Exports Under GST: Deemed Exports & Refund Forms

Export of goods under GST is when goods are shipped from India to a place outside India and the supplier fulfils prescribed documentation and customs procedures. Specifically, the transaction must involve actual movement of goods out of India and export through approved ports or airports, with export bills of entry and shipping bills filed; otherwise it may not qualify. Exports of goods are generally treated as zero-rated supplies, meaning IGST can be exported under bond/LUT without payment or exported with payment of IGST and claim refund later. Note that supplies classified as 'deemed exports' (see below) are treated differently even though goods do not leave India.

Export of services under GST is when the supplier of services is located in India, the recipient is located outside India, the place of supply is outside India, and the payment is received in convertible foreign exchange or in Indian rupees from a person located outside India. All four conditions must be satisfied for a service to qualify as an export of services; if any condition fails the supply may not be zero-rated. Export of services is also treated as zero-rated, so the supplier can export under LUT/bond without paying IGST or pay IGST and claim a refund of tax paid. Note that transactions involving foreign branches or certain rupee receipts can be excluded depending on whether the consideration is from a person located outside India and in convertible currency.

Deemed exports under GST are particular domestic supplies of goods specified by statute that are treated as exports even though the goods do not leave India. Examples include supplies to Export Oriented Units (EOU), Special Economic Zones (SEZ) in certain situations, supplies against Advance Authorisation/DFIA, supplies to UN agencies, and supplies to projects awarded through international competitive bidding; these are listed under the GST law and notifications. Unlike normal exports, deemed exports do not involve physical cross-border movement, and suppliers may be eligible for refund or other benefits under notified procedures rather than the usual zero-rating mechanisms. Suppliers should check the specific notification conditions and documentation required to treat such supplies as deemed exports and claim any refunds or concessions.

Yes, you can export goods or services under a Letter of Undertaking (LUT) or bond without paying IGST, provided you meet eligibility and procedural requirements. Exporters who furnish a valid LUT or security bond can supply zero-rated exports without payment of integrated tax and later claim refunds of unutilized input tax credit, while those who do not furnish LUT can pay IGST at the time of export and claim refund of the tax paid. Furnishing an LUT typically requires meeting compliance conditions and is subject to safeguards prescribed by the tax authorities; exporters should retain proof such as shipping bills and invoices to support zero-rating claims.

Exporters can claim either a refund of unutilised input tax credit (ITC) when exports are made under LUT/bond without payment of IGST, or a refund of IGST paid on exports if tax was paid at the time of export. The refund claims are subject to prescribed forms, documentary evidence (such as shipping bills, export invoices, and bank realization certificates for services), and verification by tax authorities under the GST refund rules. Timelines and procedural safeguards apply, for instance, the refund claim must be filed within the statutory period and can be denied or adjusted if exports are found to be ineligible or documentation is incomplete.

For GST refunds on exports you must follow the prescribed refund application formats and submit supporting documents like shipping bills, commercial invoices, and LUT/bond or proof of IGST payment; the refund application is filed electronically on the GST portal using Form RFD-01. The RFD-01 is the standard refund application form where exporters attach evidence such as the shipping bill, export invoice, bank realization certificate for services, and LUT or proof of IGST payment, and the portal validates and processes the claim. Additional supporting forms or certificates may be required depending on whether the claim is for refund of unutilized ITC (exports under LUT) or refund of IGST paid (exports with payment), and tax officers may ask for further documents during scrutiny.

Exports are treated as zero-rated supplies under GST when goods or services are exported from India and the supplier either furnishes an LUT/bond and does not pay IGST, or pays IGST and claims a refund of the tax paid. Zero-rating means the outward supply is taxed at zero percent, allowing exporters to claim refund of unutilised input tax credit or refund of IGST paid, subject to compliance with documentation and procedural rules. This treatment applies to both exports of goods and exports of services that meet the statutory conditions (place of supply, supplier and recipient locations, and convertible foreign exchange payment where applicable).

A service qualifies as an export of service only if the supplier is located in India, the recipient is located outside India, the place of supply is outside India, and the payment is received in convertible foreign exchange or in Indian rupees from a person located outside India. All four conditions are cumulative, failure of any one (for example, if the recipient is located in India or payment is from an Indian entity in non-convertible terms) will disqualify the supply as an export of service. If the service does not meet these conditions it will not be zero-rated and input tax credit apportionment or reversal rules may apply instead. Examples include consultancy services to a foreign client paid in foreign currency and whose place of supply falls outside India.

Yes, supplies to specified entities such as EOUs, SEZs, United Nations agencies, and other notified projects are treated as deemed exports or are eligible for special export-related benefits under GST if they meet notification conditions. These supplies may attract zero-rating or allow suppliers to claim refunds or concessions under specific schemes (for example supplies to EOUs or supplies against Advance Authorisation/DFIA are listed as deemed exports). The exact treatment, whether treated as deemed export, zero-rated, or eligible for refund, depends on the nature of the supply and the applicable notifications and documentation requirements; suppliers must follow the prescribed procedure to claim benefits.