Tage and the ₹4.2 lakh GST place-of-supply mismatch
Tage, 38, runs Ziro Valley Expeditions in Itanagar — boutique trekking for international clients. Bookings: Delhi, Mumbai, Bangalore. Tours happen in Arunachal Pradesh. He invoiced Voyages Durables (France operator) at Arunachal CGST+SGST on ₹15 lakhs. Voyages coded it as IGST internally. GST intelligence matched the filings. Mismatch flagged. ₹4.2 lakh demand arrived.
🚨 The problem
The officer said: Tage's GSTR-1 showed CGST+SGST. Voyages' GSTR-2A showed IGST. Either Tage invoiced wrong or Voyages coded wrong. The place-of-supply rule seemed ambiguous to Tage. What if ILP permit status changed the rule? What if serving multiple states triggered different rules?
🚀 How GabFORGE helped
An agent read the notice and the GST law:
🔍 Verified the rule: Section 12(3) place of supply = location where service is actually performed. Tage performed tours in Arunachal Pradesh.
💬 Translated the clarity: ILP is administrative, not tax-relevant. Permit status does not change place-of-supply determination.
📞 Connected the response: Your invoice is correct. Voyages' coding is their error. File response citing the regulation.
Tage filed within 24 days of 30. Tax office accepted his position. Voyages was asked to correct their GSTR-2A filing. No penalty.
🇮🇳 Why this matters
Tour operators in restricted-access states (Arunachal, Mizoram, Manipur) face unique GST problems. ILP creates legitimate regulatory complexity. But GST place of supply is simple: where the service happens. Reading this clearly prevents ₹4+ lakh exposure.
Place of supply is where service happens, not where customer sits. The rule is 12 years old. Most operators never read it.