GST Alert: Gujarat HC on Corporate Guarantees


GST ALERT | AUGUST 2026

Gujarat High Court Rules in Torrent Power Ltd.

GST on corporate guarantees between related persons without consideration


In a landmark judgment dated 14 August 2026, the Gujarat High Court in Torrent Power Ltd. v. Union of India & Ors. ruled on the GST treatment of corporate guarantees between related persons — the validity of Rule 28(2), the temporal scope of the 1% deemed valuation, and the limits of Section 74.

How we got here

1
Service Tax era
Consideration essential; settled by Edelweiss (SC)
2
GST, pre-Rule 28(2)
Schedule I taxability; OMV valuation uncertainty
3
26 Oct 2023
Rule 28(2) introduced — 1% deemed value
4
Circulars 2023-24
Scope and retrospective intent clarified

Key findings of the Court

Taxability upheld

A guarantee by a holding company for its subsidiary is a supply between related persons under Schedule I, even without consideration.

Rule 28(2) & Sec 15(4) valid

Constitutional validity upheld: the statute permits a specialised valuation mechanism for related-party supplies.

No retrospective application

Rule 28(2) cannot apply before 26 Oct 2023. Guarantees continuing beyond that date attract GST prospectively.

"Whichever is higher" read down

Where actual consideration is ascertainable and lower than 1%, the deemed value cannot be forced on the taxpayer.

DOC

Circulars cannot override statute

CBIC circulars may operationalise the law but cannot create a levy; inconsistent portions cannot prevail.

Section 74 proceedings quashed

A bona fide dispute on unsettled law is not fraud, wilful misstatement or suppression; proceedings were quashed.

What businesses should do now


Pre-26 Oct 2023 guarantees
Rule 28(2) cannot apply. Evaluate refund or adjustment where GST was already discharged.
Post-26 Oct 2023 guarantees
Reassess valuation after the reading down of "whichever is higher"; adopt actual consideration where lower than 1%.
Section 74 proceedings
Test the sustainability of penalty proceedings raised on bona fide, legally unsettled positions.
Ongoing monitoring
An appeal to the Supreme Court cannot be ruled out. Stay cautious and track developments.