The Central Board of Indirect Taxes & Customs (“CBIC”) vide its Press Release dated November 11, 2018 has issued a advisory for UIN Entities to claim refund of GST paid, as one of the conditions for claiming refund is to file invoice level data in FORM GSTR-11 as per Rule 82 of the CGST Rules, 2017. However, many UIN entities while filling invoice data have been reporting their place of supply as the State where they are registered instead of the place of supply as reflected in the invoice.
For example, it was observed that Embassies registered in Delhi have been consistently declaring their place of supply as “New Delhi”, even on hotel service consumed in the State of Maharashtra for which the place of supply is Maharashtra.
Therefore, it is advised that while reporting the “place of supply” and charging of CGST / SGST or IGST on an invoice, the details shall be exactly as per the details mentioned in the invoice issued by the supplier of goods or services. Wrong reporting of invoice level data in FORM GSTR-11 or in the statement of invoice submitted may lead to delay in processing / rejection of refund claims.