1. Time of Supply Discussion By : CA Manoj Kumar Goyal Partner
RHMS & Company
Chartered Accountants

2. Relevance of Time of Supply Taxable Event
Time of Supply is relevant for the purpose of identifying the point of taxation (Taxable Event). Tax is levied at the precise time of occurrence of an activity. Liability to pay CGST/SGST on the goods arises at the time of supply. Time of Supply hold utmost importance for discharging the tax liability.

3. Liability to pay CGST/SGST
Time of Supply
Time of Supply is the event which determines the time when the liability to pay tax arises or the tax becomes payable. It is the event on the happening of which liability for payment of tax becomes due.
Liability to pay CGST/SGST
At the Time of Supply

4. Present Vs. Proposed Scenario
In the present indirect tax regime taxable events occur at different levels. Whereas under the proposed GST regime, all the major taxes levied under the indirect taxation i,e. Central excise, Service tax, VAT/CST etc. Would be subsumed under the ambit of GST. They all will loose their relevance & Supply will become the taxable event.
TAXABLE EVENT
GST
Present Indirect Taxation
Manufacturing of Goods
Supply of Goods and/or Services
Rendering of Services
Sale of Goods

5. Time of Supply of Goods (Section 12)
Scenario Time of Supply
General Provision Date of issue of Invoice OR
Last Date on which Invoice is required
to be issued
Date of Receipt of Payment }
Whichever earlier }
Reverse Charge Date of Receipt of Goods OR
Date of Payment
Date immediately after 30 Days from Date issue of Invoice
Date of Entry in Books of recipient
Whichever earlier

6. Time of Supply of Goods continued
Scenario Time of Supply
Supply of Voucher Date of issue of Voucher, if Supply is Identifiable OR
Date of Redemption of Voucher in all other cases
Residual In case of periodical return, the date of return file OR
Date of Payment of CGST/SGST

7. Special Notes
Note 1: An amount of up to Rs. 1,000 in excess of the invoice can be adjusted against any current/future invoice.
Note 2: Date of Receipt of payment will earlier of the date on which payment is entered in the books of accounts of the supplier or the date on which amount is credited to his bank account.
Note 3: Section 28 of the CGST/ IGST Act provides for the time limit (to be prescribed separately) within which an invoice will have to be raised by the supplier of Goods/ Services.

8. Time of Supply Of Services (Section 13)
Scenario Time of Supply General Provision Date of Invoice OR Last Date on which invoice is required to be issued under section 28 Date of Receipt of Payment }
Whichever earlier }
Reverse Charge Date of Payment OR
Date immediately after 60 Days from Date issue of Invoice
Date of Debit in Books of Account
Whichever earlier

9. Time of Supply Of Services continued
Scenario Time of Supply
Supply of Voucher Date of issue of Voucher, if Supply is Identifiable OR
Date of Redemption of Voucher in other cases
Residual In case of periodical return, the date of return filing OR
Date of Payment of CGST/SGST

10. Special Notes
Note 1: An amount of up to Rs. 1,000 in excess of the invoice can be adjusted against any current/future invoice.
Note 2: Date of Receipt of payment will earlier of the date on which payment is entered in the books of accounts or the date on which amount is credited to his bank account.
Note 3: In case of “Associated Enterprises”, where the supplier is located outside India, the Time of Supply will be the date of entry in the books of accounts of the recipient or the date of payment whichever is earlier.
Note 4: “Associated Enterprise” has the same meaning as assigned to it in section 92 of the Income Tax Act.

11. CA. Manoj Kumar Goyal
Partner
RHMS & Company
Chartered Accountants