Passenger transportation service within India :
The place of supply of passenger transportation to
(a) a registered person, shall be the location of such person
(b) a person other than a registered person shall be the place where the passenger embarks on the conveyance for a continuous journey. If for future use, then as per residual provision in section 12(2)- section 12(9) of IGST Act.
“Conveyance” includes a vessel, aircraft and a vehicle – section 2(34) of CGST Act.
“Continuous journey” means a journey for which a single or more than one ticket or invoice is issued at the same time, either by a single supplier of service or through an agent acting on behalf of more than one supplier of service, and which involves no stop over between any of the legs of the journey for which one or more separate tickets or invoices are issued. – Explanation- For the purposes of this clause, ‘stopover’ means a place where a passenger can disembark either to transfer to another conveyance or break his journey for a certain period in order to resume it at a later point of time – section 2(3) of IGST Act.
Where the right to passage is given for future use and the point of embarkation is not known at the time of issue of right to passage, the place of supply of such service shall be determined on the basis of section 12(2) of IGST Act – proviso to section 12(9)(b) of IGST Act.
Return journey will be treated as a separate journey, even if right of passage for onward and return journey is issued at the same time – explanation to section 12(9) of IGST Act.