GST circular working note

Circular 225/19/2024-GST: Clarification on various issues pertaining to taxability and valuation of supply of services of providing corporate guarantee between related persons

Source-led decode of CBIC Circular 225/19/2024-GST with the actual provisions, rules, forms and official PDF trail.

Reviewed by CA Nikhil Gupta · Updated 5 October 2026

Filing identity

Circular number

225/19/2024-GST

Date

2024-07-11

CBIC record

1003220

PDF source

official text PDF; 5 page(s)

Download Circular 225/19/2024-GST PDF

Form in 2 minutes

Circular 225/19/2024-GST deals with clarification on various issues pertaining to taxability and valuation of supply of services of providing corporate guarantee between related persons. Read it as a rate, classification and taxability mapping: identify the supply, supplier, recipient, tariff or service description, notification entry and event date before applying the circular. 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 various issues pertaining to taxability and valuation of supply of services of providing corporate guarantee between related persons, a practitioner should match the product or service facts to the circular's described entry instead of extending the answer to nearby supplies by label alone.

Bare law, rules and notifications

Sections extracted

Section 168 (1)
Section 31

Rules extracted

Rule 28(2)

Forms extracted

No GST form was expressly extracted from Circular 225/19/2024-GST.

Notifications and linked circulars

Notification No. 52/2023-Central Tax
Notification No. 12/2024-CT
Circular No. 204/16/2023-GST

The source map above is limited to citations actually extracted from the official Circular 225/19/2024-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

Para	Issue dealt with in the circular
1.1	As per the recommendations of the GST Council, sub-rule (2) was inserted in Rule 28 of Central Goods and Services Tax Rules, 2017 (hereinafter referred to as the “CGST Rules”) vide Notification No. 52/2023-Central Tax dated 26 th October, 2023 to provide for a specific clause for valuation of supply of services of providing corporate guarantee to any banking company or financial institution by an entity on behalf of a related...
1.2	In this regard, various representations have been received from trade and industry, seeking clarifications on various issues pertaining to the taxability and valuation of the supply of services of providing corporate guarantee between related persons as pe r the said rule.
2	Therefore, in order 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 Central Goods and Services Tax Act, 2017 (hereinafter referred to as “CGST Act”), hereby clarifies the issues as under: S. No. Issue Clarification
1	Whether sub-rule (2) of rule 28 of CGST Rules will apply to the corporate guarantees issued prior to insertion of the said sub-rule on 26 th October 2023? Also, where intra -group corporate guarantees have been issued before 26 th October 2023, which are still in force today, would they be liable to pay GST on “1% of the amount of such guarantee offered” on such guarantees? It is to be clarified that the supply of service of...
2	In cases where the corporate guarantee is provided for a particular amount, whereas the loan is only partly availed or not availed at all by the recipient, what will be the value of supply of corporate guarantee. Also, whether the recipient would be eligible to avail full ITC (Input Tax Credit) even before total loan is disbursed? The activity of supply of the service of providing a corporate guarantee is not linked with the...

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

Identify issue.
Record the taxpayer, supply, return period, order or refund event covered by Circular 225/19/2024-GST.
Map source.
Open the circular PDF with the Act, Rule and notification entries listed above.
Compile proof.
Contract, invoice description, product literature, HSN/SAC support, rate notification, exemption condition and tax-position memo.
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 225/19/2024-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 225/19/2024-GST should be confined to clarification on various issues pertaining to taxability and valuation of supply of services of providing corporate guarantee between related persons; 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

For exams and opinions, write the classification path: facts, statutory entry, notification condition, circular clarification, past-period treatment and practical billing result. For Circular 225/19/2024-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 225/19/2024-GST is a source-specific GST clarification on clarification on various issues pertaining to taxability and valuation of supply of services of providing corporate guarantee between related persons. 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.