Taxability of related party loans: interest only consideration is exempt, but separate processing or administrative fees attract GST. The circular confirms that supply between related persons exists under the UPGST Act, but services of granting loans/advances where consideration is solely interest or discount are exempt under the notified entry. Processing, administrative, facilitation or loan granting charges distinct from interest constitute taxable consideration for supply of services and attract GST. Where no such additional fees are charged between related parties or affiliates, no separate taxable service arises and open market valuation is not applicable; any additional fees will be subject to GST.