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Microlesson · 5-min read

Section 15(1) - Transaction Value & Scope of Valuation

# Value of Supply: Section 15(1) - Transaction Value

## Why Valuation Matters

GST is an ad-valorem tax — meaning it is calculated as a percentage of the value of supply. Without a correctly determined value, you cannot compute CGST, SGST/UTGST or IGST liability. Section 15 of the CGST Act read with Chapter IV of the CGST Rules, 2017 lays down the rules for valuation.

## Scope of Section 15 — A Quick Map

Sub-sectionCovers
15(1)Supplies for money only between unrelated persons
15(4)Non-monetary consideration, part-monetary/part-non-monetary, or related party supplies
15(5)Specified categories of goods/services notified by Government

## The Core Rule — Section 15(1)

> Value of supply = Transaction Value = the price actually paid or payable for the supply,

> PROVIDED:

> 1. Supplier and recipient are not related, AND

> 2. Price is the sole consideration for the supply.

### Breaking Down "Price Actually Paid or Payable"

  • It is the price for that specific supply being valued — not a market reference price.
  • It includes:
  • Amount already paid, plus
  • Amount payable (i.e., the agreed price still due).
  • It is not the wholesale market price or notional price.

## When Section 15(1) Does NOT Apply

Move to Section 15(4) (or 15(5) if notified) when any of these is true:

  • Parties are related (definitions from Supply chapter apply).
  • Consideration is not solely in money (e.g., barter, exchange).
  • Consideration is partly non-monetary.

## Putting It Together — Decision Logic

1. Are parties related? → If YES, go to Rule 28 via Sec 15(4).

2. Is price the sole consideration? → If NO, go to Sec 15(4).

3. If both NO → Transaction value = price paid/payable is the value.

Worked example

### Example 1

Example (Bare-Act Illustration): X Ltd's wholesale price for 1 MT of cement in ordinary course of business is Rs. 7,000. It sells 1 MT to Y (an unrelated customer) for Rs. 6,700.

Answer: Since Y is unrelated and price is sole consideration, transaction value = Rs. 6,700. The wholesale market price of Rs. 7,000 is irrelevant under Section 15(1).

⚠️ Common exam mistakes

  • Using market price or MRP as the transaction value instead of the price actually paid/payable.
  • Forgetting that BOTH conditions (unrelated + sole monetary consideration) must be satisfied before Section 15(1) can be applied.
  • Mixing up 15(2) inclusions (which add to value) with 15(1) — Section 15(1) only defines the starting transaction value.
Bare-Act text Section 15(1), 15(4) & 15(5) · CGST Act, 2017 · click to expand
Sec 15(1): The value of a supply of goods/services/both shall be transaction value, which is the price actually paid or payable for the said supply of goods or services or both where the supplier and recipient of supply are not related and the price is sole consideration for supply. Sec 15(4): Where the value of supply of goods/services/both cannot be determined under sub-section (1), the same shall be determined in such manner as may be prescribed. Sec 15(5): Notwithstanding anything contained in sub-section (1) or (4), value of such supplies as may be notified by Government on recommendations of Council shall be determined in such manner as may be prescribed.
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