GST Context

• Refers to situations where a supply is considered received even without physical delivery
  
• Legal fiction created to trigger tax liability or ITC eligibility
  
• Important for accounting, valuation, and compliance
  
• Covers cases of delivery on behalf of recipient, job work, or third-party delivery
  
• Governed by Section 31, 16 and relevant GST rules
  

Scenarios Where Deemed Receipt Applies

• Delivery to a third party on instruction of buyer
  
• Movement of goods to job worker with return expected later
  
• Advance payment received for services (time of supply rules)
  
• Transfer of title or documents of title before physical receipt
  
• Stock transfer between branches (distinct persons under GST)
  

Importance in ITC Claims

• ITC can only be claimed after goods are received by the recipient
  
• If goods are delivered in batches, ITC is available after last lot
  
• Services deemed received on invoice and payment basis
  
• Exceptions exist for goods delivered to agent or third-party recipient
  
• Deemed receipt enables ITC even without physical receipt in some cases
  

Impact on Invoicing and Returns

• Supplier must raise invoice based on deemed supply date
  
• Tax liability arises as per time of supply provisions
  
• GST returns must reflect supply and tax payment accordingly
  
• Buyer can claim ITC only after deemed receipt and compliance
  
• Mismatches may lead to notices or ITC reversal
  

Compliance Considerations

• Clear agreements and instructions for third-party delivery
  
• Transport documents must mention delivery address and consignee
  
• Goods must be received within 180 days for ITC retention
  
• Deemed supply affects timing of tax liability, not commercial ownership
  

Maintain delivery challans and endorsement for job work and agents