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GST Valuation Services

Reviewed by CA and CS Team, Patron Accounting LLP ICAI & ICSI Registered| 15+ Years Experience| Last Updated: Verify Credentials →

Documents: Inter-company agreements, invoices, transfer pricing study, and cost sheet.

Fees: Starting from INR 9,999 (Exl GST and Govt. Charges) per transaction type.

Eligibility: Group entities, distinct persons under Section 25(4)/(5), and exporters with foreign affiliates.

Timeline: Written opinion in 7 to 12 working days; valuation rule mapping in 5 days.

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GST Valuation at a Glance

📌 TL;DR - GST Valuation Services Services at a Glance

GST is payable on transaction value if parties are unrelated and price is the sole consideration. If not, the value defers to Rule 27 (barter), Rule 28 (related / distinct persons - including the second proviso for ITC-eligible recipients), Rule 29 (agent), Rule 30 (cost + 10%), Rule 31 (residual), or Rules 31A-35 for special supplies. Wrong valuation triggers demand under Sections 73 / 74 / 74A CGST with 18% per annum interest plus penalty. Patron Accounting issues written valuation opinions starting from INR 9,999 per transaction type.

Section 15 of the CGST Act, 2017 is the cornerstone of every GST liability calculation. Where the supplier and recipient are unrelated and price is the sole consideration, the transaction value applies and the answer is mechanical. Where any of those two conditions fails - related parties, distinct GSTINs under Section 25(4)/(5), barter, free supply, post-supply discount, corporate guarantee, cross-border affiliate service - the law defers to Rules 27 to 35 of the CGST Rules, 2017, and the answer becomes a structured professional opinion.

Patron Accounting LLP issues written GST valuation opinions for the full spectrum: head-office to branch-office cross charge per Circular 199/11/2023-GST, foreign affiliate import of services per Circular 210/4/2024-GST, corporate guarantee valuation per Rule 28(2) and Circular 225/19/2024-GST, discount structuring under Section 15(3), and residual cost-based valuation under Rules 30 and 31. Each opinion is backed by Act sections, CBIC circulars, and AAR / High Court precedent.

Content is reviewed quarterly for accuracy.

What Is a GST Valuation Service?

GST valuation service is a professional written opinion that determines the taxable value of a supply under Section 15 of the CGST Act, 2017 read with Rules 27 to 35 of the CGST Rules, 2017. The opinion applies the transaction value test, identifies the correct fallback rule when transaction value cannot be accepted, computes the value, and signs off with supporting authority.

The deliverable covers price-sole-consideration analysis, related-person status check under the Section 15 Explanation, deemed-supply review under Schedule I, treatment of inclusions under Section 15(2), discount exclusions under Section 15(3), and the choice of valuation rule from Rule 27 (barter) through Rule 31 (residual), with special-supply provisions in Rules 31A to 35 where applicable.

Key Terms for GST Valuation Services:

  • Transaction Value: The price actually paid or payable for the supply when supplier and recipient are unrelated and price is the sole consideration - Section 15(1) CGST Act.
  • Open Market Value (OMV): The full value in money payable by an unrelated person at the same time as the supply, excluding GST - Explanation (a) to Rule 35.
  • Like Kind and Quality: Supplies similar in characteristics, quality, quantity, functional components, materials, and reputation - Explanation (b) to Rule 35.
  • Related Persons: Defined in the Explanation to Section 15 - includes officers / directors of one another, employer-employee, third party controlling both, members of the same family, and sole agent / distributor.
  • Distinct Persons: Different GSTINs of the same legal entity under Section 25(4)/(5) - treated as separate persons under GST.
  • Cross Charge: Inter-branch or HO-BO supply of services within the same legal entity but across GSTINs, valued under Rule 28 per Circular 199/11/2023.
APL-05 GST Valuation Services
Section 15 Rule 28

When You Need a Valuation Opinion

A written valuation opinion is recommended whenever the transaction value test fails or the value is materially in dispute. Typical triggers:

  • Inter-company sale of goods or services between holding-subsidiary, sister concerns, or associate enterprises
  • HO to BO cross charge across GSTINs (Section 25(4)/(5) distinct persons - covered by Rule 28 and Circular 199/11/2023)
  • Import of services from foreign affiliates - valuation under Rule 28 read with Circular 210/4/2024-GST
  • Corporate guarantee given by a holding to a subsidiary - 1% per annum of the amount guaranteed under Rule 28(2)
  • Free supplies, samples, gifts, or buy-one-get-one offers - Section 7 read with Schedule I and Section 15
  • Barter, exchange offers, or part-money-part-asset transactions - Rule 27
  • Post-supply discounts (year-end rebates, volume discounts) - Section 15(3)(b) conditions
  • Composite vs mixed supply determination affecting value attribution - Sections 2(30), 2(74), 8
  • Special-supply scenarios: money changing, life insurance, second-hand goods, vouchers, lottery, gambling - Rules 31A, 32
  • Departmental SCN, DRC-01A, or ASMT-10 alleging undervaluation

Statutory Deadline

There is no specific filing deadline for valuation per se, but where a SCN is issued under Sections 73 / 74 / 74A, reply timelines apply (30 days under Section 73; 60 days under Section 74). Voluntary disclosure under Section 73(5) before an SCN avoids penalty entirely.

Patron Accounting Services

ServiceWhat We Do
Section 15 Transaction Value OpinionWritten opinion confirming whether the declared invoice value qualifies as transaction value under Section 15(1) and what inclusions under Section 15(2) (subsidies, incidental expenses, late fees, taxes other than GST) must be added.
Related-Party and Distinct-Persons ValuationRule 28 analysis covering open market value, like kind and quality, cost-based fallback, and the critical second proviso to Rule 28(1) - invoice value deemed OMV where the recipient is eligible for full ITC. Covers HO-BO cross charge per Circular 199/11/2023-GST.
Corporate Guarantee Valuation under Rule 28(2)Computation of 1% per annum of the amount guaranteed or actual consideration whichever is higher, including the second proviso where the recipient is full-ITC eligible. Includes treatment under Circular 225/19/2024-GST and the recipient-outside-India carve-out.
Cost and Residual Method Opinions (Rules 30 and 31)Cost-method computation at 110% of cost of production / manufacture / provision; residual method where Rules 27 to 30 fail. Includes documentation of the reasonable-means rationale.
Discount Structuring under Section 15(3)Pre-supply on-invoice discount documentation, post-supply discount agreement drafting with linkage to specific invoices, GSTR credit note advisory, and ITC reversal mapping for the recipient under Section 15(3)(b)(ii).
Departmental Representation on Valuation NoticesReply to ASMT-10 scrutiny, DRC-01A intimation, and DRC-01 SCN alleging undervaluation under Sections 73, 74, or 74A. Includes Rule 30/31 defence, second-proviso defence, and revenue-neutrality argument where applicable.
Our Process

Our Process

From the scoping call and transaction value test through the Rule 27 to 31 sequence and special-supply check to the circular overlay and signed opinion.

Step 1

Scoping Call

We collect inter-company agreements, sample invoices, the transfer pricing study (if any), cost sheets, the shareholding structure, and the group-level GSTIN list. Free 15 to 30 minute consultation.

Agreements GSTIN list
Scoping 01
Step 2

Transaction Value Test

We apply Section 15(1) - checking if parties are unrelated under the Section 15 Explanation and if price is the sole consideration. Pass: transaction value stands subject to Section 15(2) inclusions and Section 15(3) exclusions.

15(1) test Related check
Section 15 02
Step 3

Rule Sequence

If transaction value fails, we apply Rules 27 to 31 in order: Rule 27 if consideration is not wholly in money; Rule 28 if related or distinct persons (with the second proviso where the recipient has full ITC); Rule 29 for agent supplies; Rule 30 cost+10%; Rule 31 residual.

Rule 27-31 Second proviso
Rule Map 03
Step 4

Special-Supply Check

Apply Rules 31A and 32 where lottery, gambling, money changing, insurance, second-hand goods, vouchers, or pure agent (Rule 33) provisions are triggered.

