The unregistered-recipient rule overrides two general goods rules
IGST section 10(1)(ca), effective from 1 October 2023, overrides contrary provisions of clauses (a) and (c) for supplies to persons other than registered persons. It uses the recipient address recorded in the invoice, or supplier location where that address is absent; recording the recipient's State is deemed address recording. CBIC Circular 209/3/2024-GST dated 26 June 2024 explains billing-versus-delivery address cases. This guide is distinct from registered B2B bill-to/ship-to and no-movement workings.
Read the applicable text: CBIC Circular 209/3/2024-GST: clause (ca) and invoice-address clarification.
Use the circular's delivery-address clarification on its facts
For the described unregistered supply where invoice delivery address differs from billing address, the circular identifies the invoice delivery address as the place under clause (ca). It also permits recording that delivery address as the recipient address for the purpose. Do not preserve an obsolete billing-State default when the supported invoice and facts fall within that clarification. This is not permission to invent an address after the event.
Verify registration status before selecting the rule
Keep the recipient identity, relevant registration evidence and invoice date together. A customer code marked retail does not alone establish the legal status; conversely, do not apply registered B2B logic to an unregistered person simply because the purchaser is a business. Special goods structures, imports/exports and other applicable provisions require separate review. The override's wording concerns clauses (a) and (c), not a blanket replacement of every place provision.
Separate three location fields
Maintain billing address, invoice delivery/recipient address and the resulting place of supply as distinct records. Retain the order, shipping instruction, invoice version and actual delivery evidence where relevant. Where only the State is recorded, understand the express deeming rule; do not treat a missing street address as automatically no recorded address. Where the relevant recipient address is absent, document why the supplier-location fallback applies. Check mandatory invoice particulars separately: the place-of-supply fallback does not permit omission of particulars that the invoicing rules require.
Reconcile orders, amendments and values
A buyer can place multiple orders to different supported delivery States. Preserve the actual supply and invoice data rather than copying the first order's place to all later orders. A price-only amendment need not relocate the supply. An address correction requires factual and legal review; changing an internal master is not itself correction of an issued invoice or filed return.
Keep the rest of the tax analysis independent
Clause (ca) determines location within its scope. Supplier location, nature of supply, rate, exemption, registration liability and invoicing consequences require their own checks. No rate is assumed here. The examples use fictional pre-tax values, assume the stated unregistered-recipient and circular conditions are established, and do not decide every marketplace or third-party-direction transaction.
Six worked illustrations
All facts and amounts are fictional. Calculations illustrate the stated assumptions, not a predetermined legal outcome.
Illustrative example 1: Different billing and delivery States
Assume an unregistered buyer's invoice shows billing in Maharashtra and delivery in Karnataka within the circular's facts. Goods of ₹20,000 plus ₹5,000 total ₹25,000. Use the supported Karnataka delivery address for the clause (ca) conclusion; the arithmetic does not determine a GST rate.
Illustrative example 2: Same customer, separate deliveries
Assume separate invoices of ₹30,000 to Rajasthan and ₹20,000 to Gujarat for the same unregistered customer. Combined value is ₹50,000, split 60:40. Maintain each supported invoice location rather than applying one customer-master State to all ₹50,000.
Illustrative example 3: State-only recipient address
Assume the invoice records the recipient's State, Tamil Nadu, and the facts are within clause (ca). Two items of ₹8,000 and ₹12,000 total ₹20,000. The absence of a street line alone does not negate the express State-recording deeming rule.
Illustrative example 4: No relevant recipient address
Assume clause (ca) applies, the applicable invoicing requirements allow the omission in this case, and the invoice records neither a recipient address nor State. The supplier location is independently established as Delhi. A ₹15,000 supply paid through ₹10,000 and ₹5,000 receipts remains one ₹15,000 supply. Apply the supplier-location fallback on those facts, not a place inferred from payment instalments.
Illustrative example 5: Price change without address change
A supported ₹40,000 invoice is reduced by an agreed ₹4,000 price correction, leaving ₹36,000. The unchanged supported delivery/recipient address does not move merely because consideration changed. Follow the applicable document correction process separately.
Illustrative example 6: Duplicate address-version import
An original ₹50,000 order and an amended full-value invoice of ₹50,000 are mistakenly counted as two supplies after an address correction. The correct underlying value remains ₹50,000, not ₹1 lakh. Resolve the valid invoice version and location evidence without doubling turnover.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Fix the supply date and scope | Applicable goods rule and transaction facts. |
| 2 | Verify recipient status | Unregistered status supported for the relevant supply. |
| 3 | Separate location records | Billing, delivery/recipient and supplier locations. |
| 4 | Inspect the invoice | Actual address or State recorded. |
| 5 | Apply the circular on its facts | Supported billing-versus-delivery address conclusion. |
| 6 | Test the fallback if necessary | Absence of recipient address/State evidenced. |
| 7 | Review special transaction boundaries | No blanket override of every place provision. |
| 8 | Reconcile values and versions | Orders, amendments and duplicate controls. |
| 9 | Complete separate tax checks | Nature, rate, exemptions and invoicing obligations. |
| 10 | Close the evidence and corrections | No reliance on a master-data edit alone. |
Sixteen practitioner FAQs
1. Does clause (ca) apply simply because a customer is labelled retail?
No. Establish the recipient's legal registration status and supply facts.
2. Can an unregistered business fall within the stated population?
Business status alone is not registration; verify the actual facts.
3. Which two clauses does the override name?
Clauses (a) and (c) of section 10(1).
4. Does it override every other place rule?
Do not infer that; review the actual applicable provisions.
5. What does the circular explain about differing invoice addresses?
For its described unregistered supply, it identifies the invoice delivery address as the relevant place.
6. Can the delivery address be recorded as recipient address for that purpose?
The circular expressly permits that approach on its facts.
7. Does missing a street line always trigger supplier location?
No. Recording the recipient's State is deemed address recording under the Explanation.
8. When is supplier location the fallback here?
Where the relevant recipient address is not recorded on the invoice, on the applicable statutory facts. A recorded recipient State counts as an address for this purpose. Check invoice particulars separately.
9. Does payment currency identify the place?
Not by itself.
10. Can one customer receive supplies at addresses in different States?
Preserve each actual supply and invoice conclusion.
11. Does a price correction automatically change location?
No. Value and address changes are separate facts.
12. Can a master change correct an already filed return?
No. Follow the applicable supported correction route.
13. Does the article replace registered B2B bill-to/ship-to analysis?
No. That is a different population and needs its own applicable rule.
14. Does the clause decide the GST rate?
No. Rate and liability questions remain separate.
15. Can invoice versions be counted as extra supplies?
No. Reconcile versions to the underlying transaction.
16. What is the essential evidence?
Recipient status, valid invoice address/State, circular applicability and the supported place conclusion.
Official sources
CBIC Circular 209/3/2024-GST: clause (ca) and invoice-address clarification