Ramesh, a registered supplier in Delhi, enters into a contract to supply and install an air conditioning system in a Royal Garden Hotel located in Punjab. The air conditioning system is assembled at the site using variou

CS Executive · Tax Laws and Practice · PYQS · December 2025
Ramesh, a registered supplier in Delhi, enters into a contract to supply and install an air conditioning system in a Royal Garden Hotel located in Punjab. The air conditioning system is assembled at the site using various components, and installation requires civil work, wiring, and testing. The total value of the contract is ₹ 12,00,000. Accountant of Ramesh argues that since he is supplying goods (air conditioning units), the supply should be treated as an Inter-State supply of goods from Delhi to Punjab, and IGST should be charged. As a tax consultant you are required to determine whether this transaction is a supply of goods or supply of services ? Also determine the place of supply and nature of the supply for the above transaction under GST Law.

Answer & Explanation:

(i) Nature of Supply: Goods or Services? This is a works contract involving supply of goods along with installation, testing, and civil work, which makes it a composite supply. As per Section 2(119) of the CGST Act, a works contract involving immovable property is treated as supply of services. Hence, this is a supply of service. (ii) Place of Supply: As per Section 12(3)(a) of the IGST Act, when the supply involves immovable property, the place of supply is the location of the immovable property. Here, the hotel (immovable property) is located in Punjab. So, the place of supply is Punjab. (iii) Nature of Supply and Tax to be Charged: Mr. Ramesh is registered in Delhi and the place of supply is Punjab. Since supplier and place of supply are in different States, this is an inter-State supply. Therefore, IGST is chargeable.

Topics: GST

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