Table of Contents
Table of Contents
Last updated: 16 October 2026 · Written and reviewed by CA Meet Dhrangadhariya, CSM & Co LLP
Quick summary
GST liability does not arise when a deal is struck, or even necessarily when goods change hands or a service finishes - it arises on a specific legal date called the “time of supply.” Getting that date wrong means reporting a supply in the wrong tax period, which misstates both the supplier’s output tax and the recipient’s input tax credit timing.
New to terms such as “forward charge” or “reverse charge”? See the technical terms explained in simple words further down.
Under section 12(2) of the CGST Act, 2017, the time of supply of goods is the earlier of:
(a) the date the invoice is issued (or the last date it should have been issued under section 31), or
(b) the date the supplier receives payment.
Notes:
– If the supplier receives up to Rs 1,000 more than the invoice amount, the supplier can choose to treat the invoice date as the time of supply for that extra amount, instead of the payment date.
– “Date of receipt of payment” is whichever is earlier: the date it is entered in the supplier’s books, or the date it is credited to their bank account.
Example: Invoice issued 15 May 2026, payment received 10 July 2026, payment recorded in the supplier’s books on 11 July 2026. The time of supply is 15 May 2026 - the earlier of the invoice date and the payment date (itself taken at its earlier sub-date).
Under section 13(2), the rule for services depends on whether the invoice was issued within the time section 31 requires:
The same Rs 1,000 excess-payment option, and the same “earlier of books entry or bank credit” rule for the payment date, apply here too.
Under section 12(3), where tax is paid on reverse charge (the recipient, not the supplier, pays the tax), the time of supply of goods is the earliest of:
(a) the date the goods are received,
(b) the date of payment (the earlier of the books entry or the bank debit), or
(c) the day immediately after 30 days from the date of the supplier’s invoice.
If none of these can be determined, the time of supply is the date the recipient enters the supply in their own books.
Under section 13(3), for services under reverse charge, the time of supply is the earlier of:
(a) the date of payment (the earlier of the books entry or the bank debit), or
(b) the day immediately after 60 days from the date of the supplier’s invoice (where the supplier is required to issue the invoice).
A 2024 amendment added a further rule: where the recipient is required to issue the invoice (rather than the supplier), the time of supply is instead the date the recipient issues that invoice. And where the service is supplied by an associated enterprise located outside India, the time of supply is the earlier of the date the recipient enters it in their books, or the date of payment - without the 60-day fallback that applies in the ordinary reverse-charge case.
Until recently, sections 12(4) and 13(4) gave vouchers their own time-of-supply rule - the date of issue if the underlying supply was identifiable at that point, or the date of redemption otherwise. This provision was omitted from the CGST Act with effect from 1 October 2025, by the Finance (No. 7 of 2025) Act. Any article, including older versions of this one, that describes a separate “date of issue vs date of redemption” rule for vouchers is citing a provision that no longer exists in the Act. For a voucher transaction today, the time of supply follows the ordinary rules above for whatever the voucher represents, not a special voucher-only rule.
Under sections 12(5) and 13(5), if the time of supply genuinely cannot be fixed by any of the rules above:
Under sections 12(6) and 13(6), if a supplier later charges interest, a late fee, or a penalty because the consideration for a supply was paid late, the time of supply for that added amount is the date the supplier actually receives it - not the date of the original supply.
Time of supply errors are easy to make and expensive to unwind, especially around reverse charge deadlines, invoice-timing rules, and now the repealed voucher provision. Please reach out to our team and we will be happy to assist with transaction-by-transaction time-of-supply determination and GST return reconciliation.
| Term | What it means |
|---|---|
| Forward charge (normal charge) | The ordinary arrangement where the supplier charges and pays the GST on a supply. |
| Reverse charge | The reversed arrangement where the recipient, not the supplier, is liable to pay the GST directly to the Government. |
| Associated enterprise | A related business entity as defined for this purpose, commonly a foreign parent, subsidiary, or group company. |
| Electronic credit/cash ledger | The online accounts on the GST Portal that track a taxpayer’s available input tax credit and cash deposits. |
| Tax period | The period (usually a month or quarter) for which GST liability is reported in a return - time of supply decides which tax period a transaction falls into. |
The specific date on which GST liability on a transaction legally arises - it determines which tax period (and which GST return) the supply must be reported and taxed in, regardless of when the underlying business transaction actually happened in full.
The earlier of the date the invoice is issued (or the last date it should have been issued under section 31) and the date the supplier receives payment, under section 12(2) of the CGST Act.
If the invoice is issued within the time section 31 requires, the earlier of the invoice date or the payment date. If it is not issued in time, the earlier of the date the service was actually provided or the payment date, under section 13(2).
For goods, the earliest of the date the goods are received, the date of payment, or the day after 30 days from the supplier’s invoice date (section 12(3)). For services, the earlier of the date of payment or the day after 60 days from the invoice date, with separate rules for recipient-issued invoices and for associated enterprises abroad (section 13(3)).
No. The provision (sections 12(4) and 13(4)) that set a separate date-of-issue or date-of-redemption rule for vouchers was omitted from the CGST Act with effect from 1 October 2025, by the Finance (No. 7 of 2025) Act. Any article still describing a separate voucher rule is citing law that no longer exists.
Its time of supply is the date the supplier actually receives that additional amount, under sections 12(6) and 13(6) - not the date of the original supply.
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.