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Rule 30: Cost Plus Ten Per Cent, and What "Cost" Means

The third rung of every valuation ladder. 110% of cost sounds simple until you have to decide which cost — and the rule points at a standard most people have not read.

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GST
Published
September 5, 2026
Last updated
Sep 5, 2026
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5 min
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Last updated: September 2026Verified against: Government sources

Rules 27, 28 and 29 all end the same way: where the value cannot be determined, it shall be determined by Rule 30 or Rule 31, in that order.

Rule 30 is therefore the workhorse fallback — and it is one sentence long.

The text

"Rule 30. Value of supply of goods or services or both based on cost.— Where the value of a supply of goods or services or both is not determinable by any of the preceding rules of this Chapter, the value shall be one hundred and ten percent of the cost of production or manufacture or the cost of acquisition of such goods or the cost of provision of such services."

Three bases, one for each kind of supplier:

  • Cost of production or manufacture — a manufacturer supplying its own output.
  • Cost of acquisition — a trader supplying bought-in goods.
  • Cost of provision — a service provider.

Which cost

The rule gives no definition, and this is where practice fills the gap.

Cost of production or manufacture. The settled reference is CAS-4, the Cost Accounting Standard on Cost of Production for Captive Consumption issued by the Institute of Cost Accountants of India. It was used under central excise for exactly this purpose — valuing captive consumption at 110% of cost — and the same discipline carries over.

CAS-4 builds cost as: material consumed, direct wages and salaries, direct expenses, works overheads, quality control cost, research and development cost, packing cost, administrative overheads relating to production — less credit for recoveries, scrap and by-products.

Critically, CAS-4 excludes:

  • selling and distribution costs
  • interest and finance charges
  • abnormal losses and idle capacity costs
  • income tax and other taxes on income

Cost of acquisition. For a trader, the purchase price plus costs of bringing the goods to their present location and condition — freight inward, insurance, loading and unloading, and non-creditable duties. Creditable GST is not a cost.

Cost of provision of services. No standard is prescribed. A reasonable build-up of direct salary cost, direct expenses, and attributable overheads is the usual approach, documented on a consistent basis.

Where Rule 30 actually gets used

It is a fallback, so it appears only after earlier rules fail:

  • Rule 27(d) — consideration not wholly in money, no open market value, no like-kind comparable.
  • Rule 28(c) — related or distinct persons, no open market value, no comparable, and the full-credit proviso unavailable because the recipient makes exempt supplies.
  • Rule 29(b) — supply through an agent where the 90% option is unusable.
  • Stock transfers to a branch making exempt supplies — the most common real-world case.
  • Captive consumption between distinct persons where nothing comparable is sold to third parties.

Rule 30 also has a proviso in practice worth noting: for a supplier of services, the rule allows the option to skip Rule 30 and go directly to Rule 31, because cost of provision is often less determinable than a reasonable-means valuation.

The 10% mark-up

The uplift is a fixed proxy for profit. It is not evidence-based and cannot be adjusted:

  • a business making a 30% margin still values at 110% of cost;
  • a business making a loss still values at 110% of cost.

That asymmetry is the point of a deeming rule. It removes the argument, at the cost of accuracy.

Practical notes

  • Build the cost sheet before you need it. A Rule 30 valuation reconstructed under audit, from management accounts never designed for the purpose, is difficult to defend.
  • Use a consistent basis across periods and locations. Inconsistency is the fastest way to lose the point.
  • Exclude what CAS-4 excludes. Including selling costs or interest overstates the value and the tax.
  • Recompute periodically. Cost moves; a valuation fixed at the start of the year and never revisited will drift.
  • Where the recipient has full credit, check Rule 28's second proviso first. It deems the invoice value to be open market value and takes you off the ladder entirely. Supplies to related persons and Rule 28 →
  • Consider Rule 31 for services. A documented reasonable-means valuation may be both easier and more defensible than a synthetic cost of provision.

Key takeaways

  • Rule 30: 110% of cost — of production or manufacture, of acquisition, or of provision.
  • It applies only where Rules 27 to 29 fail.
  • "Cost" is undefined; the accepted reference for manufacture is CAS-4.
  • CAS-4 excludes selling, distribution, interest and abnormal costs.
  • The 10% uplift is fixed, regardless of actual margin.
  • Rule 28's full-credit proviso should be checked first — it usually avoids the ladder.

Read next

Disclaimer: Positions stated as on 5 September 2026, based on the CGST Rules as amended to 31 March 2026 (ICAI Bare Law, 12th edition).

Quick recapKey facts & short answers

Key Facts About Rule 30

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

When does Rule 30 apply?

Only where the value of a supply is not determinable under Rules 27, 28 or 29.

What is the value under Rule 30?

One hundred and ten per cent of the cost of production or manufacture, the cost of acquisition of the goods, or the cost of provision of the services.

Know which registrations your business actually needs — both too few and too many cost money.

— TaxClue Compliance Desk

Rule 30: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

Only where the value of a supply is not determinable under Rules 27, 28 or 29.

One hundred and ten per cent of the cost of production or manufacture, the cost of acquisition of the goods, or the cost of provision of the services.

The rule does not define it. For cost of production, CAS-4 issued by the Institute of Cost Accountants of India is the accepted reference.

No, if CAS-4 is followed. It excludes selling and distribution costs, interest and finance charges, and abnormal losses.

No. It is a fixed uplift regardless of the supplier's actual profitability.

In practice yes — a supplier of services may proceed directly to Rule 31 where cost of provision is not readily determinable.