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.




