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applicant can apply Rule 28 of the GST Rules, 2017 to determine the value of supply of goods for supply of goods by one distinct entity (factory/depot) as defined Section 25(4) of the CGST Act to another entity having same PAN (factory/depot).

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Valuation of Supply — Whether supply of goods by one distinct entity (Factory/depot) as defined under Section 25(4)of the CGST Act 2017 as amended to another distinct entity having same PAN (Factory/depot) can be valued at a price declared on the invoice raised by the supplier of goods under second proviso to Rule 28 to CGST Rules, 2017?
Held that— Applicant can apply Rule 28 of the GST Rules, 2017 to determine the value of supply of goods for supply of goods by one distinct entity (factory/depot) as defined Section 25(4) of the CGST Act to another entity having same PAN (factory/depot). — Kansai Nerolac Paints Ltd., In Re… [2019] 10 TAXLOK.COM 108 (AAR-Maharashtra)