise

(i.e. Deemed Recipient/ Bill to Ship to Transactions)

The principal place of business of such a person.

(It shall be deemed that the said third person has received the goods.)

Place Of Supply Of Goods Other Than Supply Of Goods Imported Into Or Exported From India

Thus, here, there are 2 supplies involved:

1. Supplier to Third Person/ Buyer – Sec 10(1)(b)

2. Third Person/ Buyer to Recipient – Sec 10(1)(a)

(c)

Where the supply does not involve the movement of goods whether by

→ the supplier or

→  the recipient

Location of the goods at the time of delivery to the Recipient

(d)

Where the goods are assembled or installed at SitePlace of such Installation/ Assembly

(e)

Where the goods are supplied on board a conveyance, including a vessel, an aircraft, a train or motor vehicleLocation at which such goods are taken on Board

As per Sec 10(2), where the place of supply of goods cannot be determined, the place of supply shall be determined in such manner as may be prescribed.

As per Section 11: Place of Supply shall be:-

Sr. No.

Description of Supply

Place of Supply

1.

Imported into IndiaLocation of the Importer

2.

Exported from India

Location outside India

As per Section 12, Place of Supply of Services where Location of Supplier and Location of Recipient is in India (except the services specified in sub-section (3) to (14)) is:

DEFAULT RULE (Sec 12(2)):
If Supply of Service to a Registered Person

  • Then Location of such person
  • If Supply of Services to a person other than a Registered Person
  • The Location of Recipient where the address on record exists
  • The Location of Suppliers of services in other cases.

Subsection 3 to 14 are specific cases and the Place of Supply provided in the same are as under:

Sec 12(3): Place of Supply of Immovable Property Services

Location of PropertyDescription of Service SuppliedPlace of Supply
If a property is located in India

→ Directly in relation to an immovable property

→ Including services provided by architects, interior decorators, surveyors, engineers, and other related experts or estate agents

Location at which the immovable property or boat or vessel, as the case may be, is located or intended to be located.
→ Grant of rights to use immovable property or for carrying out or coordination of construction work

→ Lodging accommodation by a hotel, inn, guest house, homestay, club or campsite, by whatever name called

→ Including a houseboat or any other vessel

→ Accommodation in any immovable property for organizing any marriage or reception on matters related thereto, official, social, cultural, religious or business functions

→ Service provided in relation to search function and such property

→ Any services ancillary to the services referred above
If a property is located outside IndiaAny of the aboveLocation of the Recipient

⇒ But what if such Immovable Property is located in more than one State or Union Territory?
Services shall be treated as made in each of the respective State or Union Territory in proportion to:

  • The value for service separately collected or determined in terms of the contract/ agreement entered into in this regard
  • In the absence of such contract/ agreement, on such other basis as may be prescribed in Rule 4 of IGST Rules, 2017 (summarised below):
Description of ServiceBasis of Apportionment & Value of Service

Lodging Accommodation & Ancillary Services

Except: Cases where such property is a single property located in two or more contiguous States or Union Territories or both

→ Each of the respective States or Union Territories

→ In proportion to the number of nights stayed in such property

→  All other services in relation to immovable property

→ Accommodation services in any immovable property for organizing any marriage or reception

→  Accommodation services where such property is a single property located in two or more contiguous States or Union Territories or both

→ Ancillary Services

→ Each of the respective States or Union Territories

→ In proportion to the area of the Immovable Property lying in each State or Union Territory

Lodging Accommodation by houseboat or other vessel and ancillary services

→ Each of the respective States or Union Territories

→ In proportion to the Time Spent by the boat/vessel in each States or Union Territories

→ Which shall be determined on the basis of a declaration made to the effect by the service provider

Sec 12(4): Place of Supply based on Performance
In case of the supply of:

  • Restaurant & catering services
  • Personal grooming
  • Fitness
  • Beauty treatment
  • Health service including cosmetic and plastic surgery,

Place of Supply is the Location where services are actually performed.