Rule 31A/32 Pure agent
Special 04
Step 5

Circular and Case Law Overlay

Apply CBIC Circulars 92/11/2019 (discounts), 199/11/2023 (HO-BO), 210/4/2024 (foreign affiliate import), 225/19/2024 (corporate guarantee), and recent AAR / High Court rulings (e.g., KEI Industries, Cummins India, Columbia Asia).

Circular overlay Case law
Authority 05
Step 6

Draft Opinion + CA Review + Sign-Off

Partner sign-off with implementation guidance for the ERP, the invoicing system, and GSTR-1 reporting.

CA review Implementation
Opinion 06

Document Checklist

A defensible valuation opinion depends on accurate group, agreement, and cost data. The following documents support the engagement:

  • Group structure chart with all GSTINs and incorporation states
  • Inter-company services / goods supply agreements
  • Last 12 months sample invoices for the transaction in question
  • Transfer pricing study (if any) or comparability analysis
  • Cost sheets, BOM, and overhead allocation methodology (for the cost method)
  • Corporate guarantee deeds and board resolutions (where applicable)
  • Discount policy, customer-wise discount schedule, and post-supply credit note register
  • Any departmental correspondence (ASMT-10, DRC-01A, DRC-01) on valuation

Common Challenges and How We Resolve Them

ChallengeImpactHow Patron Accounting Solves It
HO Charges Branch at Zero but Recipient Claims Full ITCDepartments may allege undervaluation on Nil or low cross-charge between distinct GSTINs.Resolved under the second proviso to Rule 28(1) and Circular 199/11/2023-GST - where the recipient BO has full ITC, the HO-declared value is deemed OMV, even Nil. The Delhi High Court in KEI Industries (May 2025) sustained Nil cross-charge; we draft the supporting board note and reporting framework.
Corporate Guarantee - 1% or Actual?Uncertainty on the basis and frequency of corporate-guarantee valuation creates exposure.Rule 28(2) read with Circular 225/19/2024-GST requires 1% per annum of the amount guaranteed or actual consideration, whichever is higher; where the recipient is outside India Rule 28(2) does not apply, and the second proviso permits invoice value where the recipient has full ITC.
Department Recharacterising Secondary Discount as Price ReductionDiscounts not meeting Section 15(3)(b) conditions get added back to value.Circular 92/11/2019-GST distinguishes pre-supply, qualifying post-supply, and secondary discounts; we structure customer discount agreements to qualify under Section 15(3)(b) and document the ITC reversal trail.
Free Samples and BOGO OffersMisclassifying promotions as taxable or exempt creates either over-payment or demand risk.Per Circular 92/11/2019-GST, a free supply between related persons is a deemed supply under Schedule I valued under Rule 28, while BOGO is a discounted price for two items; we map each promotion to the correct rule and document the GSTR-1 disclosure.

Patron Accounting Fees

Fee ComponentAmount
Section 15 Transaction Value Opinion (single transaction type)Starting from INR 9,999 (Exl GST and Govt. Charges)
Related-Party / Distinct-Person Valuation (Rule 28)Starting from INR 9,999 (Exl GST and Govt. Charges)
Corporate Guarantee Valuation (Rule 28(2))Starting from INR 9,999 (Exl GST and Govt. Charges)
Cost / Residual Method Opinion (Rules 30 / 31)Quote on call - varies by SKU count and cost complexity
Discount Structuring + Agreement Drafting (Section 15(3))Quote on call - varies by scheme count
Departmental Representation (Sections 73 / 74 / 74A)Quote on call - varies by demand quantum
Government FeesNIL for advisory; AAR application fee of INR 10,000 applies only if an advance ruling is filed

All fees and charges listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on the volume of work and the complexity involved.

Professional service charges for drafting, filing, and representation are separate from the statutory fees. The exact fee depends on the complexity of the case, disputed amount, and number of hearings required. Contact us for a detailed quote.

Get a free GST Valuation Services consultation - Call +91 945 945 6700 or WhatsApp us. No-obligation assessment.

