DETERMINE the GST liability of Niramaya Pharma Limited for the month of January, 2026.

9 Total GST Liability for January 2026 Particulars CGST (₹) SGST (₹) IGST (₹) Advance received for drug development services (to be provided to Jonson Biotech Ltd., Mumbai) 38,025 38,025 Nil Supply of bulk drugs to wholesale dealers in Mumbai 1,05,000 1,05,000 Nil Bulk drugs supplied to Fizer Alberta Inc., Canada (Export of goods) Nil Nil Nil Supply of drug development services to Bi-Con Life Ltd., Mumbai 1,27,800 1,27,800 Nil Supply of bulk drugs to consignment agents - ZYD Pharma Pvt. Ltd. (Haryana) & Arvind Medicos (Uttar Pradesh) Nil Nil 2,47,500 Supply of bulk drugs to Niramaya Healthcare Pvt. Ltd. (Aurangabad, Maharashtra) (Related Party Transaction - Open Market Value - 24,00,000 applied) 60,000 60,000 Nil Total GST Liability for January 2026 3,30,825 3,30,825 2,47,500 Notes Being an intra-State supply of services, supply of drug development services to Jonson Biotech Ltd. of Mumbai is subject to CGST and SGST @ 9% each. Further, in terms of section 13(2) of the CGST Act, the time of supply of services is the earlier of the date of invoice or date of receipt of payment, if the invoice is issued within 30 days of the supply of service. In the given case, invoice is issued within 30 days of the supply of service. Therefore, time of supply of services will be date of receipt of advance and hence, GST is payable on the advance received in January. 2. Being an intra-State supply of goods, supply of bulk drugs to ANZ Pharmaceuticals of Aurangabad, Maharashtra is subject to IGST @ 5%. Further, in terms of section 12(2) of the CGST Act, the time of supply of goods is the earlier of the date of issue of invoice/last date on which the invoice is required to be issued or date of receipt of payment. However, Notification No. 66/2017 CT dated 15.11.2017 specifies that time of supply of goods for the purpose of payment of tax is the date of issue of invoice/last date of issue of invoice. Thus, GST is not payable at the time of receipt of advance against supply of goods. The time of supply of the advance received for bulk drugs to be supplied to ANZ Pharmaceuticals is the time of issue of invoice, which is in April. Thus, said advance will be taxed in April and not in January. 3. Being an intra-State supply of goods, supply of bulk drugs to wholesale dealers of drugs in Mumbai is subject to CGST and SGST @ 2.5 % each. 4. Section 2(5) of the IGST Act defines export of goods as taking goods out of India to a place outside India. In view of the said definition, supply of the bulk drugs to Fizer Alberta Inc. of Canada under bond is export of goods. Export of goods is a zero-rated supply [Section 16(1) of the IGST Act]. A zero-rated supply under bond is made without payment of integrated tax [Section 16(3)(a) of IGST Act]. 5. Being an intra-State supply of services, supply of drug development services to Bi-Con Life Ltd. of Mumbai is subject to CGST and SGST @ 9% each. 6. Value of supply of goods made through an agent is determined as per rule 29 of the CGST Rules. Accordingly, the value of supply of goods between the principal and his agent is the open market value of the goods being supplied, or at the option of the supplier, is 90% of the price charged for the supply of goods of like kind and quality by the recipient to his unrelated customer, where the goods are intended for further supply by the said recipient. In the given case, since open market value is not available, value of bulk drugs supplied to consignment agents - ZYD Pharma Pvt. Ltd. and Arvind Medicos – will be - 49,50,000 [90% of (₹ 41,00,000 +14,00,000)]. Further, being an inter-State supply of goods, supply of bulk drugs to the consignment agents is subject to IGST @ 5%. 7. If any person directly or indirectly controls another person, such persons are deemed as related persons. [Clause (a)(v) of explanation to section 15 of the CGST Act]. In the given case, since Niramaya Pharma Ltd. owns 62.5% shares of Niramaya Healthcare Pvt. Ltd., both are related persons. Value of supply of goods between related persons (other than through an agent) is determined as per rule 28 of the CGST Rules. Accordingly, the value of supply of goods between related persons is the open market value of such goods and not the invoice value. Furthermore, since Niramaya Health care Pvt. Ltd is not eligible for full input tax credit, value declared in the invoice cannot be deemed to be the open market value of the goods. Thus, open market value of the bulk drugs supplied to Niramaya Healthcare Pvt. Ltd., i.e.24,00,000 is the value of supply of such goods. Further, being an intra-State supply of goods, supply of bulk drugs to Niramaya Healthcare Pvt. Ltd., is subject to CGST and SGST @ 2.5 % each.