Value declared accepted when recipient is eligible for full input tax credit
Where the recipient is eligible for full input tax credit, the value declared in the invoice shall be deemed to be the open market value of goods or services – proviso to rule 2 of Valuation Rules.
This is a very sensible provision as when the recipient can take entire input tax credit, there cannot be any intention to evade tax.
However, this proviso applies only in case of supplies covered under section 25(4) and 25 of CGST Act, i.e. supply is to own branch or division or godown.