Quick Answer: Which Date Determines GST?
Time of supply is the statutory point at which GST liability arises. It is not always the date on the invoice, and it is not always the date of payment.
1. Legal Framework – Sections 12, 13 & 14
| Provision | Subject | Core purpose |
|---|---|---|
| Section 12 | Time of supply of goods | Determines when GST on goods becomes payable. |
| Section 13 | Time of supply of services | Determines when GST on services becomes payable. |
| Section 14 | Change in rate of tax | Special matrix where the GST rate changes around the supply/invoice/payment dates. |
| Section 31 | Tax invoice timing | Important because Sections 12/13 refer to the invoice or the time by which it is required to be issued. |
| Section 15 | Value of supply | Determines the taxable value once time of supply is identified. |
2. Time of Supply of Goods – Section 12
2.1 Normal Forward-Charge Goods
For ordinary taxable goods, Section 12(2) generally uses the earlier of the date of issue of invoice/last date on which invoice is required to be issued and the date on which the supplier receives payment. citeturn0search1turn0search2
| Invoice / payment | Time of supply – normal goods |
|---|---|
| Invoice first, payment later | Invoice/last permissible invoice date, as applicable. |
| Payment first, invoice later | Payment date, subject to the statutory rule. |
| Invoice and payment same date | That date. |
2.2 Date of Receipt of Payment
Section 12 explains that the date of receipt of payment is the earlier of the date on which payment is entered in the supplier's books or the date on which it is credited to the supplier's bank account. citeturn0search1
2.3 Excess Payment up to ₹1,000
Section 12 contains a specific option for an amount received up to ₹1,000 in excess of the amount shown in the tax invoice, allowing the supplier to treat the invoice date as the time of supply for that excess amount.
2.4 Interest, Late Fee and Penalty
For an addition to the value of supply by way of interest, late fee or penalty for delayed payment of consideration, Section 12(6) places the time of supply on the date the supplier receives that addition in value. citeturn0search1
3. Time of Supply of Services – Section 13
Services require a different timing framework because invoice timing and the statutory invoice period are central to Section 13.
3.1 Where Invoice Is Issued Within the Prescribed Period
For the ordinary forward-charge service rule, time of supply is generally the earlier of the date of issue of invoice and receipt of payment.
3.2 Where Invoice Is Not Issued Within the Prescribed Period
Where the invoice is not issued within the prescribed period, Section 13 shifts the test to the date of provision of service or receipt of payment, as applicable. Therefore, delayed invoicing can create an earlier GST liability than the eventual invoice date.
3.3 Date of Receipt of Payment
For Section 13 purposes, payment is generally tested by the date it is entered in the supplier's books or credited to the bank account, whichever is earlier, subject to the statutory wording.
3.4 Associated Enterprise – Cross-Border Service Supplier
For specified supplies of services by an associated enterprise where the supplier is located outside India, Section 13 contains a special rule using the earlier of the recipient's book-entry date and payment date.
4. Reverse Charge – Time of Supply Is Different
RCM requires a separate analysis because the person paying GST is the recipient rather than the ordinary supplier.
4.1 RCM Goods
Section 12(3) uses the earliest of the date of receipt of goods, the payment date under the statutory book/bank test, and the date immediately following 30 days from the supplier's invoice/document date. If the time cannot otherwise be determined, the recipient's book-entry date becomes relevant. citeturn0search1turn0search2
4.2 RCM Services
Section 13(3) generally uses the earlier of the recipient's payment date and the date immediately following 60 days from the supplier's invoice/document date. If neither can determine the time, the recipient's book-entry date applies. For specified foreign associated-enterprise services, a special earlier-of-books/payment rule applies. citeturn0search1
| RCM supply | Key timing trigger |
|---|---|
| Goods | Receipt of goods / payment / 30-day invoice rule, whichever is earliest under Section 12(3). |
| Services | Payment / 60-day invoice rule, whichever is earlier under Section 13(3). |
| Foreign associated enterprise services | Recipient books/payment special rule. |
5. Continuous Supply – Milestones Matter
5.1 Continuous Supply of Goods
Where goods are supplied continuously and involve periodic statements of accounts or successive payments, Section 31's invoice provisions and Section 12 timing must be read together. The contractual milestone and payment arrangement should be mapped to the tax invoice requirement.