Sec 12(5): Place of Supply of Training & Performance Services

Description of Service

Provided toPlace of Supply

In relation to Training & Performance Appraisal

Registered Person

Location of such Person

Other than Registered Person

A location where the services are actually performed

Sec 12(6): Place of Supply for Admission to Events
Supply of Services provided by way of admission to a cultural, artistic, sporting, scientific, educational, entertainment event or amusement park or any other place and services ancillary thereto:
Place of Supply:

  • Where the event is actually held or
  • Where the park or such other place is located

Sec 12(7): Place of Supply for Organizing of Events

Description of Service

Provided to

Place of Supply

→ Organization of cultural, artistic, sporting, scientific, educational or entertainment event

→ Including the supply of services in relation to a conference, fair, exhibition, celebration or similar events

→ Services ancillary to above

→ Assigning of sponsorship of such events

Registered PersonLocation of such Person
Other than Registered Person

→ If event held in India: Place where the event is actually held

→ If event held outside India: Location of Recipient

⇒ But what if such an event is held in more than one State or Union Territory and a Consolidated Amount is charged for such Supply?
Services shall be treated as made in each of the respective State or Union Territory in proportion to:

  •  The value for service separately collected or determined in terms of the contract/ agreement entered into in this regard
  •  In the absence of such a contract/ agreement, on such other basis as may be prescribed in Rule 5 of IGST Rules, 2017 which states that the basis of apportionment shall be determined by the application of the Generally Accepted Accounting Principles (GAAP).

Sec 12(8): Place of Supply for Transportation of Goods

Description of ServiceProvided toPlace of Supply
By way of Transportation of Goods including by mail or courierRegistered PersonLocation of such Person
Other than Registered PersonLocation at which such goods are handed over for their transportation

If goods are to be transported to a place outside India,

Place of Supply will be the place of destination of such goods.

Sec 12(9): Place of Supply for Transportation of Passenger

Description of Service

Provided to

Place of Supply

Passenger Transport Services

Registered Person

Location of such Person

Other than Registered Person

Place where the passenger embarks on the conveyance for a continuous journey

  • It is to be noted that where the right to passage is given for future use (eg. Metro Card, Railway Pass, seasonal tickets, etc.) and the point of embarkation is not known at the time of issue of the right to passage, Place of Supply will be determined using Sec 12(2) i.e. the Default Rule.
  • An Explanation has been inserted to state that, here, Return Journey shall be treated as a separate journey, even if the right to passage for onward and return journey is issued at the same time (eg. Return tickets).

Sec 12(10): Place of Supply of On-Board Services
For the supply of services on board a conveyance, Place of Supply is the location of the first scheduled point of departure of that conveyance for that journey.

Sec 12(11): Place of Supply of Telecommunication Services
The place of supply of telecommunication services including data transfer, broadcasting, cable, and direct to home (DTH) television services to any person:

DescriptionPlace of Supply

→ Fixed telecommunication line

→ Leased circuits

→ Internet leased circuit

→ Cable or dish antenna

A location where the telecommunication line, leased circuit or cable connection or dish antenna is installed for receipt of services
 Postpaid mobile connection for telecommunication and internet services

→ Recipient’s billing address in the records of the supplier

→ Location of Supplier of Services if address not available

Prepaid mobile connection, internet services and DTH services (recharge coupon, vouchers, net pack, etc.)

Services provided through → the selling agent

→ reseller

→ distributor of SIM card or recharge voucher

→ Address of the selling agent/ reseller/ distributor at the time of supply

→ Location of Supplier of Services if address not available

Services provided by any person to final subscriberThe location where such prepayment is received or such vouchers are sold
Other Cases

→ Recipient’s address in the records of the supplier

→ Location of Supplier of Services if address not available

Proviso: Prepaid services, the payment for which is made through internet banking/other electronic modes of paymentLocation of the recipient of services in the records of the supplier of services

⇒ But what if the leased circuit is installed in more than one State or Union Territory and a Consolidated Amount is charged for the supply of services relating to such a circuit?
Place of Supply of such services shall be taken as being in each of the respective State or Union Territory in proportion to:

  • The value for service separately collected or determined in terms of the contract/ agreement entered into in this regard
  • In the absence of such contract/ agreement, on such other basis as may be prescribed in Rule 6 of IGST Rules, 2017 as follows:

The supply of services shall be treated as made in each of the respective States or Union territories in proportion to the number of points lying in the State or Union territory.

  • The number of points in a circuit shall be determined in the following manner:

I. In the case of a circuit between two points or places, the starting point or place of the circuit and the endpoint or place of the circuit will invariably constitute two points.
II. Any Intermediate point or place in the circuit will also constitute a point provided that the benefit of the leased circuit is also available at that intermediate point

Sec 12(12): Place of Supply of Banking & Financial Services
For supply of Banking and other financial services, including Stock Broking services to any person, Place of Supply is:

  • Location of the Recipient of services
  • If the location of the recipient is not on the records of the supplier, Location of Supplier of services.

