A corporate group with multiple entities and GSTINs faces a GST position that is greater than the sum of its parts. The related-party transactions—management fees, brand usage, guarantees, shared services—must be valued under Rule 28. The common input services must be routed through the ISD from April 2025. The group-level reconciliation must tie the entities’ returns to the consolidated financial statements.
The Related-Party Valuation
The group should document each related-party service, the consideration, the recipient’s ITC eligibility and the valuation basis. The Torrent Power read-down of Rule 28(2) and the KEI Industries zero-value principle provide the framework for the defence where the recipient has full ITC.
The ISD/Cross-Charge Architecture
The group should map each common input service to the ISD route and each internal cost allocation to the cross-charge analysis. The ISD registration and GSTR-6 filing are mandatory from April 2025 for eligible common input services.
The Group-Level Reconciliation
The group should reconcile the GSTR-1, GSTR-3B and GSTR-2B across all entities and GSTINs, and should tie the inter-company transactions to the consolidated financials. A group-level mismatch is a common trigger for a multi-entity notice.
What the Consultant Does
The consultant assists with the related-party documentation, the ISD/cross-charge mapping and the group-level reconciliation. The value is in the consolidated architecture that prevents an entity-by-entity notice cascade.
Call to Action: We advise corporate groups on related-party valuation, ISD/cross-charge architecture and group-level reconciliation. For a group-structure review, contact office@anujdesaiassociates.com, Ph No. 9619456656, Website https://anujdesaiassociates.com, LinkedIn linkedin.com/in/ca-anuj-desai-122547230.