PRESS RELEASE
5 January 2026

IGST, And Not CGST, Is Payable When Goods Handed Over To Common Carriers For Transportation To Another State

LS
Lakshmikumaran & Sridharan

Contributor

Lakshmikumaran & Sridharan (LKS) is a premier full-service Indian law firm specializing in areas such as corporate & M&A/PE, dispute resolution, taxation and intellectual property. The firm, through its 14 offices across India works closely on litigation and commercial law matters, advising and representing clients both in India and abroad.
In a case where the assessee handed over the goods to the common carrier for the purpose of delivery to the ultimate destination outside the State of Karnataka, the Karnataka High Court has held...
India

In a case where the assessee handed over the goods to the common carrier for the purpose of delivery to the ultimate destination outside the State of Karnataka, the Karnataka High Court has held that the supply of goods was inter-State supply and not intra-State supply so as to attract CGST/KGST. The assessee was represented by Lakshmikumaran & Sridharan Attorneys here.

Relying upon Section 10(1)(a) of the IGST Act, the Court in Toyota Kirloskar Motor Pvt. Ltd. v. Union of India noted that the movement of the goods terminates for handing over delivery to the recipient not when the goods are handed over to the ‘common carrier’ but only when the goods reach the destination.

The High Court in this decision dated 27 November 2025 thus held that the liability to pay IGST under Section 10(1)(a) would arise when the movement of the goods terminated for delivery to the recipient at various places outside Karnataka.

Contributor

Lakshmikumaran & Sridharan (LKS) is a premier full-service Indian law firm specializing in areas such as corporate & M&A/PE, dispute resolution, taxation and intellectual property. The firm, through its 14 offices across India works closely on litigation and commercial law matters, advising and representing clients both in India and abroad.

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