No movement is a fact to establish, not an invoice label
For goods supplied to registered B2B recipients within IGST section 10, paragraph (1)(c) places a supply not involving movement by supplier or recipient at the goods location when delivered to the recipient. This guide is confined to registered recipients. For supplies made on or after 1 October 2023, supplies to unregistered persons need separate review under section 10(1)(ca), which overrides clauses (a) and (c); CBIC Circular 209/3/2024-GST reproduces that provision. The guide concerns the delivery-time location evidence for the registered-recipient supply. It does not mean every warehouse sale qualifies, or that passing title alone settles GST delivery. Imports, exports and special transaction structures require their own applicable analysis.
Read the applicable text: CBIC: IGST Act, sections 7–11, particularly 10(1)(c) CBIC Circular 209/3/2024-GST: unregistered-recipient boundary.
Map the full contractual delivery obligation
Read the order, delivery terms, release instruction, custody records and any required onward transport. Goods being stationary when invoiced does not prove the supply involves no movement. If movement by the supplier or recipient forms part of the supply, analyse the relevant rule rather than forcing paragraph (c). Distinguish later independent use or transport from movement required under the actual supply; that distinction needs the real contract and facts.
Locate the goods at the delivery event
Identify the site, lot, serials or other reliable goods identifiers and the effective delivery date. For goods remaining with a custodian, retain evidence explaining the custodian's role and the actual delivery arrangement. A warehouse balance, payment receipt or purchaser's head-office address alone may leave the legal delivery question unresolved. Do not assume a universal constructive-delivery result from this article.
Separate buyer identity from goods location
Record the purchaser's legal identity and GST details alongside the physical location conclusion. A billing office in a different State does not automatically replace the established paragraph (c) location. Conversely, supplier location and the nature of the supply still need independent analysis under the relevant IGST provisions and exceptions. This article prescribes no tax rate and does not decide registration obligations merely from the goods location.
Control stock and invoice movements
Reconcile the identified delivered goods with stock ownership, custody instructions, invoices and payment records. Avoid recording a later internal movement as a second sale without an actual supply analysis. Also avoid leaving the same quantity allocated to two owners in the custody register. Where there are genuinely separate supplies, preserve each location and delivery event instead of merging them into one billing-address result.
Resolve boundary cases before finalising
Installation at site, third-party directions, imports/exports and a supply requiring onward movement may engage other rules. Preserve the reason paragraph (c) applies or does not apply. If an earlier invoice or return used the wrong location, determine the supported correction route separately; editing a stock-location master alone does not correct filed documents. The illustrations assume recipients are registered, with valid classified goods supplies and the stated delivery facts.
Six worked illustrations
All facts and amounts are fictional. Calculations illustrate the stated assumptions, not a predetermined legal outcome.
Illustrative example 1: Head office elsewhere
Assume goods are delivered without movement at a warehouse in Ahmedabad to a buyer headquartered in Mumbai, with paragraph (c) established as applicable. Goods value is ₹8 lakh, paid as ₹3 lakh and ₹5 lakh. The receipts total ₹8 lakh; the buyer's head office does not replace the delivery-time goods location.
Illustrative example 2: Partial identified delivery
A lot contains 100 identified units, of which 40 are validly delivered without movement under the assumed arrangement. At ₹2,000 each, delivered value is ₹80,000 and the remaining 60 units represent ₹1,20,000. Do not treat the full ₹2 lakh lot as delivered from the invoice proposal alone.
Illustrative example 3: Separate supplies at two sites
Assume independently established no-movement deliveries of ₹6 lakh at Surat and ₹4 lakh at Nagpur. Total value is ₹10 lakh, with a 60:40 value split. Preserve the separate delivery locations; the ratio is a reconciliation, not a location-allocation rule for an unanalysed single supply.
Illustrative example 4: Stationary stock with onward obligation
Assume ₹12 lakh of goods are invoiced while stored, but the actual supply requires dispatch to the recipient in another State. An advance ₹4 lakh and balance ₹8 lakh reconcile to ₹12 lakh. Their temporary stationary status does not by itself establish paragraph (c).
Illustrative example 5: Custody allocation control
Opening stock is 200 units. Valid identified delivery transfers 70 units to Buyer A and 50 to Buyer B, leaving 80 with the seller. The physical site may still hold all 200, but ownership/custody subrecords must explain 120 delivered units separately; physical co-location alone is not proof of the legal arrangement.
Illustrative example 6: Duplicate value import
A ₹5 lakh delivery is represented in the invoice system and again in a custody-transfer report. Adding both as sales gives ₹10 lakh instead of ₹5 lakh. Reconcile the shared underlying supply identifier before determining return values.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Identify the goods supply | Registered-recipient evidence and classification within section 10 scope. |
| 2 | Map delivery obligations | Supplier and recipient movement requirements. |
| 3 | Establish the delivery event | Supported date and legal delivery arrangement. |
| 4 | Identify goods at that event | Lot, serial, quantity and location records. |
| 5 | Verify custodian involvement | Release and custody documents where applicable. |
| 6 | Record buyer details separately | Legal identity and billing data distinguished from location. |
| 7 | Test other place rules | Movement, installation and import/export boundaries. |
| 8 | Reconcile stock and value | Delivered quantities, retained stock and invoices. |
| 9 | Complete separate tax analysis | Supplier location, nature of supply and applicable liabilities. |
| 10 | Close the evidence file | Location rationale and any required correction review. |
Sixteen practitioner FAQs
1. Does stationary stock at invoicing prove no movement?
No. Examine the full supply and delivery obligation.
2. Does movement by the recipient matter?
The paragraph addresses absence of movement by supplier or recipient.
3. Does the buyer's billing State automatically control?
For the registered-recipient scope here, use the established paragraph (c) analysis; unregistered supplies have the separate paragraph (ca) override.
4. Does payment prove where delivery occurred?
Not by itself.
5. Can goods remain physically with a custodian?
Review the actual legal delivery and custody arrangement; no universal result is assumed here.
6. Does passing title alone resolve every GST delivery question?
No. Assess the transaction and applicable law.
7. Can later independent transport be ignored automatically?
Determine whether it forms part of the actual supply rather than assuming either answer.
8. Does a planned onward dispatch affect the analysis?
Yes. Examine whether the supply involves movement under its actual obligations.
9. Are imported and exported goods generally governed by this rule?
They require the applicable section 11 analysis rather than automatic paragraph (c) treatment.
10. Can installation arrangements be assumed to be no-movement sales?
No. Consider the actual classification and applicable place provision.
11. Can separate site supplies use one location for convenience?
Preserve each supported supply and delivery event.
12. Does a custody register alone determine legal delivery?
It is evidence to assess with the contract and other records.
13. Does physical co-location mean one owner?
No. Reconcile the actual identified rights and custody records.
14. Can the same sale be counted from both invoice and custody imports?
No. Use a common supply identifier to avoid duplication.
15. Does the article prescribe tax rates or registrations?
No. Those require their own applicable analysis.
16. What establishes the place conclusion?
The supported no-movement supply, delivery event and goods location at that time.
Official sources
CBIC: IGST Act, sections 7–11, particularly 10(1)(c) CBIC Circular 209/3/2024-GST: unregistered-recipient boundary