Time Taken

StageEstimated Timeline
Section 15 transaction value opinion7 to 10 working days
Rule 28 related-party valuation (single transaction type)7 to 12 working days
Corporate guarantee valuation5 to 7 working days
Group-wide cross-charge framework (multi-state)15 to 30 working days
Discount structuring and agreement7 to 14 working days
Reply to ASMT-10 / DRC-01A on valuation7 to 14 working days
Section 73 / 74 / 74A SCN reply15 to 30 working days (within statutory limit)

Key timelines: a standard written opinion in 7 to 12 working days, complex group structures in 2 to 4 weeks, and SCN replies within the statutory limit (30 days under Section 73, 60 days under Section 74).

Key Benefits

Why Engage a Professional

Defensible Written Opinion

Withstands departmental scrutiny, statutory audit, and tribunal proceedings.

Section 74 Fraud-Allegation Blocker

A documented bona fide valuation rationale defeats a wilful-misstatement charge.

Second-Proviso Optimisation

Where the recipient has full ITC, valuation can be reduced to invoice or Nil legitimately.

Cross-Charge Framework

One-time setup that runs cleanly across monthly GSTR cycles.

Lower Long-Term Cost

One INR 9,999 opinion replaces multi-year cumulative interest and penalty exposure.

Trusted by Businesses Across India

10,000+ Businesses Served | 4.9 Google Rating | 50,000+ Documents Filed | 15+ Years of CA / CS Practice

Trusted by Hyundai, Asian Paints, Bridgestone, and a growing portfolio of SMEs across manufacturing, IT services, FMCG, and exporters.

Outcome proof: a Mumbai-based group with five GSTINs facing a INR 3.2 crore demand on alleged HO-BO undervaluation closed at the Commissioner (Appeals) stage on the second proviso to Rule 28 read with Circular 199/11/2023, with the demand reduced to Nil.

With offices in Pune, Mumbai, Delhi and Gurugram, Patron Accounting serves businesses across India both in-person and remotely. See our GST returns support in Mumbai for local coordination.

DIY vs Patron Accounting Valuation Advisory

ParameterDIY / Internal TeamPatron Accounting Advisory
MethodCopy prior practice; benchmark to other group entitySection 15 test + Rule 27 to 31 sequence + circular overlay
Authority citedRarely - usually a one-line ERP noteSections, Rules, Circulars (199 / 210 / 225 / 92), AAR / HC precedent
Second-proviso optimisationOften missed - clients overpay on cross chargeApplied where ITC eligible - legitimate value reduction
Circular currencyStale - typically pre-2023 logicUpdated to Circular 225/19/2024 (corporate guarantee) and KEI Industries 2025
Section 74 defenceWeakStrong - written bona fide opinion
CostHidden - interest + penalty + audit timeStarting from INR 9,999 per transaction type
Audit / board comfortLowHigh - signed CA opinion

Related Patron Services

Valuation advisory connects with other GST workstreams. Patron also handles:

  • GST Services - the complete GST services hub covering registration, returns, ITC, refunds, notices and audits.
  • GST Audit - statutory and management audit including valuation review across all inter-company transactions.
  • GST Notice - ASMT-10, DRC-01A, and DRC-01 representation including valuation disputes.
  • GSTAT Anti Profiteering Appeal - valuation often triggers anti-profiteering scrutiny; integrated representation.
  • GSTAT Advance Ruling Appeal - appeal AAR rulings on valuation under Section 100.
  • GSTAT Appeal Filing - Section 112 tribunal appeals on valuation orders.
  • GST Returns - monthly GSTR-1 / GSTR-3B filing reflecting correct valuation.

We also offer GST Classification and HSN/SAC Advisory, as HSN classification often interacts with valuation, as part of an integrated engagement.

Legal and Compliance Framework

Governing Act and Rules: Central Goods and Services Tax Act, 2017 read with the CGST Rules, 2017 (Chapter IV - Determination of Value of Supply) and the relevant CBIC circulars.

