Invoice value applies for supply to related persons eligible for ITC

Last updated: 01 December 2025

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Quick Summary

This ruling clarifies GST valuation rules for supplies between related parties. For unrelated persons, the transaction value (price paid) applies. However, for supplies to related persons who are eligible for full input tax credit, the invoice value is considered the deemed value for GST purposes. Additionally, transportation services provided to unregistered persons are exempt from GST, provided consignment notes are not issued and responsibility for the goods is not assumed.

Court :
Andhra Pradesh AAR

Brief :
The Andhra Pradesh AAR in the matter of Sri Lakshmi Ganesh Cement and Iron General Stores [AAR No. 04/AP/GST/2025, order dated July 08, 2025] held that for supply of cement and iron to unrelated persons, the transaction value as per Section 15(1) of the CGST Act, 2017 applies; for supplies to related persons eligible for full input tax credit, the invoice value is deemed value of supply under Rule 28 of the CGST Rules, 2017; further, the registered person providing transportation services to unregistered persons is not liable to pay GST on the transportation charges, as such services are exempt under Serial No. 21A of Notification No. 12/2017-CT (Rate), as amended.

Citation :
AAR No. 04/AP/GST/2025, order dated July 08, 2025

Daily Limit Reached