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of AAR holds that where goods are supplied to an unrelated person for a price that is the sole consideration, transaction value under s.15(1) of the CGST Act governs. Supplies to a related person are taxable supplies; valuation among related/distinct persons is to be determined per Rule 28 (open market value, like-kind/value, cost plus 10%, or reasonable means), but the invoice value will be accepted where the recipient is eligible for full input tax credit. A registered supplier of road transportation must issue a consignment note/invoice even for unregistered recipients; however, the supplier is not liable to pay tax under the relevant notification entry for supplies to unregistered persons.
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