Where no comparable supply of goods or services can be ascertained, ‘open market value’ shall mean the following:
(1)
in respect of goods, an amount that is not less than the purchase price of the goods or of similar goods or, in the absence of a purchase price, the cost price, determined at the time of supply;
(2)
in respect of services, an amount that is not less than the full cost to the taxable person of providing the service.