Sec 12(13): Place of Supply of Insurance Services

Description of ServiceProvided toPlace of Supply
Insurance ServicesRegistered PersonLocation of such Person
Other than Registered PersonLocation of the Recipient of services (on records of the supplier)

Sec 12(14): Place of Supply of Advertisement Service to Government

Description of Service

Place of Supply

Advertisement service to the Central Government/ State Government/ statutory body/ local authority meant for the State or Union territory identified in contract or agreement

Each of such States or Union territories where the advertisement is broadcasted/ run/ played

⇒ But what if such an Advertisement is broadcasted/ run/ played in more than one State or Union Territory and a Consolidated Amount is charged for such Supply?
Services shall be treated as made in each of the respective State or Union Territory in proportion to:

  • The value for service separately collected or determined in terms of the contract/ agreement entered into in this regard
  • In the absence of such a contract/ agreement, on such other basis as may be prescribed in Rule 3 of IGST Rules, 2017 along with other Valuation Rules.

As per Section 13, Place of Supply of Services where Location of Supplier or Location of Recipient is outside India i.e. cross border transactions (except the services specified in subsection (3) to (13)) is:

DEFAULT RULE (Sec 13(2)):

  • Location of Recipient of Services
  • Where the location of the recipient is not available in the ordinary course of business, the Location of Supplier of services.

Eg. BPO Service, IT Services, etc.

Subsection 3 to 13 are specific cases and the Place of Supply provisions of the same are as under:

Sec 13(3): Place of Supply of Performance-Based Services

Section 13(3)(a) – Physical Presence of Goods for provision of Service

Section

Service Description

Place of Supply

13(3)(a)

Service-related to goods which are required to be made physically available by the Recipient to

→ Supplier or

→ A person acting on behalf of a supplier

Place of Performance

Proviso 1

(Special Case)

If such service provided from a remote location by way of electronic means

The location where goods are situated at the time of supply of services

Proviso 2

(Exceptions)

EXCEPTION: If goods are temporarily imported into India for repair or for any other treatment or process

If exported after repair without other use

POS as per Sec 13(2)

[13(3)(a) not applicable]

If exported after repair after other use

Place of Performance

[as per Sec 13(3)(a)]

Section 13(3)(b) – Physical Presence of Individual

Services supplied to an individual represented

  • Either as the Recipient of services or
  • A person acting on behalf of the Recipient

Which requires the physical presence of the recipient/person acting on his behalf with the supplier for the supply of services

Then, the Place of Supply will be the Place of Performance.

(Eg. Cosmetic/Plastic surgery, Personal security service, photography service, etc.)

Section

Scope

Service Description

Place of Supply

13(4)

Immovable Property Services

Provided directly or in relation to Immovable Property, including

→ By experts and estate agents

→ Hotel accommodation by a hotel, inn, guest house, club or campsite, etc.

→ Renting of immovable property

→  coordination of construction work, including architects or interior decorators

Place where the immovable property is located or intended to be located.

13(5)

Relating to Events

→ Admission to or organization of a cultural, artistic, etc. events

→ Services ancillary to such admission or organization

Place where the event is actually held

13(6)

Provided at Multiple Taxable Territory

Any service referred in subsection (3), (4) or (5) is supplied at more than one location including a location in the taxable territory

Location in the taxable territory

(Eg. An Indian Firm provides an inspection service for an overseas firm. The testing is carried out in Maharashtra (30%) and Alaska (70%).

Here, even if the greatest proportion of service is outside the taxable territory, the place of supply will be → )

Place in the taxable territory i.e. Maharashtra

Sec 13(7): Place of Supply of Services when Supplied in Multiple State/ Union Territory

Any service referred to in subsection (3), (4) or (5) is supplied at more than one State/ Union Territory →  Place of Supply will be taken as being in each of the respective State/ Union Territories. Services shall be treated as made in each of the respective State or Union Territory in proportion to:

  • The value for service separately collected or determined in terms of the contract/ agreement entered into in this regard
  • In the absence of such contract/ agreement, on such other basis as may be prescribed in Rule 7, Rule 8 & Rule 9 of IGST Rules, 2017 (summarised below):

Rule

Section

Description of Service

Basis of Apportionment

Rule 7

Sec 13(3)

Supplied on the same goods

Equally divided in each State/UT where service is performed

Supplied on different goods

The ratio of the invoice value of goods in each State/UT where service is performed 

Supplied to individuals

Applying Generally Accepted Accounting Principles (GAAP)

Rule 8

13(4)

Directly in relation to Immovable Property

Apply Rule 4 to determine

Rule 9

13(5)

Admission to or organization of a cultural, artistic etc. event

Apply Rule 5 to determine

Sec 13(8): Place of Supply of Specified Services

Specified Services:

  • By Banking Company/ Financial Institution/ NBFC to account holders
  • Intermediary Services
  • Services Consisting of hiring of all means of transportation [other than aircraft, vessels (except yachts)] up to a period of one month

In this case, the Place of Supply will be the Location of Service Provider.

