Kishore, a registered service provider entered into an agreement of provision of service with one of his clients. The full payment was received in advance by cheque on 15.09.2024 which was entered in the books on 16.09.2

As per section 14(b) of CGST Act, 2017, in case the goods or services or both have been supplied after the change in rate of tax, where the payment is received after the change in rate of tax but the invoice has been issued prior to the change in rate of tax, the time of supply shall be the date of receipt of payment; or where the invoice has been issued and payment is received before the change in rate of tax, the time of supply shall be the date of receipt of payment or date of issue of invoice, whichever is earlier; or where the invoice has been issued after the change in rate of tax but the payment is received before the change in rate of tax, the time of supply shall be the date of issue of invoice In the present facts, the payment is received on 16.9.2024 i.e. before the change of rate of tax but completion of supply of service occurred on 21.10.2024 and issue of invoice has occurred on 25.11.2024 both after the change of rate of tax. Hence considering the above provision section 14(b)(iii) time of supply shall be date of invoice i.e., 25.11.2024. Hence, Mr. Kishore's contention is incorrect and applicable rate will be 12%.