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IGST Implication for transportation purpose

Shambhavi Nayak

The buyer is an Builder at Bellary and have Karnataka Registration

He needs the material to be delivered at Kerala site where he doesnt have Kerala Registration.

We can issue e Invoice Bill to ship to basis but it shows

CGST SGST

In Kerala state is it necessary to give IGST Invoice or bill to ship to option is accepted.

Bill-to ship-to GST treatment allows CGST and SGST when Karnataka registration governs place of supply. Under the GST place of supply rules, a bill-to ship-to arrangement remains an intra-State supply where the supplier and the bill-to recipient are both registered in Karnataka, even if the goods are physically delivered to a site in Kerala. In such a case, the deemed place of supply is the principal place of business of the bill-to recipient, and charging CGST and SGST is legally correct. Physical movement of goods to another State does not, by itself, require IGST if the statutory bill-to ship-to conditions are satisfied. (AI Summary)
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Sadanand Bulbule on Mar 20, 2026

As per Section 10(1)(b) of the IGST Act read with Section 8(1), where the "Bill To" and supplier are in Karnataka, the place of supply is deemed to be Karnataka and the transaction qualifies as intra-State supply, hence charging CGST and SGST under a Bill To-Ship To model is legally correct even if goods are delivered to Kerala

Pinnacle Tax Advisor on Mar 20, 2026

Where goods are delivered to a third party on the direction of the buyer, the buyer's location shall be considered the place of supply (POS). Accordingly, if you are registered in Karnataka and issue the invoice to the buyer on their GSTIN registered in karnataka, CGST and SGST will be applicable-even if the goods are physically delivered in Kerala.

Shilpi Jain on Mar 21, 2026

Bill to Karnataka registration and deliver the goods to Kerala.

If your location is other than Karnataka then IGST to be charged.

YAGAY andSUN on Mar 21, 2026

Under the Goods and Services Tax (GST) framework, the nature of tax (IGST vs CGST+SGST) depends on the "place of supply" provisions read with the location of the supplier, as governed by the Integrated Goods and Services Tax Act, 2017.

In the present case:

  • Supplier: Karnataka

  • Buyer (Bill-to): Karnataka (registered)

  • Delivery (Ship-to): Kerala (unregistered site of same buyer)

As per Section 10(1)(b) of the IGST Act, where goods are delivered by the supplier to a recipient or any other person on the direction of a third person ("bill-to ship-to" model), it shall be deemed that the third person (i.e., the buyer in Karnataka) has received the goods, and the place of supply shall be the principal place of business of such third person.

Accordingly:

  • Place of supply = Karnataka

  • Location of supplier = Karnataka

  • Hence, the transaction qualifies as an intra-State supply under Section 8 of the IGST Act.

Therefore, levy of CGST + SGST is legally correct.

Further:

  • The fact that goods are physically delivered to Kerala does not alter the tax position due to the deeming fiction under Section 10(1)(b).

  • "Bill-to ship-to" invoicing is expressly recognized under GST law and is valid for e-invoicing compliance.

  • There is no mandatory requirement to charge IGST merely because the goods are delivered in another State, if the statutory conditions of Section 10(1)(b) are satisfied.

Conclusion:
Issuance of a "bill-to ship-to" invoice charging CGST and SGST is legally permissible and compliant. Raising an IGST invoice in this fact pattern would not be aligned with the place of supply provisions. This position is well-settled in law and supported by GST circulars and interpretative guidance.

KASTURI SETHI on Mar 21, 2026

CGST and SGST is legally correct, it being "Bill to--Ship to" model

Vijay kumar on Mar 22, 2026

Your query says - In Kerala state is it necessary to give IGST Invoice or bill to ship to option is accepted.

All states have to uniformly follow the GST law. Your transaction is intra-state and payment of CGST+SGST is correct.

Your invoice should mention "Bill to" name and address and "ship to" name and address properly with EWB to destination in Kerala. There should be no issues.

Ryan Vaz on Mar 22, 2026

You are correct to charge CGST + SGST (Karnataka GST) if the "Bill To" party is registered in Karnataka, even though goods are physically delivered to Kerala.

Under GST law, this is a valid bill-to ship-to transaction, and IGST is NOT required merely because goods move to Kerala. The transaction is treated as intra-state supply (Karnataka) based on the buyer's registration.

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