GST-Time of Supply of Services

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GST implementation is rapidly moving forward with the government adhering to its self- imposed deadlines. In our all articles we just trying to breakdown GST provisions in short and try to analyse it. We already discussed “Time of Supply of Goods” in our previous article and I hope you all like it. So now we come up with our next article on “time of supply of services”.

As we already discussed the relevance of knowing “time of supply” in our previous article. So in this article, we are only going to discuss the provisions that GST act provides.

A) In Normal Case (Earlier of following) 

  1. The date of issue of Invoice.
  2. Last date of issuing invoice i.e within 30 days of provisioning of service.
  3. Date when payment is entered in the books of account of supplier.
  4. Date when payment is credited in suppliers bank account.

Now in proposed regime its going to be very difficult to track exact date when payment is entered in books of account.

B) Reverse charge 

  1. Date when payment is entered in the books of account of recipient.
  2. Date when payment is debited from the bank account of the recipient.
  3. Date immediately following 60 days from the date of issue of invoice by supplier.

Here it is important to note that if it is not possible to determine time of supply of services from above, the time of supply shall be the date of entry in the books of account of the recipient of supply.

C) Associated Enterprise

Proposed GST law provides for new provision for determining time of supply of service in case of associated enterprise.

  1. Date of entry in the books of recipient of supply.
  2. Date when payment is entered in the books of account of recipient.
  3. Date when payment is debited from recipient bank account.
  4. Date of payment.

D) Supply of Vouchers

  1. If supply Identifiable- Date of issue of Vouchers.
  2. In other cases- Date of redemption of Voucher.

E) Not able to determine time of supply of services from above 

  1. In case where periodical return has to filled- Date on which such return is to filled.
  2. In other cases- Date on which CGST/SGST paid.

F) Conclusion

After examining above provision accounted for determining “time of supply of services”, it seems that revised MGL does not provide any provision for determining time of supply of services in case of “continuous supply of services”. In my opinion this means that the general provision given for normal cases would apply or later they will provide by notification.

Hope you all find this article useful.Your feedback is important for us and we are looking for it.

For any clarification, please contact us at info@centrik.in

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