Value of Supply
AI-assisted · review in progress · last updated 25 July 2026 · jump to quick revision
In 30 seconds
- GST is an ad valorem levy — Section 15's value of supply is the base on which tax is computed.
- Transaction value under 15(1) applies only between unrelated persons where price is the sole consideration; related-party, non-monetary and notified supplies go to Chapter IV Rules (Final level).
- Section 15(2) inclusions — TIPS-I: Taxes/duties/cess (other than GST), Incidental expenses, Penalty/interest/late fee, Subsidy (non-Govt, price-linked), Incurred-by-recipient payments.
- Section 15(3) discounts: before/at supply and recorded in the invoice = auto-excluded; post-supply needs a pre-existing invoice-linked agreement plus ITC reversal by the recipient.
- Government subsidies, GST and Compensation Cess themselves, TCS under the Income-tax Act, and notional/waived interest never enter the value.
Based on GST law as on 30.04.2025 (May 2026 exams onwards). Section numbers are CGST Act unless stated.
How the chapter fits together
GST is an ad valorem levy — tax is a percentage of value — so the value of supply is crucial for every tax computation. Section 15 resolves it with one decision flow:
- 1. Is price the sole consideration? No → Chapter IV CGST Rules (Final level).
- 2. Are supplier and recipient related persons? Yes → Chapter IV Rules [Sec 15(4)].
- 3. Is it a notified supply? Yes → Chapter IV Rules [Sec 15(5)].
- 4. No to all → Transaction value = Sec 15(1) price + 15(2) inclusions − 15(3) exclusions.
Golden rule: transaction value applies only to unrelated persons where price is the sole consideration. Related-party, non-monetary and notified-supply valuation lives in Chapter IV of the CGST Rules — Final level, not in the Inter syllabus. At Inter you work Sec 15(1)/(2)/(3) only.
When the amount you are given is GST-inclusive, back-calculate the value as Amount × [100 / (100 + rate)].
Key definitions
Transaction value [Sec 15(1)]
The price actually paid or payable for the supply, where supplier and recipient are not related and price is the sole consideration. Keyword: “actually paid or payable”.
Consideration [Sec 2(31)]
Any payment (in money or otherwise) plus the monetary value of an act or forbearance, whether by the recipient or any other person. It excludes Government subsidy, and a deposit is NOT consideration unless the supplier applies it towards the supply.
Related persons (Explanation to Sec 15)
8 categories — officers/directors of one another’s business, partners, employer–employee, ≥25% voting stock/shares, one controls the other, both controlled by a third person, together they control a third person, same family — plus a separate limb: a sole agent, sole distributor or sole concessionaire is deemed related even if none of the 8 categories applies.
Recipient [Sec 2(93)]
The person liable to pay the consideration; where there is no consideration, the receiver of the goods or services. Trap: “liable to pay” is not the same as “who actually pays”.
Supplier [Sec 2(105)]
The person supplying, including an agent acting on his behalf — with a deeming fiction for platforms of specified actionable claims (includes online gaming platforms).
The smaller definitions that feed the chapter:
| Term | Crisp meaning | Trap / keyword |
|---|---|---|
| Money [2(75)] | Indian legal tender / instruments used to settle an obligation | Excludes currency held for numismatic value |
| Agent [2(5)] | Factor, broker, commission agent, arhatia, del credere agent, auctioneer, mercantile agent | “By whatever name called”; acts on behalf of another |
| Cess [2(22)] | Same meaning as the GST (Compensation to States) Act | GST Compensation Cess excluded from value; cesses under other laws included |
| Commercial credit note | Issued for the discount value only, with NO GST component | No ITC reversal needed; used when 15(3)(b) fails |
| Pure agent | Not detailed at Inter (Final-level Chapter IV concept) | — |
Inclusions — Section 15(2)
Mnemonic TIPS-I: Taxes/duties/cess (other than GST, charged separately) · Incidental expenses (commission, packing, anything done before/at delivery) · Penalty/interest/late fee for delayed payment · Subsidy (non-Govt, price-linked) · Incurred by the recipient on the supplier’s behalf (third-party payment).
| Clause | What is added | Watch for |
|---|---|---|
| 15(2)(a) | Taxes, duties and cesses under other laws (other than GST/Comp Cess), if charged separately | TCS under the Income-tax Act is NOT includible [Circular 76/50/2018] |
| 15(2)(b) | Supplier’s liability paid by the recipient and not included in the price | The supplier must have a contractual liability |
| 15(2)(c) | Incidental expenses — commission, packing, anything done before/at delivery, charged to the recipient | Supplier-arranged freight → composite supply |
| 15(2)(d) | Interest, late fee or penalty for delayed payment | Time of supply = date of actual receipt [Sec 13(6)] |
| 15(2)(e) | Subsidy directly linked to price, from anyone other than the Government | Govt subsidy excluded; blanket/lumpsum subsidy never included |
Both 15(2) inclusions and 15(3) exclusions operate on the transaction value derived from 15(1) — they adjust the price, they are not independent triggers.
