Rule 28 - Value of supply of goods or services or both between distinct or related persons, other than through an agent

Value of supply between related persons: open market value or specified alternatives govern taxable valuation and invoice presumption.

Value of supply between distinct or related persons is determined primarily by open market value, then by the value of like goods or services, and ultimately by prescribed valuation rules if earlier measures are not determinable. A supplier may elect an alternative ninety percent valuation where goods are for onward supply to non-related customers. If the recipient is eligible for full input tax credit, the invoice-declared value is deemed to be the open market value. For corporate guarantees provided to related recipients in India, value is deemed to be a prescribed percentage of the guarantee amount per annum or actual consideration, whichever is higher, with the invoice deemed where full input tax credit applies.