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When you sell something, GST is charged on the value of supply. Most of the time, that's simply the price the buyer pays — called the transaction value under Section 15 of the CGST Act. But what if the buyer pays partly in goods? Or the buyer and seller are relatives fixing a cozy low price? That's exactly when the CGST (Determination of Value of Supply) Rules, 2017 (Rules 27–35) kick in — they are the backup valuation mechanism.

Think of these rules as a waterfall: you only move to the next rule when the previous one fails. Rule 27 applies when consideration is not wholly in money. First try the open market value (OMV) — what an unrelated buyer would pay in cash for the same supply. If OMV isn't available, add the cash part and the money-equivalent of the non-cash part. Still stuck? Jump to Rules 30 or 31. Rule 28 covers supplies between related persons or distinct persons (e.g., Delhi HO to Mumbai branch). Use OMV — but exam favourite alert: if the recipient is eligible for full Input Tax Credit (ITC), even the invoice value is acceptable. Rule 29 covers supply through an agent: value is either OMV at the agent's place, OR 90% of the price the agent charges to the end customer — supplier's choice. Rule 30 is the clean, exam-friendly cost-based method: Value = Cost of production or acquisition + 10%. Use this when Rules 27–29 don't work. Rule 31 is the last resort — any reasonable method consistent with Section 15 principles.

Three special rules you must not skip: Rule 32 covers specific transactions — money changers (forex), travel agents, second-hand goods dealers, and tokens/vouchers each have tailored valuation. Rule 33 deals with the pure agent — if a supplier incurs costs purely on behalf of the recipient (like customs duty paid on their behalf), those reimbursements are excluded from the value of supply, provided specific conditions are met. Rule 35 is used when the price is GST-inclusive: back-calculate as Value = (Gross Amount × 100) ÷ (100 + GST rate%). This topic is examined frequently as a 5–8 mark scenario question where you must identify which rule applies and calculate the taxable value step by step.

📊 Worked example

Example 1 — Rule 27: Consideration Partly in Kind

Ms. Iyer, an interior designer, provides design services to Mr. Kapoor. Mr. Kapoor pays ₹75,000 cash and gifts a smartphone worth ₹25,000 (open market value). GST rate: 18%.

Working:

  • Open market value of the service = ₹1,00,000 (what an unrelated client would pay in cash for the same service)
  • Since OMV is ascertainable, Rule 27 First Option applies
  • Taxable Value = ₹1,00,000
  • GST @ 18% = ₹18,000
  • Total GST liability = ₹18,000 (not on ₹75,000 alone — the smartphone value is included)

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Example 2 — Rule 35: Price Inclusive of GST

Rajesh & Co. Pvt. Ltd. sells packaged goods to a retailer at ₹1,18,000 inclusive of GST. GST rate = 18%.

Working:

  • Formula: Taxable Value = (Gross Amount × 100) ÷ (100 + Rate)
  • Taxable Value = (₹1,18,000 × 100) ÷ (100 + 18)
  • = ₹1,18,00,000 ÷ 118
  • = ₹1,00,000
  • GST @ 18% on ₹1,00,000 = ₹18,000
  • Cross-check: ₹1,00,000 + ₹18,000 = ₹1,18,000 ✓

⚠️ Common exam mistakes

  • Applying Valuation Rules to every transaction: Students jump straight to Rule 27 or Rule 30 without checking if Section 15 transaction value applies. Rules 27–35 are used ONLY when transaction value cannot be determined — always start with Section 15.
  • Forgetting the ITC exception in Rule 28: When the recipient (like a branch) can claim full ITC, even a below-market invoice value is accepted. Many students mechanically apply OMV and lose marks for ignoring this relief.
  • Calculating Rule 30 as Cost × 10% instead of Cost + 10%: The value is cost of production/acquisition PLUS 10% of cost — not a multiplication. ₹80,000 cost → value is ₹88,000, not ₹8,000.
  • Getting Rule 35 backwards: Don't multiply gross amount by rate and subtract. The correct formula is (Gross × 100) ÷ (100 + Rate). Using ₹1,18,000 × 18/118 gives you the tax, not the taxable value — be precise.
  • Missing pure agent conditions in Rule 33: Students claim pure agent exclusion without checking all conditions — the supplier must act as a disclosed agent, costs must be separately invoiced, and the recipient must know. Skipping conditions in exam answers costs easy marks.
📖 Reference: Valuation Rules — Institute of Chartered Accountants of India
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