Place of Supply for Specific Services under GST (2026): Immovable Property, Events, Transport, Telecom and More
CA Meet Dhrangadhariya 
May 2, 2026
CA Meet Dhrangadhariya May 2, 2026
Table of Contents
7 min readTable of Contents
Last updated: 26 October 2026 · Written and reviewed by CA Meet Dhrangadhariya, CSM & Co LLP
Quick summary
Our general rule guide covers section 12(2) - the default that applies to most services. This post covers the specific rules in sections 12(3) to (14) of the IGST Act, which override the general rule for particular categories of service.
New to terms such as “recipient on record” or “continuous journey”? See the technical terms explained in simple words further down.
Under section 12(3), the place of supply is the location of the immovable property (or boat/vessel) itself, for:
This applies regardless of who the recipient is or where they are registered. If the property is outside India, the place of supply falls back to the recipient’s own location. Where the property spans more than one State, the supply is split across those States in proportion to the value of services attributable to each.
Example: A company registered in Gujarat books hotel accommodation in Maharashtra for a business trip. Even though the recipient is a registered person, the place of supply is Maharashtra (the hotel’s location), not Gujarat - so CGST and SGST apply, and the Gujarat company cannot set off Maharashtra’s SGST credit against its own Gujarat SGST output liability.
Under section 12(4), the place of supply of restaurant and catering services, personal grooming, fitness, beauty treatment, and health services (including cosmetic and plastic surgery) is where the service is actually performed - not the recipient’s registration address.
Under section 12(5): for a registered recipient, the recipient’s own location; for an unregistered recipient, where the service is actually performed.
Under section 12(6), admission to a cultural, artistic, sporting, scientific, educational or entertainment event, or an amusement park, is placed where the event is actually held, or where the park or venue is located - for anyone, registered or not.
Under section 12(7), organising such an event (as opposed to simply attending it) - including conferences, fairs, exhibitions, celebrations, and sponsorship of such events - follows a different test:
Section 12(8) used to set a specific rule for transportation of goods within India. This sub-section was omitted with effect from 1 October 2023, confirmed on the CBIC Tax Information Portal. Domestic goods transportation now follows the general rule under section 12(2) - the recipient’s location if registered, or the recipient’s address on record (or the supplier’s location) if unregistered - rather than a dedicated goods-transportation rule.
Under section 12(9): for a registered person, their own location; for an unregistered person, where they board the conveyance for a continuous journey. A return journey is always treated as a separate journey, even if both tickets are booked together.
Under section 12(10), services supplied on board a vessel, aircraft, train or motor vehicle are placed at the location of the first scheduled point of departure of that journey - not where the passenger is, or where the journey ends.
Under section 12(11), the rule depends on the type of service: a fixed line, leased circuit or dish connection is placed where the equipment is installed; a post-paid mobile or internet connection uses the recipient’s billing address on record; a prepaid recharge sold through an agent uses the agent’s own address, and one sold directly to the final subscriber uses where the payment was received or the voucher sold; recharges through internet banking or electronic payment use the recipient’s address on record.
Under sections 12(12) and 12(13), both banking/financial services (including stock broking) and insurance services use the recipient’s address on the supplier’s own records, falling back to the supplier’s own location if no such record exists. Insurance additionally distinguishes a registered recipient (always their own location) from an unregistered one (the address on record).
Under section 12(14), where an advertisement is supplied to the Central Government, a State Government, a statutory body or a local authority, and the advertisement targets specific States or Union Territories named in the contract, the place of supply is split across each of those States or Union Territories, in proportion to the value attributable to each.
Each of these specific rules overrides the general rule for its own narrow category, and getting the category wrong - treating an immovable-property service as a general service, for instance - means charging the wrong tax entirely. Please reach out to our team and we will be happy to assist with service classification under these specific rules.
| Term | What it means |
|---|---|
| Recipient on record | The recipient’s address or details the supplier has genuinely captured and kept in its own records, used as the place-of-supply test for several specific services. |
| Continuous journey | A single uninterrupted journey for place-of-supply purposes; a return trip counts as a separate continuous journey even if booked at the same time. |
| Ancillary service | A service that supports or is closely connected to a main service, and is placed at the same location as that main service for GST purposes. |
| Billing address | The address a telecom or similar service provider has on file for sending bills to a customer - used as a place-of-supply anchor for post-paid connections. |
The location of the immovable property (or boat/vessel) itself - under section 12(3) of the IGST Act. This covers architects, interior decorators, construction and co-ordination services, hotel and lodging accommodation, and venues for weddings or functions. If the property is outside India, the place of supply falls back to the recipient’s location.
Admission to an event (a concert, sporting event, amusement park) is always placed where the event is actually held, under section 12(6). Organising an event is different: for a registered recipient, it is the recipient’s own location; for an unregistered recipient, it is where the event is held (or the recipient’s location if the event is held outside India), under section 12(7).
For a registered person, their own location. For an unregistered person, the place where they board the conveyance for a continuous journey - under section 12(9). A return journey is always treated as a separate journey from the onward journey.
No. Section 12(8), which used to set a specific rule for transportation of goods within India, was omitted with effect from 1 October 2023. Domestic goods transportation now follows the general rule under section 12(2) instead.
Not by physical location, but by a billing-address or recipient-on-record test. Telecom (section 12(11)) looks at where the connection is installed, the billing address, or where a prepaid recharge is sold, depending on the type of service. Banking and financial services (section 12(12)) and insurance (section 12(13)) use the recipient’s address on the supplier’s own records, falling back to the supplier’s location if no such record exists.
Where the advertisement is for the Central Government, a State Government, a statutory body or a local authority, and is meant for specific States or Union Territories named in the contract, the place of supply is split across each of those States or Union Territories, in proportion to the value attributable to each, under section 12(14).
This article is for general informational purposes only and should not be considered professional advice. Please consult a qualified expert for advice tailored to your specific situation. The author and website owner are not liable for any errors or actions based on this content.
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