5.2 Continuous Supply of Services
For continuous services, the point at which payment becomes due under the contract, the invoice date and the event specified in the contract can affect time of supply. The finance team should maintain a milestone calendar rather than waiting for bank payment.
6. Advances, Payment and Accounting Entries
6.1 Advance for Goods
For ordinary goods, the current Section 12(2) framework should be applied carefully rather than importing the old pre-GST practice or assuming every advance creates the same result as an advance for services. The exact supply and statutory provision should be documented.
6.2 Advance for Services
For services, receipt of advance/payment can become a time-of-supply event under the applicable Section 13 rule. Finance teams should therefore reconcile customer advances with GST liability rather than treating the advance as a pure balance-sheet item in every case.
6.3 Payment Date – Books vs Bank
When the Act uses the payment date, the statutory definition can make the earlier of book entry and bank credit relevant. The date shown by a bank statement alone should not automatically be used without checking the statutory explanation.
7. Special Situations
GST on the additional amount follows the specific time-of-supply rule when the supplier receives the interest/late fee/penalty.
Accounting provision does not automatically equal GST time of supply. Check whether a supply has occurred and which statutory trigger applies.
Service completion and invoice timing can create GST liability before the invoice is booked.
Map certification/milestones, invoice date and payment separately.
Determine whether the amount is an advance against taxable service and apply the current time-of-supply provisions.
Retention does not automatically decide time of supply; examine the contractual milestone and invoice rules.
RCM time-of-supply rules can apply to imported services; payment and the 60-day invoice rule are important.
Associated-enterprise provisions can override the ordinary timing framework.
The earlier voucher-specific provisions in Sections 12/13 were changed by Finance (No. 7) Act, 2025; verify the current treatment rather than using old GST articles.
Determine whether the additional amount is a new supply, additional consideration or a separate statutory event.
8. Change in GST Rate – Section 14
Section 14 overrides the ordinary Section 12/13 rules when there is a change in the rate of tax. It examines whether the supply occurred before or after the rate change and whether invoice and payment occurred before or after it. citeturn1search0
8.1 The Three Dates
| Supply timing | Invoice | Payment | Section 14 result |
|---|---|---|---|
| Before rate change | After | After | Earlier of invoice/payment. |
| Before rate change | Before | After | Invoice date. |
| Before rate change | After | Before | Payment date. |
| After rate change | Before | After | Payment date. |
| After rate change | Before | Before | Earlier of invoice/payment. |
| After rate change | After | Before | Invoice date. |
Example
Suppose a service is supplied before a rate change. The invoice is issued after the rate change and payment is received before the rate change. Section 14's specific matrix can make the payment date the time of supply, meaning the earlier rate may apply depending on the complete statutory facts.
9. Construction, EPC, Mining, AMC & Year-End Projects
| Situation | Time-of-supply control |
|---|---|
| RA bill certified in March, paid in May | Do not wait for May automatically; determine service invoice/time-of-supply rules. |
| Work completed but invoice delayed | Check Section 13 and Section 31; delayed invoicing can create earlier liability. |
| Retention released after defect period | Do not equate retention release date with the entire service's time of supply without analysing the contract. |
| Mobilisation advance | Track separately from final invoice and apply current advance/payment provisions. |
| Annual AMC | Determine whether it is a continuous service and identify invoice/payment/milestone events. |
| Electricity/utilities | Identify whether the transaction is taxable supply and determine the applicable timing provision. |
| Imported consultancy | Review RCM time-of-supply rules, especially the 60-day invoice test. |
| Foreign related-party service | Check the associated-enterprise rule under Section 13. |
10. GSTR-1, GSTR-3B & Month-End Controls
Once time of supply is determined, the finance team should ensure that the tax is reported in the correct return period. The accounting period and GST tax period are not necessarily identical when invoices, payments or RCM events cross month-end.
