India’s GST law treats exports and qualifying supplies to Special Economic Zone (SEZ) units or developers as zero-rated. A registered exporter generally chooses between supplying under a bond or letter of undertaking (LUT) without paying integrated GST and claiming eligible unutilized input tax credit (ITC), or paying integrated GST on the supply and claiming a refund under the applicable procedure. The route, export type and current eligibility rules determine what to file; zero-rated status does not guarantee recovery of every tax amount.
What zero-rated means for GST exports
Section 16 of the Integrated Goods and Services Tax Act (IGST Act) covers exports of goods or services and supplies to SEZ units or developers as zero-rated supplies. The section preserves input-tax credit for making zero-rated supplies, subject to restrictions under the Central Goods and Services Tax Act, and provides two alternative refund routes. This differs from simply calling a supply “tax-free”: the law provides mechanisms for eligible credit or tax refunds, subject to their conditions. Read section 16 of the IGST Act.
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Choose the refund route that fits the supply
| Question | Bond/LUT, without integrated tax | On payment of integrated tax |
|---|---|---|
| What is paid on the supply? | No integrated tax is paid under this option. | Integrated tax is paid on the supply. |
| What refund is sought? | Eligible unutilized ITC, subject to the statutory calculation and conditions. | Refund of integrated tax paid, subject to the applicable procedure. |
| Main process and records | Furnish a bond or LUT in FORM GST RFD-11 before the supply; use the relevant invoice endorsement and file the applicable refund claim and evidence. | For exported goods, the shipping-bill procedure applies, with export manifest/report and valid return conditions. Do not assume this goods procedure applies to exported services. |
| Important boundary | Rule 96A deadlines and consequences apply; check the operative rule for the filing date and facts. | The shipping bill is the deemed application mechanism described for goods, not a general process for every export. |
The statutory options are in section 16; refund applications, evidence and the ITC calculation are addressed in the refund rules. IGST Act, section 16; CGST Rules, refund provisions.
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Route A: supply without payment of integrated tax
A registered person using this option must furnish a bond or LUT in FORM GST RFD-11 to the jurisdictional Commissioner before making the supply. Rule 96A links the undertaking to the export of goods within the prescribed period or receipt of qualifying payment for exported services within the prescribed period. If the applicable requirement is not met and no extension applies, tax and interest consequences can follow. Because the available CBIC rules text is dated and amendments may affect deadlines, check the consolidated rule in force for the relevant filing date rather than relying on an older deadline summary. Rule 96A, CGST Rules.
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A refund of unutilized ITC is not automatically a refund of all tax paid on inputs. The refund rules use a formula involving zero-rated turnover, net ITC and adjusted total turnover; statutory definitions affect those figures. The applicant must debit the electronic credit ledger by the amount claimed. Use FORM GST RFD-01 for applicable refund categories, selecting the category and supporting statement relevant to the claim. CGST Rules, refund provisions.
Route B: exported goods on payment of integrated tax
For goods exported under rule 96, the shipping bill is treated as the refund application for integrated tax paid. It is deemed filed only after the export manifest or export report covering that shipping bill has been filed and the exporter has furnished a valid return. Electronic data exchange between the common portal and Customs supports export confirmation and refund processing. A shipping bill by itself does not complete these deemed-application conditions. The rule’s shipping-bill mechanism is specific to goods; it should not be applied by assumption to service exports. Rule 96, CGST Rules.
How do I claim a GST refund on exports?
Start by identifying whether the supply is goods or services and which of the two statutory routes applies. Then reconcile the invoice, return and export records to the relevant refund category. The precise portal workflow and validation requirements can change, so use the live GST portal instructions and the operative rules when filing.
- Select the route. Decide whether the supply will be made without integrated tax under bond/LUT, with an eligible unutilized-ITC claim, or on payment of integrated tax with a refund claim under the applicable process.
- For the no-payment route, furnish RFD-11 first. Submit the bond or LUT to the jurisdictional Commissioner before making the supply, and retain its reference and records of any formally allowed extension.
- Prepare the invoice and matching export records. Apply the prescribed invoice endorsement and match invoice particulars to shipping-bill or service-remittance details, as applicable.
- Check the claim category and supporting statement. For applicable categories, submit FORM GST RFD-01 electronically with the required statement and supporting particulars. For an unutilized-ITC claim, reconcile the statutory formula and debit the electronic credit ledger for the amount claimed.
- For goods using the tax-paid route, verify both filing conditions. Confirm the relevant export manifest/report has been filed and a valid return furnished; the shipping-bill route depends on both.
Which documents are needed for an export refund?
Use this as a preparation checklist, then verify the current refund category and portal requirements. The documents and statements vary by route and by whether the export is goods or services.
- Export invoice: Include the prescribed endorsement for the chosen route: “SUPPLY MEANT FOR EXPORT ON PAYMENT OF IGST” or “SUPPLY MEANT FOR EXPORT UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF IGST.” Check the invoice rule for all required particulars. CGST Rules, invoice provisions.
- Export of goods: Keep shipping-bill or bill-of-export details matched to the relevant export invoice. The refund rules call for a statement of shipping-bill/bill-of-export numbers and dates and corresponding export-invoice numbers and dates. CGST Rules, refund provisions.
- Export of services: Keep invoice numbers and dates and relevant Bank Realization Certificate (BRC) or Foreign Inward Remittance Certificate (FIRC) particulars. CGST Rules, refund provisions.
- Unutilized-ITC claim: Prepare the prescribed invoice statement for inputs and input services during the claim period; reconcile the turnover and credit figures to the statutory formula and account for the required electronic credit ledger debit. CGST Rules, refund provisions.
- Goods using the shipping-bill route: Check the export manifest/report and valid return conditions, in addition to matched export data. Rule 96, CGST Rules.
- No-payment route: Retain the RFD-11 bond/LUT reference and records relevant to rule 96A deadlines or any formally allowed extension. Rule 96A, CGST Rules.
Exceptions and limits to check
CBIC has clarified that a bond or LUT cannot be insisted upon for refund claims relating to exports without integrated tax of exempt or non-GST goods. This is a narrow clarification; it does not remove the ordinary LUT requirement for taxable exports made without integrated tax. Other legal requirements may still apply, and the clarification also addresses treatment of unutilized ITC. CBIC circulars; CBIC GST FAQs.
Export duty and other statutory restrictions can affect ITC refunds. The CBIC FAQ discusses this limitation, but an older FAQ is not a substitute for current consolidated law. Eligibility can also depend on whether the particular transaction meets the legal definition of export and on the taxpayer’s records; those questions cannot be resolved from the route alone. CBIC GST FAQs.
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CBIC procedural material includes older explanations, so do not treat historical processing descriptions or portal steps as current guarantees. Check the operative consolidated law and live portal instructions for the claim being filed; no refund eligibility or processing time can be guaranteed from the general rules alone.
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