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Circular 210/04/2024-GST: Clarification on valuation of supply of import of services by a related person where recipient is eligible to full input tax credit

Source-led decode of CBIC Circular 210/04/2024-GST with the actual provisions, rules, forms and official PDF trail.

Reviewed by CA Nikhil Gupta · Updated 5 October 2026

Filing identity

Circular number
210/04/2024-GST
Date
2024-06-26
CBIC record
1003211
PDF source
official text PDF; 4 page(s)

Form in 2 minutes

Circular 210/04/2024-GST deals with clarification on valuation of supply of import of services by a related person where recipient is eligible to full input tax credit. Read it as a input tax credit analysis: map the invoice, recipient, supplier compliance trail, goods or services use and the exact condition in section 16 or the relevant rule. The circular is binding administrative clarification under the GST framework only to the extent of the issue it answers; the Act, Rules, notifications and event-date version still control the final legal result.

Working point: On the issue of clarification on valuation of supply of import of services by a related person where recipient is eligible to full input tax credit, the advisory file should show the transaction facts beside each statutory condition; the circular helps resolve the identified doubt, not replace the primary ITC test.

Bare law, rules and notifications

Sections extracted

  • Section 168 (1)
  • Section 25
  • Section 31(3)(f)

Rules extracted

  • Rule 30
  • Rule 31
  • Rule 28(1)

Forms extracted

No GST form was expressly extracted from Circular 210/04/2024-GST.

Notifications and linked circulars

  • Circular No. 199/11/2023-GST

The source map above is limited to citations actually extracted from the official Circular 210/04/2024-GST PDF. Where the transaction also touches another charging section, exemption entry, return rule or limitation provision, document that separate source before filing or advising.

Paragraph-wise decode

ParaIssue dealt with in the circular
2Representations have been received from trade and industry stating that demands are being raised by some of the field formations against the registered persons seeking tax on reverse charge basis in respect of certain activities undertaken by their related persons based outside India, by considering the said activities as import of services by the registered person in India, based on an expansive interpretation of the deeming...
3.1In order to clarify the issue and to ensure uniformity in the implementation of the provisions of law across the field formations, the Board, in exercise of its powers conferred by section 168 (1) of the CGST Act, hereby clarifies the issues as under:
3.2Rule 28 of Central Goods and Services Tax Rules, 2017 (hereinafter referred to as t he ‘CGST Rules’) is reproduced as below: “Rule 28.Value of supply of goods or services or both between distinct or related persons, other than through an agent. – (1) The value of the supply of goods or services or both between distinct persons as specified in sub-section (4) and (5) of section 25 or where the supplier and recipient are...
3.3As per second proviso to rule 28(1) of CGST Rules, in cases involving supply of goods or services or both between the distinct or related persons where the recipient is eligible for full input tax credit, the value declared in the invoice shall be deemed to be th e open market value of the said goods or services.
3.4It may be noted that vide Circular No. 199/11/2023 -GST dated 17.07.2023 , clarification has been issued regarding taxability of services provided by an office of an organisation in one State to the offi ce of that organisation in another State, both being distinct persons .It has been clarified in the said circular that as per the second proviso to rule 28(1) of CGST Rules, in respect of supply of services by Head Office(HO)...

Use these paragraph cues to locate the operative part quickly, then read the full official PDF for conditions, exceptions, examples, effective dates and past-period regularisation language.

Workflow

  1. Identify issue.
    Record the taxpayer, supply, return period, order or refund event covered by Circular 210/04/2024-GST.
  2. Map source.
    Open the circular PDF with the Act, Rule and notification entries listed above.
  3. Compile proof.
    Tax invoice, e-way or delivery proof, books, GSTR-2A or GSTR-2B support, reversal/re-availment entries and board or contract notes.
  4. Close filing.
    Use the portal or officer channel that matches the event date and keep the acknowledgement with the source PDF.

Forms and downloadable source

Circular 210/04/2024-GST does not prescribe a separate static form PDF in its extracted source text. The operative document for this page is the circular PDF and the applicable Act, Rule, notification or portal process.

Do not use a form title by memory alone. Confirm the live portal, the rule that prescribes the form, historical return period and any officer instruction before upload or reply.

Highlighted advisory points

Scope

Circular 210/04/2024-GST should be confined to clarification on valuation of supply of import of services by a related person where recipient is eligible to full input tax credit; nearby issues require their own source check.

Evidence

Keep the official PDF, transaction documents and portal record together so a reviewer can reproduce the conclusion.

Version

For historical periods, use the law and portal version applicable to the event, not merely the current screen label.

Exam and advisory case study

In an exam answer, state the ITC condition, identify the mismatch or special fact, cite the circular's answer, and conclude with the accounting or return consequence. For Circular 210/04/2024-GST, a complete answer names the issue, lists the controlling provisions extracted above, applies the circular's operative answer, and then states what the taxpayer or officer must do in the return, refund, appeal, billing or record file.

Finin2min summary and Q&A

Summary: Circular 210/04/2024-GST is a source-specific GST clarification on clarification on valuation of supply of import of services by a related person where recipient is eligible to full input tax credit. Use the exact official PDF, not a generic circular checklist, and preserve the law/rule/notification map with the working file.

Is the circular itself the full law?

No. It clarifies administration under GST. The Act, Rules, notifications, court orders and facts of the transaction remain necessary.

When is a form PDF needed?

Only when the circular or linked rule actually points to a prescribed form. If the page lists forms, use the form compendium and the current GST portal version.

Can this be applied to another tax period?

Only after checking the effective date, amendment history and any past-period regularisation language in the official circular and related notification.

Primary official sources

CBIC circular metadata | Official CBIC PDF viewer | CBIC circular list | GST Council circulars

This Finin2min page is an educational working note. Official legislation, Gazette instruments, circulars, portal rules, court decisions and the facts of the matter prevail. Obtain professional advice for a live filing, refund, appeal or dispute.