ElementReference
Charging sectionSection 9 CGST Act - GST is ad valorem on value of supply
Value of taxable supplySection 15 CGST Act, 2017
Inclusions in valueSection 15(2) - taxes other than GST, expenses paid by recipient, incidentals, interest / late fees, subsidies (not from govt)
Exclusions from valueSection 15(3) - pre-supply discount on invoice; post-supply discount with agreement and ITC reversal
Related persons - definitionExplanation to Section 15 CGST Act
Distinct personsSection 25(4) and (5) CGST Act - different GSTINs of same legal entity
Schedule I deemed supplySection 7(1)(c) read with Schedule I - related persons supply without consideration is supply
Rule 27 - barterConsideration not wholly in money: OMV / money + equivalent / like kind and quality / cost+10%
Rule 28 - related / distinctOMV / like kind and quality / Rule 30 or 31; second proviso: invoice value = OMV when recipient has full ITC
Rule 28(2) - corporate guarantee1% per annum of amount guaranteed or actual consideration whichever higher
Rule 29 - through agentOMV or 90% of price charged by recipient to unrelated customer
Rule 30 - cost method110% of cost of production / manufacture / provision
Rule 31 - residual methodReasonable means consistent with principles of Section 15 and Rules 27 to 30
Rule 31A - lottery / gambling100% of face value of bet or 100% of ticket price
Rule 32 - special suppliesMoney changing, insurance, second-hand goods, vouchers, redemption
Rule 33 - pure agentPure agent expenses excluded from value subject to conditions
Rule 34 - rate of exchangeGST Council notified rate at time of supply
Rule 35 - tax includedBack-calculation formula when value is inclusive of GST
Demand - non fraudSection 73 CGST Act - 10% penalty or INR 10,000 (whichever higher); 3-year limitation
Demand - fraudSection 74 CGST Act - 100% penalty; 5-year extended period (up to FY 2023-24)
Unified demand (FY 2024-25 onwards)Section 74A CGST Act
Interest18% per annum under Section 50; 24% on wrongful ITC reversal
Key Circulars92/11/2019 (discounts), 199/11/2023 (HO-BO), 210/4/2024 (foreign affiliate), 225/19/2024 (corporate guarantee)

Authoritative references: Circular 199/11/2023-GST (HO-BO Cross Charge), Circular 225/19/2024-GST (Corporate Guarantee), and the Section 15 CGST Act (CBIC Tax Information).

What is value of supply under Section 15 of the CGST Act?

The value of supply under Section 15(1) is the transaction value, meaning the price actually paid or payable for the supply of goods or services, provided the supplier and recipient are unrelated and price is the sole consideration. If either condition fails, value is determined under Rules 27 to 35 of the CGST Rules, 2017.

How is the value determined for a related-party transaction?

Rule 28 of the CGST Rules applies. Value is open market value first, then value of like kind and quality, then cost method (Rule 30 - 110% of cost), then residual method (Rule 31). The second proviso to Rule 28(1) allows the invoice value to be deemed open market value where the recipient is eligible for full input tax credit, per Circular 199/11/2023-GST.

How is GST valued on a corporate guarantee given to a subsidiary?

Rule 28(2) provides that the value is 1% per annum of the amount guaranteed or the actual consideration, whichever is higher. Circular 225/19/2024-GST clarifies the 1% applies per annum (not one-time). Where the recipient is located outside India, Rule 28(2) does not apply. Where the recipient has full ITC, the second proviso allows invoice value to be accepted.

Can post-supply discounts be excluded from value of supply?

Yes, but only if the conditions of Section 15(3)(b) are met: the discount is established by an agreement entered into at or before the time of supply, the discount is specifically linked to relevant invoices, and the input tax credit attributable to the discount is reversed by the recipient. Secondary discounts not meeting these conditions cannot be deducted, per Circular 92/11/2019-GST.

Is GST payable on a free supply or sample to a related party?

Yes. Under Section 7(1)(c) read with Schedule I, a supply between related persons made without consideration is a deemed supply and is taxable. Valuation is under Rule 28 - open market value, like kind and quality, or fallback to Rule 30 or 31. The 1% per annum guarantee and zero-value cross-charge rules can apply where conditions are met.

What is Rule 30 cost method under GST valuation?

