Place of Supply / State Code

Inter-State vs Intra-State GST

CA Nikhil Gupta·May 2026·3 min readPlace of Supply / State Code

Tax type is a legal conclusion, not a dropdown selected from the customer’s billing state.

Quick View

Decision

Create a state-code and place-of-supply validation before invoice generation.

First action

Confirm supplier GSTIN.

Core evidence

GST registration records.

Main warning

Using customer head-office GSTIN.

Why It Matters

Inter-state or intra-state treatment generally compares supplier location with place of supply, subject to special cases such as SEZ supplies and imports or exports.

Wrong state code can send tax to the wrong government, block customer credit and require a refund-and-repayment process.

Bill-to ship-to, branch transfers and third-party delivery structures should be reviewed before master data is configured.

Control Framework

AreaWhat to establishOperating rule
SupplierGST registration making supply.Use actual establishment.
PlaceGoods movement or service rule.Determine independently.
Special statusSEZ, import, export or distinct person.Apply statutory override.
InvoiceState code and tax head.System validation.

Action Checklist

  1. Confirm supplier GSTIN.
  2. Determine place of supply.
  3. Verify customer and delivery states.
  4. Flag SEZ transactions.
  5. Test bill-to ship-to cases.
  6. Reconcile tax heads monthly.

Practical Example

A Karnataka branch invoices a customer’s Maharashtra GSTIN, but the service is supplied from and connected to the customer’s Karnataka fixed establishment. The billing GSTIN alone may misstate the tax type.

Evidence to Keep

  • GST registration records.
  • Customer purchase order.
  • Delivery or service-location proof.
  • SEZ endorsement if relevant.
  • Tax determination memo.
  • Invoice and ledger data.

Warning Signs

  • Using customer head-office GSTIN.
  • Ignoring delivery location.
  • Treating all branch transfers as non-taxable.
  • Wrong SEZ flag.
  • No tax-head reconciliation.

Detailed Review

A defensible GST position must connect the commercial transaction, statutory rule, notification or circular, invoice, books, portal return and electronic ledger. A conclusion supported by only one layer is fragile.

Prepare an issue sheet that records GSTIN, period, tax head, amount, legal provision, effective date, evidence owner and approval. This is especially important where rates, thresholds or portal advisories changed during the year.

Reconcile by CGST, SGST, IGST and cess instead of only by total. An equal total can conceal tax paid to the wrong jurisdiction or credit recorded under the wrong registration.

Maintain original downloads and signed documents. Portal screenshots are useful context but should not replace JSON, returns, bills of entry, e-way bills, IRNs, ledgers, contracts and acknowledgements.

For judgemental matters, document competing interpretations and why one was selected. A short approval note created before filing is more credible than a justification written after a notice.

Product and customer master data should be locked to the approved tax position. Changes to HSN, SAC, rate, state code or place-of-supply logic should require controlled approval.

Review the exact effective date of every notification. Commercial announcements and GST Council recommendations do not replace an operative notification.

Transaction Test

Before filing, restate the transaction in one sentence using the legal parties, GST registrations, product or service, value, place, date and consideration. This often exposes hidden assumptions.

Test the result under an alternative fact: different customer GSTIN, delayed invoice, changed vehicle, partial vendor payment, exempt recipient or later cancellation. The control should explain why the tax outcome changes.

Create a gross-to-net bridge from commercial value to taxable value, tax, credit, payment and ledger effect. Avoid unexplained balancing figures.

Reconcile the counterparty’s likely records. Customer ITC, vendor GSTR-1, operator settlement, customs bill of entry and transport documents can contradict internal accounting.

Record the correction route before an error occurs: cancellation, credit note, amendment, reversal, re-availment, refund, DRC-03, representation or appeal.

Set a named owner, internal due date and evidence requirement for every exception.

Escalate material exposure before the statutory deadline rather than after portal rejection.

Escalation Route

Start with the commercial record, GST portal data and statutory working. Correct system or document errors through the prescribed process and retain the acknowledgement.

Where the matter is judgemental, disputed or enforcement-related, obtain a reasoned GST and legal review before payment, reply, refund, statement, appeal or restructuring.

Final Control

Management should record the financial exposure, cash-flow consequence, counterparty impact and statutory deadline for every unresolved GST issue. A tax difference can affect customer ITC, pricing, bank limits or business continuity even before an order is issued.

The control is complete only when the corrected invoice, portal filing, ledger entry, payment, refund, ruling, registration or authority communication is received and stored. An internal email saying that the issue is resolved is not closure evidence.

Frequently Asked Questions

What decides IGST versus CGST-SGST? â–¼
Supplier location and place of supply, subject to statutory special cases.
Are branch transfers taxable? â–¼
Distinct GST registrations can be treated as separate persons.
Does bill-to ship-to change place of supply? â–¼
It can under the specific goods rule.
Can tax paid under the wrong head be moved internally? â–¼
Usually not; formal payment and refund provisions must be reviewed.