Orion Fuel Palanpur (Gujarat) has entered into a contract with PrimeAxis Refinery, Abu Road (Rajasthan) on 1 st July to supply 10 valves on FOR…
CA Final · Indirect Tax Laws · MTP · May 2026
Orion Fuel Palanpur (Gujarat) has entered into a contract with PrimeAxis Refinery, Abu Road (Rajasthan) on 1 st July to supply 10 valves on FOR basis. The following information is provided in this regard: (1) List price per valve is 1,00,000, exclusive of taxes. (2) One of the conditions of the contract is that Orion Fuel should ensure a two stage third party inspection for the valves during the manufacturing process. Cost of two stage inspection of 15,000 (for 10 valves) is directly paid by PrimeAxis Refinery to testing agency. (3) PrimeAxis Refinery requires a special packing for the valves. Cost of special packing is 10,000 (for 10 valves). (4) Orion Fuel arranges for erection and testing of the valves supplied by it at PrimeAxis Refinery's site. Cost of erection etc. is 15,000 (for 10 valves). (5) Goods are dispatched with tax invoice on 20 th July and they reach the destination at Abu-Road on 21 st July. Lorry freight of 5,000 has been paid by PrimeAxis Refinery directly to the lorry driver. Assume CGST and SGST rates to be 9% each and IGST rate to be 18%. Opening balance of ITC of IGST is Nil, CGST is 20,000 and SGST is 20,000. All the given amounts are exclusive of GST, wherever applicable. You are required to compute the total output tax payable by Orion Fuel.
Suggested Answer and Working Notes:
Computation of output tax liability of Orion Fuel for the month of July Particulars Amount (₹) List price of 10 valves (₹ 1,00,000 x 10) 10,00,000 Add: Amount paid by PrimeAxis Refinery to testing agency [Note 1] 15,000 Add: Special packing [Note 2] 10,000 Add: Erection and testing at site [Note 2] 15,000 Add: Freight [Note 3] 5,000 Value of taxable supply 10,45,000 IGST @ 18% [Note 4] 1,88,100 Notes: (1) As per section 15(2) of the IGST Act, 2017, any amount that the supplier is liable to pay in relation to a supply but which has been incurred by the recipient of the supply and not included in the price actually paid or payable for the goods shall be included in the value of supply. Since, in the given case, arranging inspection was the liability of the supplier, the same should be included in the value of supply charges for the same, however, have been paid directly to the third party service provider by the recipient. Therefore, the value shall be included in taxable value. (2) As per section 15(2) of the CGST Act, 2017, any amount charged for anything done by the supplier in respect of the supply of goods at the time of, or before delivery of goods shall be included in the value of supply. (3) As per section 15(2) of the CGST Act, 2017, any amount that the supplier is liable to pay in relation to a supply but which has been incurred by the recipient of the supply and not included in the price actually paid or payable for the goods shall be included in the value of supply. Since, in the given case, the supply contract is on FOR basis, payment of freight is the liability of supplier but the same has been paid by the recipient and thus, should be included in the value of supply. (4) As per section 10(1) of the IGST Act, 2017, where the supply involves movement of goods, the place of supply is the location of the goods at the time at which the movement of goods terminates for delivery to the recipient, which in the given case is Abu Road (Rajasthan). Since the location of the supplier (Gujarat) and the place of supply (Rajasthan) are in two different States, the supply is an inter-State supply liable to IGST.
Topics: Value of Supply
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