Analysis – If less than one month, POS will be determined by Sec 13(2)]

Sec 13(9): Place of Supply of Goods Transport Services

In the case of Transportation of goods other than by way of mail or courier, Place of Supply is the place of destination of the goods.

[Analysis – In the case of mail & courier, apply Sec 13(2) or 13(3)]

Section

Service Description

Place of Supply

13(10)

Passenger Transportation

Place where the passenger embarks on the conveyance for a continuous journey 

13(11)

Onboard a conveyance including services consumed while onboard

First scheduled point of departure of that conveyance for the journey

13(12)

Online information and database access or retrieval services (OIDAR)

Location of the recipient of services

(discussed in detail in Sec 14)

13(13) Government Power to notify service to avoid double taxation 

To prevent double taxation or non-taxation of the supply of a service or for the uniform application of rules, the Government shall have the power to notify any description of services or circumstances in which the place of supply shall be the place of effective use and enjoyment of a service. Following services are notified:

Research and Development related to the Pharmaceutical sector 

Supply of research and development services related to the Pharmaceutical sector by a person located in the taxable territory to a person located in the non-taxable territory

Place of supply is the location of the recipient of service subject to the fulfillment of conditions (mentioned below).

CONDITIONS:

  •  The supply of services from the taxable territory is as per a contract between a service provider located in taxable territory and service recipient located in non-taxable territory.
  • Such supply fulfills all other conditions in the definition of export of services [Sec 2(6)(iii)

As discussed in section 13(12), the place of supply of OIDAR services is the Location of Recipient of services. But how shall one determine the location of the recipient in this case?
For this service, as per Section 14, the recipient will be deemed to be located in the taxable territory if any two of the following conditions are satisfied:

  1. The location of the address presented by the recipient through the internet is in the taxable territory.
  2. Credit card or debit card or any other card such as store value card which the recipient uses to pay is issued in the taxable territory.
  3. The billing address of the recipient of services is in the taxable territory.
  4. The IP address of the device used by the recipient is in the taxable territory.
  5. Bank of the recipient’s account used for payment is maintained in the taxable territory.
  6. The country code of the subscriber identity module card used by the recipient of services is of taxable territory.
  7. The location of the fixed landline through which the service is received by the recipient is in the taxable territory. 

Further, the taxability of OIDAR services is also subject to Exemption and Reverse Charge provisions.

Some CBIC Clarifications regarding Place of Supply are as under

  • ISSUE:
    Whether services of short-term accommodation, conferencing, banqueting, etc. provided to SEZ unit/ developer by a supplier located in the same state as that of the SEZ unit/ developer should be treated as an inter-state supply under section 7(5)(b) or an intra-state supply in terms of Section 8(2) read with 12(3)(c)?
  • Clarification: Circular No. 48/22/2018 GST dated 14.06.2018 clarifies that services of short-term accommodation, conferencing, banqueting, etc. provided to SEZ unit/ developer shall be treated as an Inter-state supply.
  • ISSUE:
    Whether the place of supply for services provided by port authorities to its clients in relation to cargo handling would be determined in terms of Section 12(2) or Section 13(2) of the IGST Act or shall be determined as per Sec 12(3)?
  • Clarification: Circular No. 103/22/2019 GST dated 28.06.2019 clarifies that cargo handling services are not related to immovable property. Accordingly, the place of supply of services will be determined as per section 12(2) or 13(2) of the IGST Act, depending on the contract.
  • ISSUE:
    What is the place of supply in case of services rendered on unpolished diamonds received from abroad which are exported after cutting, polishing, etc.?
  • Clarification: Circular No. 103/22/2019 GST dated 28.06.2019 clarifies that the above case is covered in an exception of section 13(3)(a). Hence, the place of supply will be determined as per section 13(2) of the IGST Act.

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