As per section 12(3) time of supply of goods for recipient when the supply attracts reverse charge shall be the
Give this collapsible section a title
the date of payment as entered in the books of account of the recipient or the date on which the payment is debited in his bank account, whichever is earlier; or
the date immediately following thirty days from the date of issue of invoice or any other document, by whatever name called, in lieu thereof by the supplier
Provided that where it is not possible to determine the time of supply under clause (a) or clause (b) or clause (c), the time of supply shall be the date of entry in the books of account of the recipient of supply.
There are four dates that we need to consider for determining time of supply under reverse charge for goods
Date of receipt of goods
The date of payment as entered in the books of accounts of the recipient
Date on which payment is debited in the bank account of the recipient
The date immediately following thirty days from the date of issuance of the invoice
Date of Receipt of Goods :- 10th June 2025
Date of Payment Entered in Books :- 20th June 2025 Date of Bank Debit :- 22nd June 2025
Invoice Date :- 1st June 2025
30 Days from Invoice Date :- 1st July 2025
Clause (a) :- 10th June (receipt)
Clause (b) :- earlier of 20th June or 22nd June = 20th June Clause (c) :- 1st July
Time of Supply = earliest of 10th June, 20th June, 1st July = 10th June 2025
Date of Receipt of Goods :- 15th August 2025 Date of Payment in Books :- 5th August 2025
Date of Bank Debit :- 6th August 2025 Invoice Date :- 1st August 2025
30 Days from Invoice Date :- 31st August 2025 Clause (a): 15th August
Clause (b): earlier of 5th or 6th August = 5th August Clause (c): 31st August
Time of Supply = earliest of 15th Aug, 5th Aug, 31st Aug = 5th August 2025
Date of Receipt of Goods: 5th July 2025 Date of Payment: Not yet paid
Invoice Date: 15th June 2025
30 Days from Invoice Date: 15th July 2025 Clause (a): 5th July
Clause (b): No payment - Not Applicable Clause (c): 15th July
Time of Supply = earliest of 5th July and 15th July = 5th July 2025
The amended section is as under
In case of supplies in respect of which tax is paid or liable to be paid on reverse charge basis, the time of supply shall be the earlier of the following dates, namely:-
the date of payment as entered in the books of account of the recipient or the date on which the payment is debited in his bank account, whichever is earlier; or
the date immediately following sixty days from the date of issue of invoice or any other document, by whatever name called, in lieu thereof by the supplier, in cases where invoice is required to be issued by the supplier; or
the date of issue of invoice by the recipient, in cases where invoice is to be issued by the recipient. Provided that where it is not possible to determine the time of supply under clause (a) or clause(b) or clause (c), the time of supply shall be the date of entry in the books of account of the recipient of supply :-
Provided further that in case of supply by associated enterprises, where the supplier of service is located outside India, the time of supply shall be the date of entry in the books of account of the recipient of supply or the date of payment, whichever is earlier.
The Finance Act, 2024 has brought clarity and alignment in the determination of time of supply for services under reverse charge, especially in the context of self-invoicing and associated enterprises. As per the amended Section 13(3), the time of supply for services taxable under reverse charge shall be earliest of the following :-
Clause (a)
- Date of Payment :-
This refers to the earlier of:
The date of entry of payment in the books of account of the recipient, or
The date on which payment is debited in the bank account.
Clause (b)
- 60 Days from Invoice :-
The date immediately following 60 days from the invoice date issued by the supplier (where the supplier is required to issue an invoice).
This replaces the earlier 60-day benchmark with a more structured application, avoiding interpretational delays.
Clause (c)
- Date of Recipient's Invoice:
Where the recipient is required to issue an invoice (i.e. in case of unregistered supplier, or as covered under Section 31(3)(f)), the date of such self-invoice shall be the time of supply.
This clause directly links with Rule 47A (inserted vide Notification No. 20/2024-CT dated 8th October 2024) which requires the recipient to issue the self-invoice within 30 days from the date of receipt of the service.
Proviso 1 - Fallback Provision :
If none of the above clauses (a), (b), or (c) can be applied due to absence of payment or invoice, then the date of entry in the books of account of the recipient shall be treated as the time of supply.
Proviso 2 - Associated Enterprises (Import of Services) :
In case of associated enterprises, where the supplier is located outside India, the time of supply shall be the earlier of :-
The date of payment, or
The date of entry in the books of the recipient.
This ensures timely taxation of cross-border services between associated enterprises, which might otherwise escape the tax net due to non-issuance of formal invoices or delayed payments.
The amendment to Section 31(3)(f) (via Finance Act 2024) and the insertion of Rule 47A have made it mandatory for a registered person liable to pay tax under RCM to issue a self-invoice within 30 days from the receipt of supply (as discussed earlier)
Clause (c) of Section 13(3) specifically recognizes this situation by treating the date of issue of self-invoice as the time of supply where applicable.
This ensures consistency between invoice issuance and tax payment timelines, preventing delayed availment of input tax credit or deferred compliance.
Date of receipt of service: 10th July 2025 Invoice by unregistered supplier: Not applicable Self-invoice issued by recipient: 5th August 2025 Payment made on: 18th August 2025
Payment debited in bank: 19th August 2025 Entry in books: 25th August 2025
Here, clause (c) applies (self-invoice issued by recipient), so time of supply = 5th August 2025.