| Month-end question | Control |
|---|---|
| Was service supplied before month-end? | Check Section 13 even if invoice/payment is pending. |
| Was advance received? | Check goods/services distinction and applicable rule. |
| Is RCM applicable? | Apply recipient-side time-of-supply rule. |
| Did GST rate change? | Apply Section 14 matrix. |
| Is invoice delayed? | Check statutory invoice period and time of supply. |
| Is the amount only a provision? | Do not book GST merely from the accounting provision; first establish the statutory trigger. |
11. 36 Practical Time-of-Supply Cases
| # | Scenario | Core treatment |
|---|---|---|
| 1 | Goods invoice 10 April, payment 20 April | Normal goods: earlier relevant date under Section 12. |
| 2 | Goods payment 5 April, invoice 15 April | Payment can trigger earlier time of supply under the normal rule. |
| 3 | Service invoice 10 April, payment 20 April | Normal service rule generally uses earlier invoice/payment. |
| 4 | Service supplied, invoice issued late | Apply Section 13 late-invoice rule; liability may arise before invoice date. |
| 5 | Government contractor bill paid after 3 months | Payment delay does not automatically defer GST liability. |
| 6 | RCM goods received before invoice | Receipt date can become the time of supply. |
| 7 | RCM goods invoice old, payment later | Apply 30-day test and compare all statutory dates. |
| 8 | RCM service payment before 60 days | Payment date can trigger earlier liability. |
| 9 | RCM service invoice 1 January, no payment | Test the date immediately following 60 days. |
| 10 | Foreign related-party service booked before payment | Apply special associated-enterprise rule. |
| 11 | Customer advance for service | Check Section 13 payment/advance treatment. |
| 12 | Customer advance for goods | Apply current Section 12 goods provisions rather than assuming service treatment. |
| 13 | Interest received on delayed customer payment | GST time of supply for the additional value is linked to receipt of that addition. |
| 14 | March service invoice raised in April | Check statutory invoice timing and Section 13. |
| 15 | March RA bill certified in April | Identify the actual service/invoice event and applicable continuous-service rule. |
| 16 | Retention released after defect period | Retention release is not automatically the original service time-of-supply date. |
| 17 | Rate increases 1 July; supply before 1 July | Apply Section 14 based on invoice/payment timing. |
| 18 | Rate decreases 1 July; invoice before, payment after | Use Section 14 matrix. |
| 19 | Supply before rate change, invoice after, payment before | Payment date can determine time under Section 14. |
| 20 | Supply after rate change, invoice before, payment after | Payment date can determine time under Section 14. |
| 21 | Supply after rate change, invoice after, payment before | Invoice date can determine time under Section 14. |
| 22 | Bank credit occurs more than four working days after rate change | Apply Section 14's payment-date proviso. |
| 23 | Annual AMC invoiced upfront | Analyse service timing, continuous supply and invoice/payment rules. |
| 24 | Monthly SaaS subscription | Identify recurring/continuous service and invoice/payment timing. |
| 25 | Annual software licence | Determine actual supply and invoice/payment terms. |
| 26 | Mining contractor measured monthly | Map measurement/certification, invoice and Section 13. |
| 27 | Construction work completed but invoice pending | Accounting delay does not necessarily delay GST liability. |
| 28 | Year-end legal-fee provision | Provision alone does not determine GST time of supply. |
| 29 | Year-end audit-fee provision | Check actual service and invoice/payment timing. |
| 30 | Import of consultancy services | Apply RCM service time-of-supply rules. |
| 31 | Foreign group company charges management fee | Check associated enterprise rule and RCM. |
| 32 | Price escalation approved later | Identify when additional consideration becomes taxable under the actual supply arrangement. |
| 33 | Late-payment penalty charged to customer | Apply the specific interest/late-fee/penalty time rule if it forms part of value. |
| 34 | Voucher issued after 1 October 2025 | Do not rely on the old Section 12(4) voucher timing rule; it was omitted effective 1 October 2025. |
| 35 | Invoice entered in books but bank credit later | Check statutory definition of payment date. |
| 36 | Invoice and payment straddle FY-end | Determine time of supply first; financial year accounting alone does not decide GST liability. |
12. Accounting Entries – Practical Examples
Forward-Charge Service Invoiced Before Payment
| Particulars | Debit (₹) | Credit (₹) |
|---|---|---|
| Customer Receivable | 1,18,000 | — |
| To Service Revenue | — | 1,00,000 |
| To Output GST | — | 18,000 |
RCM Service Liability
| Particulars | Debit (₹) | Credit (₹) |
|---|---|---|
| RCM Expense / Relevant Account | 1,00,000 | — |
| To Supplier / Accrued Liability | — | 1,00,000 |
| Input CGST/SGST or IGST, where eligible | 18,000 | — |
| To RCM GST Payable | — | 18,000 |
13. GST Audit Questions on Time of Supply
- How does the ERP determine GST tax period?
