Sections 10(1)(c), (d), (e) and 11: The Remaining Goods Rules

Sections 10 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.

Four short rules covering the situations the movement-based default does not reach — and one of them, assembly at site, decides a great deal of project work.

10(1)(c): where the supply does not involve movement, the place of supply is the location of the goods at the time of delivery to the recipient. 10(1)(d): where goods are assembled or installed at site, the place of supply is the place of such installation or assembly. 10(1)(e): where goods are supplied on board a conveyance — a vessel, aircraft, train or motor vehicle — the place of supply is the location at which such goods are taken on board. 10(2): where the place of supply cannot be determined, it shall be determined in such manner as may be prescribed. 11(a): goods imported into India — the location of the importer. 11(b): goods exported from India — a location outside India.

Clause (c): no movement

When it applies: the supply does not involve movement of goods, whether by the supplier or the recipient.

The place of supply: where the goods are at the time of delivery to the recipient.

The situations:

• goods sold where they stand — machinery sold in situ, stock sold at a warehouse without moving;
• a sale of goods already in the buyer's possession — for example on the exercise of a purchase option at the end of a lease;
• a transfer effected by handing over keys or documents without any physical movement.

And note clause (ca) overrides it for supplies to an unregistered person, from 01.10.2023. Section 10(1)(ca) →

Clause (d): assembly or installation at site

"Where the goods are assembled or installed at site, the place of supply shall be the place of such installation or assembly."

This is the clause that governs plant and equipment supplied for a project. Where machinery is despatched in parts and assembled or installed at the customer's site, the place of supply is the site, not where the movement terminated and not the customer's registered address.

Two practical consequences.

A supplier delivering to a site in another State makes an inter-State supply, determined by the site's location — and the customer must be registered there, or hold a registration whose GSTIN is used, for the credit to be usable.

The clause has to be distinguished from a works contract. Where the contract is for works contract service — an immovable-property outcome — it is a supply of services under Schedule II paragraph 6(a), and the place of supply is determined by s.12(3) or s.13(4) as a service in relation to immovable property, not by s.10(1)(d). The dividing line is whether what is supplied is goods that happen to be installed or a works contract. Works contract classification →

The contract drafting therefore matters, because the same commercial arrangement can be structured either way and the place-of-supply consequence differs.

Clause (e): goods supplied on board a conveyance

"Where the goods are supplied on board a conveyance, including a vessel, an aircraft, a train or a motor vehicle, the place of supply shall be the location at which such goods are taken on board."

The test is where the goods are loaded, not where they are sold.

So goods loaded onto an aircraft at Delhi and sold to a passenger over Nagpur have a place of supply in Delhi.

Compare the services rule. Section 12(10) places services supplied on board a conveyance at the first scheduled point of departure of that conveyance for the journey — a different test producing a different answer on the same flight. So a caterer selling a meal as goods and a supplier providing a service on board are determined by different rules. Section 12(9) and (10) →

Section 10(2): where it cannot be determined

"Where the place of supply of goods cannot be determined, the place of supply shall be determined in such manner as may be prescribed."

A residual power. In practice the clauses in s.10(1) cover the field, and s.10(2) is rarely invoked — but it is worth knowing that the Act contemplates prescription rather than leaving a gap.

Section 11: imports and exports

Two clauses, each of one line.

11(a) — imported into India: the location of the importer.

Why it matters. The place of supply being the importer's location makes an import an inter-State supply under s.7(2) of the IGST Act, on which IGST is levied and collected under s.3 of the Customs Tariff Act, 1975 at the point of importation, along with the customs duties.

And the credit follows the importer. IGST paid on import is credited to the importer's electronic credit ledger against the GSTIN on the bill of entry — which is why the GSTIN on the bill of entry must be the registration that will use the credit. An import cleared under one State's GSTIN and consumed in another leaves the credit stranded in the first. Section 16(2) →

11(b) — exported from India: a location outside India.

Which is what makes an export a zero-rated supply. Section 2(5) of the IGST Act defines "export of goods" as taking goods out of India to a place outside India, and s.16 makes it zero-rated — with the two routes of LUT without payment and with payment of IGST followed by refund. Rule 96 → Rule 96A →

Note what s.11(b) does not require. It does not import the conditions that apply to an export of services under s.2(6) — receipt of payment in convertible foreign exchange, and the supplier and recipient not being merely establishments of a distinct person. Goods are simpler: they either leave India or they do not. Export of services →

Key takeaways

• Clause (c) — no movement: the location of the goods at delivery.
• Clause (d) — assembly or installation at site: the site, which governs project equipment supplies.
• Distinguish goods installed from a works contract, which is a service determined under s.12(3) or s.13(4).
• Clause (e) — on board a conveyance: where the goods are taken on board, unlike the services rule in s.12(10).
• Section 11(a) — import: the location of the importer, which drives the GSTIN on the bill of entry.
• Section 11(b) — export: a location outside India, which is what makes it zero-rated.

Read next

• Section 10(1)(a): Where the Movement Terminates for Delivery
• Section 10(1)(ca): Supplies to Unregistered Persons
• Export of Services: The Five Conditions in Section 2(6)
• Works Contract vs Composite Supply: The Classification Test

Disclaimer: Positions stated as on 5 September 2026, based on the IGST Act as amended to 31 March 2026 (ICAI Bare Law, 12th edition).