Rule 30 prescribes that where value cannot be determined under Rules 27, 28, or 29, the value is 110% of the cost of production or manufacture of the goods, or the cost of provision of the service. For service providers, Rule 31 (residual method) may be elected in place of Rule 30 at the option of the supplier.

How is cross-charge between head office and branch valued?

Per Circular 199/11/2023-GST dated 17 July 2023, supplies between HO and BO across GSTINs are valued under Rule 28. Where the recipient BO is eligible for full ITC, the value declared by HO in the invoice is deemed open market value under the second proviso. If no invoice is issued, value can be deemed Nil where ITC is fully available. The Delhi High Court in KEI Industries (May 2025) sustained Nil cross-charge on this basis.

What is the cost of GST valuation advisory at Patron Accounting?

Starting from INR 9,999 (Exclusive of GST and government charges) per transaction type for a written opinion. Corporate guarantee, cross-charge framework, discount structuring, and group-wide valuation reviews are quoted separately based on transaction count and complexity. Government fees apply only if an advance ruling under Section 97 CGST is filed (INR 10,000 in total).

Related party ke saath GST valuation kaise hoga?

Rule 28 ke under jaata hai. Sabse pehle open market value, phir like kind and quality, phir cost+10% (Rule 30), aur akhri me residual method (Rule 31). Agar recipient full ITC le sakta hai, toh invoice value hi accept ho jaati hai - second proviso to Rule 28. Circular 199/11/2023 ne yeh HO-BO ke liye confirm kiya hai.

Quick Answers

  • What is transaction value? The price actually paid or payable when parties are unrelated and price is the sole consideration - Section 15(1) CGST.
  • What is Rule 28 about? Valuation of supplies between related or distinct persons; OMV first, then like kind, then Rule 30 or 31.
  • What does the second proviso to Rule 28 say? Where the recipient has full ITC, invoice value is deemed open market value.
  • How is a corporate guarantee valued? 1% per annum of the amount guaranteed or actual consideration, whichever higher - Rule 28(2).
  • What is cost method valuation? 110% of cost of production, manufacture, or service provision - Rule 30 CGST Rules.
  • Is free supply to a related party taxable? Yes - Schedule I treats it as a deemed supply; valued under Rule 28.

Why Move Now on GST Valuation

Valuation errors compound monthly.

A wrong cross-charge value over 24 months can convert into a multi-crore demand once interest at 18% per annum and Section 74 penalty stack up. Voluntary disclosure under Section 73(5) before an SCN waives the penalty entirely.

The cost of a defensible opinion - starting from INR 9,999 - is a tiny fraction of the downside.

At the Centre of Every Tax Invoice

GST valuation under Section 15 and Rules 27 to 35 sits at the centre of every tax invoice you issue. For unrelated arm-length supplies, the transaction value answers itself. For related parties, distinct GSTINs, corporate guarantees, free supplies, post-supply discounts, and cross-border affiliate services, the law is rule-based, circular-driven, and increasingly case-law shaped.

Patron Accounting LLP, with CA and CS professionals practising for 15+ years across Pune, Mumbai, Delhi, and Gurugram, issues written valuation opinions that map the right rule, apply the latest circular, and protect the value declared on every invoice - from departmental scrutiny through GSTAT and writ jurisdiction.

Pair it with a periodic GST Audit, expert GST Notice representation, and tribunal support through GSTAT Appeal Filing.

Book a Free Consultation - No Obligation.

GST Valuation Support Across India

With offices in Pune, Mumbai, Delhi, and Gurugram, Patron Accounting serves group entities and exporters across India - both in-person and remotely.

GST Valuation Support by City
Section 15 and Rule 28 opinions, cross-charge frameworks and representation, on-the-ground and remote
Related Services
End-to-end support across the GST compliance stack

Content Created: 27 May 2026  |  Last Updated:  |  Next Review: 1 September 2026  |  Reviewed By: CA & CS Team, Patron Accounting LLP

This page is reviewed quarterly (Tier 1 cadence) and on any new CBIC valuation circular, an amendment to Section 15 or Rules 27 to 35, an AAR/GSTAT/High Court ruling on related-party valuation or cross charge, or a corporate guarantee notification change.