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GST Law

Value of Supply — Section 15 CGST Act & Valuation Rules

Value of Supply determines the taxable base on which GST is computed. Section 15 of CGST Act defines what is included and excluded, while Rules 27–35 handle special cases like related parties, agents, forex, insurance, and pure agents. Incorrect valuation = incorrect GST = audit risk.

Core Section
Section 15
Valuation Rules
Rules 27–35
Inclusions
6 Items
Exclusions
4 Items

Components of Value of Supply (Section 15)

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Transaction Value

Included

Price actually paid or payable for the supply, where supplier and recipient are not related and price is the sole consideration

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Taxes/Duties/Cess (other than GST)

Included

Any amount of duty, fee, cess charged under any law other than GST — e.g., Excise (on tobacco), Municipal tax

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Amount payable by recipient on behalf of supplier

Included

Any expense incurred by recipient but payable by supplier — e.g., commission, packing, transport arranged by recipient but charged to supplier

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Incidental expenses

Included

Commission, packing, loading/unloading, insurance, and similar charges charged by the supplier to the recipient

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Interest/late fee/penalty

Included

Interest or late fee or penalty for delayed payment of consideration for the supply

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Subsidies (linked to price)

Included

Subsidies directly linked to the price — e.g., government subsidy to reduce selling price of fertiliser. Exception: subsidies from government NOT linked to price are excluded

Discount before or at time of supply

Excluded

Discounts given before or at the time of supply and recorded in the invoice are deductible from the value

Discount after supply (conditional)

Excluded

Post-supply discounts allowed ONLY if: (a) established by agreement at or before time of supply, (b) linked to specific invoices, and (c) recipient has reversed proportionate ITC

Deposit refunded

Excluded

Refundable deposits are NOT included in value. However, if deposit is applied toward consideration, it becomes taxable at that point

GST amount

Excluded

CGST, SGST, IGST, and Compensation Cess amounts are NOT included in the value of supply (tax is calculated on the value, not on itself)

Valuation Rules (Rules 27–35 CGST Rules)

Rule 27

Supply between related persons or distinct persons

Open market value; or value of like kind/quality supply; or 110% of cost of production/provision; or value determined by residual method

Rule 28

Supply through agents

Open market value; or 90% of price charged by agent to the customer

Rule 29

Supply of goods for repacking and labelling

Open market value or 110% of manufacturing cost

Rule 30

Supply of goods made/provided through agents

Open market value of like goods; failing which, 90% of the final selling price to unrelated buyer

Rule 31

Residual method

When value cannot be determined by Rules 27-30: use reasonable means consistent with GST Act principles. Cost + 10% markup as a fallback

Rule 32

Specific supplies — purchase/sale of foreign currency, booking of airline tickets, life insurance, second-hand goods

Special computation methods prescribed for each scenario — e.g., forex: lesser of 1% of gross amount or ₹250 for amounts up to ₹1 lakh

Rule 33

Pure agent exclusion

Expenditure incurred by supplier as pure agent is excluded from value, provided: written authority exists, supplier acts as pure agent, and the amount is separately indicated in invoice

Rule 35

Government notified value

Value of supply determined by the government through notification for specific goods/services — e.g., lottery, betting, gambling

Value of Supply FAQs

What is 'transaction value' under GST?

Transaction value is the price actually paid or payable for supply of goods/services, where the supplier and recipient are NOT related and price is the SOLE consideration. It includes all amounts charged — e.g., packing, transport, insurance. If conditions are not met (related parties, non-monetary consideration), valuation rules under Chapter IV of CGST Rules apply.

Are discounts deductible from GST value?

Yes, but with conditions. Pre-supply discounts (recorded on invoice at time of supply) are fully deductible — just reduce the invoice value. Post-supply discounts (volume discounts, year-end rebates) are deductible ONLY if: (1) the discount was known/agreed before or at time of supply, (2) it can be linked to specific invoices, and (3) the recipient reverses proportionate ITC. If any condition fails, the discount cannot reduce GST value.

How is GST calculated for related party transactions?

Under Rule 27, for supply between related persons (or distinct persons like branches): (1) Use open market value; if not available, (2) Use value of supply of like kind and quality; if not available, (3) Use 110% of cost of production/provision (for goods) or cost of provision (for services); if none work, (4) Use residual method under Rule 31. For supply of goods through agent, Rule 28 applies (90% of agent's selling price or open market value).

Is freight/transport included in value of supply?

If the supplier charges freight/transport to the buyer as part of the supply contract (e.g., CIF delivery), it is included in the value of supply and taxed at the same GST rate as the goods. However, if transport is arranged separately by the buyer (FOB/ex-works), it is NOT part of the goods' value — the transport service is separately taxed at the applicable rate for GTA (Goods Transport Agency) services.

What is 'pure agent' concept and how does it reduce GST?

Under Rule 33, a pure agent incurs expenditure on behalf of the recipient (not the supplier). If the supplier acts as a 'pure agent' for certain expenses — e.g., a customs broker paying customs duty on behalf of the importer — those amounts are excluded from the supply value, provided: (a) written authority from recipient, (b) supplier doesn't hold any title/interest, (c) amount shown separately on invoice. This legitimately reduces the GST base.

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