M Rishabh & AssociatesCHARTERED ACCOUNTANTS
CBICCIRCULARGST

Clarification on valuation of services supplied between distinct persons

SOURCE

GST Policy Wing, Central Board of Indirect Taxes and Customs, Department of Revenue

NUMBER

251/01/2026-GST

ISSUED

14 October 2026

EFFECTIVE

Immediate

NOTE BY

CA Ananya Mishra

REVIEWED BY:CA M. Rishabh

What the notification does

CBIC clarifies issues regarding the valuation of inter-branch supplies and head office shared services among distinct persons under Section 25(4) of the CGST Act:

  • Where the recipient unit is eligible for full ITC, the invoice value is deemed to be open market value in terms of the second proviso to Rule 28(1).
  • Internally generated services between branches can be invoiced based on verifiable cost allocations without mandatory salary cost integration.
  • Distribution of credit through the Input Service Distributor (ISD) route remains mandatory for third-party procured services.

Who it affects

Enterprises operating with GSTINs across multiple Indian states sharing IT, human resources, accounting, and marketing overheads.

Points for finance teams

ACTIONBY WHENOWNER
Review cross-charge methodology and branch allocation ratiosQuarterly reviewTax manager
Verify full credit eligibility at receiving branch GSTINsBefore monthly billingAccounts team

The firm's note

Clarifies that open market value mechanisms for corporate cost allocations across branch offices are governed under Rule 28 second proviso where the recipient unit is entitled to full input tax credit. Businesses with multi-state footprints should review cross-charge debit notes.

Disclaimer. This note is a summary prepared by M Rishabh & Associates for general information as on 26 October 2026. It is not professional advice. Refer to the official notification for the full text, which prevails in case of any difference. See the full disclaimer.

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