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Microlesson · 5-min read

Section 15(1) – Transaction Value (Scope and Conditions)

# Section 15 – Value of Supply: Introduction & Transaction Value

## Why Valuation Matters

  • GST is levied ad valorem (i.e., as a % of value of supply).
  • Correct valuation drives correct CGST + SGST/UTGST and IGST.
  • Section 15 of the CGST Act + Chapter IV of CGST Rules, 2017 comprehensively govern valuation.

## Scope of Section 15

Sub-sectionCoverage
15(1)Supplies for money price between unrelated persons
15(2)Inclusions in value
15(3)Exclusions (discounts)
15(4)Non-monetary / part non-monetary / related person supplies — referred to Rules
15(5)Specified categories of goods/services notified

## Sec 15(1) – Transaction Value

> The value of supply shall be the transaction value = the price actually paid or payable, where:

> (a) supplier and recipient are NOT related, AND

> (b) price is the sole consideration.

### Twin Conditions

1. Unrelated parties (per Sec 15 Explanation — same as discussed in supply chapter)

2. Price is the sole consideration — no non-monetary element

### Meaning of Price Paid or Payable

  • The price for the specific supply being valued.
  • Includes amounts already paid + amounts payable.
  • "Payable" = the agreed price (not a market or notional figure).

### Consequence

  • If both conditions are met → invoice price = transaction value = value of supply.
  • If either fails → step out to Sec 15(4) → Valuation Rules.

Worked example

### Example 1

Wholesale vs special price: X Ltd. ordinarily sells 1 MT of cement at ₹7,000. To unrelated customer Y, it sells at ₹6,700. Since Y is unrelated and ₹6,700 is the sole consideration → Value = ₹6,700 (the price actually paid). The 'normal' ₹7,000 wholesale price is irrelevant.

### Example 2

Related party trap: A Ltd. sells goods to its 100% subsidiary B Ltd. at ₹5,000 vs. market price ₹10,000. Sec 15(1) does NOT apply (related parties). Value must be determined under Sec 15(4) read with valuation rules.

⚠️ Common exam mistakes

  • Comparing invoice price with 'market' or 'normal' price to challenge value — irrelevant under Sec 15(1) if parties are unrelated and price is sole consideration.
  • Forgetting the twin conditions: failing either unrelated-party test or sole-consideration test ousts Sec 15(1).
  • Assuming 'payable' means market-fair value — it means the agreed price.
Bare-Act text Section 15(1) · CGST Act, 2017 · click to expand
The value of a supply of goods or services or both shall be the transaction value, which is the price actually paid or payable for the said supply of goods or services or both where the supplier and the recipient of the supply are not related and the price is the sole consideration for the supply.
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