- Are invoice date and supply date separately captured?
- How are delayed invoices identified?
- How are customer advances reconciled?
- How are RCM liabilities identified from payment/book-entry data?
- How is the 30-day RCM goods rule monitored?
- How is the 60-day RCM services rule monitored?
- How are foreign related-party services monitored?
- How are continuous supplies tracked by milestone?
- How are March unbilled services reviewed?
- How are year-end provisions distinguished from actual taxable supplies?
- How are rate-change transactions tested under Section 14?
- How is the four-working-day payment proviso handled for rate changes?
- How are interest/late-fee additions tracked?
- How are GSTR-1 and GSTR-3B reconciled with time-of-supply workings?
14. 15 Common Mistakes
15. Time-of-Supply Decision Matrix
| Question | What to check |
|---|---|
| Goods or services? | Start with Section 12 or Section 13. |
| Forward charge or RCM? | If RCM, use the special recipient-side timing rule. |
| Is invoice issued within prescribed time? | If not, Section 13 service timing can shift to another trigger. |
| Was payment received? | Check the statutory definition of payment date. |
| Is it a continuous supply? | Map contractual milestones and invoice/payment events. |
| Is there a rate change? | Stop and apply Section 14. |
| Is it foreign related-party service? | Check the special associated-enterprise provision. |
| Is it year-end provision? | Separate accounting accrual from GST statutory event. |
| What tax period? | Report GST in the period determined by time of supply. |
16. Month-End & Year-End Time-of-Supply Checklist
| Control | Done? |
|---|---|
| All invoices issued within statutory time | ☐ |
| Customer advances reviewed | ☐ |
| Unbilled services reviewed | ☐ |
| RCM goods 30-day tracker checked | ☐ |
| RCM services 60-day tracker checked | ☐ |
| Foreign related-party services reviewed | ☐ |
| Continuous contracts/milestones reviewed | ☐ |
| Rate-change transactions tested | ☐ |
| Interest/late-fee additions reviewed | ☐ |
| GSTR-1 and GSTR-3B reconciled | ☐ |
17. Frequently Asked Questions
What is time of supply?
It is the statutory point at which GST liability arises for the supply.
Does invoice date always determine GST?
No. Sections 12, 13 and 14 contain different timing rules, including payment, RCM, continuous supply and rate-change provisions.
Does payment always determine GST?
No. For ordinary forward-charge goods and services, invoice-related triggers can arise earlier.
Does a year-end provision create GST liability?
Not merely because an accounting provision was posted. The actual supply and applicable statutory time-of-supply trigger must be established.
What is the RCM time limit for goods?
Section 12(3) includes receipt of goods, payment and the date immediately following 30 days from the supplier's invoice/document, with the earliest applicable date controlling under the statutory rule.
What is the RCM time limit for services?
Section 13(3) generally uses payment or the date immediately following 60 days from the supplier's invoice/document, whichever is earlier, subject to its special provisions.
What happens when GST rate changes?
Section 14 overrides Sections 12 and 13 and applies a specific matrix based on supply, invoice and payment dates relative to the rate-change date.
How is payment date determined?
The statutory explanation generally uses the earlier of the date payment is entered in the supplier's books and the date it is credited to the bank account.
Are voucher time-of-supply rules unchanged?
No. The current Section 12 text records the omission of the earlier voucher-specific provision with effect from 1 October 2025. Businesses should use current law rather than older summaries.
Key Takeaway
GST Legal Reference Map
Time of supply of goods.
Time of supply of services.
Change in rate of tax.
Tax invoice timing.
Value of taxable supply.
Sections 12(3) and 13(3).
Read Sections 12/13 with invoice provisions.
Section 14 before/after analysis.
Section 12(4) omitted effective 1 October 2025.