Jagatguru Textiles Ltd. transfers from Bellary in Karnataka stocks of 15,000 meters of cloth having cost of ₹15,00,000 requiring further processing before sale to its Bhilwara branch located in Rajasthan from where it is

As per section 25(4) of the Central Goods and Services Tax Act, 2017 a person who has obtained more than one registration, whether in one State or Union territory or more than one State or Union territory shall, in respect of each such registration be treated as distinct person for the purposes of this Act. As per provisions of section 7 read with Para- 2 of Schedule -1, transfer of goods between two registered units of the same person (having the same PAN) will be treated as supply even if the transfer is made without consideration, as such persons will be treated as 'distinct persons' under the GST law. The value of the supply would be the open market value of such supply, if open market value cannot be determined, the value shall be the value of supply of goods of like kind and quality prevailing in the market. If value cannot be determined any of the above modes, then the value shall be determined as per Rule 30 or Rule 31 of the CGST Rules in that order. In this case, although goods of like kind and quality are available, the same may not be accepted as the 'like goods' since they are supplied by another manufacturers located in Rajasthan whereas supplier in the case of Jagatguru Textiles is located at Bellary in Karnataka. Transportation cost in respect of manufacturers of Rajasthan are lower and thus less expensive in comparison to goods under consideration which were supplied from Karnataka. Therefore, the value of the supply would be taken as per Rule 30 of the Central Goods and Services Tax Rules at 110% of the cost (110% x ₹15,00,000) = ₹16,50,000 for charge of GST.