Discounts — Section 15(3)
The discount test is a 2-step:
- Step 1 — before/at supply: discount recorded in the invoice → automatically deductible [15(3)(a)].
- Step 2 — after supply: deductible ONLY IF a pre-existing agreement (at/before supply, invoice-linked) exists AND the recipient reverses the proportionate ITC [15(3)(b)] — twin conditions cumulative.
- Fail either → not deductible → issue a commercial credit note (discount value only, no GST impact).
| Discount type | Condition | Deductible? |
|---|---|---|
| Before/at supply | Recorded in the invoice | YES [15(3)(a)] |
| Staggered (“buy more, save more”) | Shown in the invoice | YES [15(3)(a)] |
| Post-supply | Pre-existing agreement (at/before supply) + invoice-linked + ITC reversed by recipient | YES [15(3)(b)] — both conditions cumulative |
| Periodic / year-end / volume | Agreement pre-exists, quantity known only later, credit note issued, ITC reversed | YES if 15(3)(b) satisfied |
| Secondary | No prior agreement, decided after supply | NO — never deductible |
| Turnover/performance cash-back (not pre-agreed) | Not known at the time of supply | NO |
Credit-note pairing: a GST credit note (Sec 34) reduces output tax and the recipient must reverse ITC — used when 15(3)(b) is satisfied. A commercial credit note carries only the discount value, no GST, no ITC reversal — used when 15(3)(b) fails.
Insurance angle: NCB (no-claim bonus) is a permissible discount under 15(3)(a) if pre-disclosed in the policy and mentioned in the invoice [Circular 186/18/2022].
Never included, and when transaction value fails
These amounts stay out of the value in every case:
- CGST, SGST, UTGST and GST Compensation Cess themselves.
- TCS under the Income-tax Act, 1961 — an interim levy, not a tax [Circular 76/50/2018-GST].
- Subsidy from the Central/State Government — even if price-linked.
- Blanket/lumpsum non-Govt subsidy not linked to a specific price.
- Notional/waived interest — never actually received.
- Freight/insurance on an ex-factory contract (buyer arranges).
- Amounts not charged to the recipient (supplier bears out of pocket).
Transaction value is rejected — 15(1) inapplicable — when the parties are related persons (any of the 8 categories or the sole agent/distributor/concessionaire limb), when price is not the sole consideration (barter, non-monetary or part-monetary), or for notified supplies u/s 15(5). All of these go to Chapter IV CGST Rules (Final level, not in the Inter syllabus). Section 15(5) opens with “notwithstanding” — it overrides both 15(1) and 15(4).
Inter-State supplies: Section 20 of the IGST Act applies the CGST value provisions to IGST; its third proviso keeps the value inclusive of taxes other than IGST/Comp Cess.
Timelines and traps
| Event | Timing | Ref |
|---|---|---|
| Time of supply for interest/late fee/penalty | Date of actual receipt by the supplier (not accrual) | Sec 13(6) |
| Discount recording | Before or at the time of supply | 15(3)(a) |
| Agreement for post-supply discount | Must exist at or before the time of supply | 15(3)(b)(i) |
- Treating 15(2) inclusions and 15(3) exclusions as independent triggers — both operate on the 15(1) transaction value: inclusions add (taxes, incidental expenses, interest, subsidy, third-party payments), exclusions reduce (discounts only).
- Applying one test to all discounts — pre-supply [15(3)(a)] just needs recording in the invoice; post-supply [15(3)(b)] needs both a pre-existing agreement and ITC reversal by the recipient.
- Including a Government subsidy because it is price-linked — Govt (Central/State) subsidy is never included, regardless of linkage; non-Govt subsidy enters only if directly price-linked.
- Confusing staggered/periodic discounts with secondary discounts — a pre-existing agreement (even if quantified later) keeps them deductible; a secondary discount, decided after supply with no prior agreement, never is.
- Mixing up the credit notes — a GST credit note (Sec 34) reduces output tax and forces ITC reversal; a commercial credit note is discount-value only, no GST, no reversal.
- Adding freight on an ex-factory contract — buyer arranges, so it is excluded; only supplier-arranged freight/insurance becomes part of a composite supply and enters the value.
- Counting a deposit as consideration — it is not, unless the supplier actually applies it towards the supply [proviso to Sec 2(31)].
- Including TCS under the Income-tax Act as a “tax charged separately” — it is an interim levy, never includible [Circular 76/50/2018]; other-law taxes (e.g. municipal tax) are includible if charged separately.
Quick revision cards
Decision flow of Section 15?
TIPS-I inclusions of 15(2)?
Two-step discount test?
Govt vs non-Govt subsidy?
Is TCS under the Income-tax Act included in value?
Secondary discount?
GST credit note vs commercial credit note?
Interest for delayed payment — taxed when?
Related persons test?
Back-calculation from a GST-inclusive amount?
Deposit — is it consideration?
Ex-factory freight?