A goods-installation rule starts with classification
IGST section 10(1)(d) places supply of goods assembled or installed at site at that installation or assembly location. Section 10 concerns goods other than imports or exports. Establish that the actual supply falls within this goods rule before using it. An installation contract is not automatically a supply of goods: immovable-property and works-contract questions require their own classification review. This guide concerns the installation-site evidence, not a universal rule for every equipment invoice.
Read the applicable text: CBIC: IGST Act, sections 7–11, particularly 10(1)(d).
Identify the actual contractual supply
Read the order, technical scope, installation responsibilities, acceptance provisions and deliverables. Distinguish equipment assembled at the customer's site from goods merely delivered there, a separate service, or a wider composite arrangement. Invoice headings and a delivery address cannot alone resolve the classification. Where more than one place rule appears relevant, including a third-party direction arrangement, resolve the actual statutory facts rather than assuming a mechanical hierarchy from this article.
Prove the installation location
Retain the site address, commissioning or installation record, assembly report, acceptance evidence and asset identifiers. Distinguish the purchaser's registered office, billing GSTIN, dispatch location, transit warehouse and actual site. A revised installation location should trigger review even if the purchaser has not changed. A payment coming from head office does not itself establish that head office as the installation location.
Reconcile quantities and contract changes
Match equipment serials, quantities, site changes, replacements and variations to the underlying supply. Do not assume that each delivery vehicle or instalment creates a separate supply or installation site. Conversely, separate sites need traceable documentation; do not collapse them into one location solely because a central procurement team placed one order. The monetary examples assume separate supplies where expressly stated and exclude tax.
Separate place of supply from other GST decisions
Once the applicable location is established, determine the nature of supply using the relevant supplier-location and inter-State/intra-State provisions and exceptions. Rate, registration, exemption, time of supply, input credit and invoicing obligations remain separate. This article does not assume an 18% rate or declare every cross-State dispatch an inter-State supply. Import and export goods have their own place framework under section 11.
Close the site-to-invoice bridge
For each established supply, connect the legal classification, actual site, installation evidence and invoice amount. A site master change is an internal control, not a correction of an already issued invoice or filed return. Investigate the legal correction route where necessary. Keep commissioning and acceptance evidence distinct from any revenue-recognition or GST time-of-supply conclusion; the same document may support several analyses without making their tests identical.
Six worked illustrations
All facts and amounts are fictional. Calculations illustrate the stated assumptions, not a predetermined legal outcome.
Illustrative example 1: Head office differs from site
Assume a qualifying ₹20 lakh goods supply is assembled at a Pune site for a purchaser headquartered in Bengaluru. The installation place is Pune under paragraph (d) on these facts. Two instalments of ₹12 lakh and ₹8 lakh total ₹20 lakh; the payer's head-office address does not replace the site.
Illustrative example 2: Genuinely separate sites
Assume separate qualifying supplies of ₹15 lakh at Hyderabad and ₹10 lakh at Jaipur. Total contract values are ₹25 lakh, with 60% and 40% by value. Preserve each installation location; the ratio is a value reconciliation, not an allocation rule for an unanalysed single supply.
Illustrative example 3: Variation at the same site
A supported qualifying supply of ₹18 lakh is increased by ₹2 lakh for agreed additional goods in the same installation. Revised value is ₹20 lakh. A price increase alone does not establish another place of supply.
Illustrative example 4: Serial-number reconciliation
The installation scope covers 24 machines. Evidence shows 18 installed and six awaiting work. The completion proportion is 75%; 25% awaits installation evidence. These percentages do not automatically determine GST time of supply or revenue recognition.
Illustrative example 5: Site relocation
Assume a qualifying installation is contractually relocated from Site A to Site B without changing the ₹30 lakh value. A ₹9 lakh advance and ₹21 lakh balance reconcile to ₹30 lakh. The unchanged price does not justify retaining the obsolete installation address.
Illustrative example 6: Duplicate dispatch records
A ₹12 lakh underlying supply arrives in three consignments of ₹4 lakh each. Their sum is ₹12 lakh. Importing the full ₹12 lakh order and all dispatch amounts as separate supply values produces ₹24 lakh, an unsupported ₹12 lakh overstatement.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Establish section 10 scope | Domestic goods population distinguished from imports/exports. |
| 2 | Classify the contract | Goods installation versus other arrangements. |
| 3 | Resolve overlapping place facts | Third-party directions and contract structure where relevant. |
| 4 | Identify each supply | No automatic splitting by delivery or instalment. |
| 5 | Record the actual site | Full location and asset identifiers. |
| 6 | Obtain installation evidence | Assembly, commissioning and acceptance records. |
| 7 | Trace amendments | Relocations, variations and replacements. |
| 8 | Reconcile quantities and values | Order, dispatch and installation populations. |
| 9 | Determine separate GST consequences | Nature of supply, rate and invoicing analysis. |
| 10 | Close exceptions | Supported location conclusion and correction review if needed. |
Sixteen practitioner FAQs
1. Does every installation invoice use section 10(1)(d)?
No. Establish the actual goods-supply classification and scope.
2. Does this rule cover imported or exported goods generally?
Section 10 has a different scope from section 11's import/export rules.
3. Does the buyer's head office automatically determine place?
Not where the established paragraph (d) rule points to the installation site.
4. Is dispatch location necessarily the installation location?
No. Trace the actual site and installation evidence.
5. Does a warehouse receipt prove installation?
Not by itself; obtain the relevant assembly or installation records.
6. Can an immovable-property arrangement be assumed to be goods?
No. Classify it under the applicable law first.
7. Do invoice lines alone create separate supplies?
No. Examine the actual contractual arrangement.
8. Does one procurement order necessarily mean one site conclusion?
No. Establish the supplies and locations from the facts.
9. Can a third-party direction be ignored?
Resolve the applicable statutory facts rather than assuming this guide overrides another rule.
10. Does a variation price necessarily change location?
No. Record value and site changes separately.
11. Does an unchanged price preserve the original site?
Not when supported facts establish a different installation location.
12. Can each dispatch be counted as the whole order value?
No. Reconcile dispatches to the underlying supply without duplication.
13. Does installation percentage decide the GST tax point?
Not automatically; time of supply has a separate analysis.
14. Does the article prescribe a GST rate?
No. Verify the actual classification and applicable rate separately.
15. Does changing a master correct a filed return?
No. Follow the applicable correction process where required.
16. What is the key evidence chain?
Classified supply, actual site, identified goods, installation evidence and reconciled invoice value.