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How to Prepare GST-Compliant Invoices for Software and IT Service Exports in India

By Freedom251 Team · · 4 min read

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To invoice an Indian software or IT service export, first confirm that the transaction qualifies as an export under GST, then issue a service tax invoice with the particulars required by Rule 46 of the CGST Rules and the export endorsement that matches your route: payment of IGST or export under bond or letter of undertaking (LUT) without payment of IGST. A foreign customer alone does not establish export status, and software can be classified as either a service or goods depending on what is supplied and how.

First check whether the supply qualifies as an export

For GST purposes, a supply is an export of services only when all the statutory conditions are met. CBIC’s sectoral FAQ lists these five conditions: the supplier is located in India; the recipient is located outside India; the place of supply is outside India; payment is received in convertible foreign exchange; and the supplier and recipient are not merely establishments of a distinct person under the relevant explanation in the IGST Act. A foreign billing address does not, by itself, settle these tests. CBIC’s sectoral FAQ

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Place of supply can depend on the service category, the recipient’s structure and the contract. The FAQ offers general observations for IT and IT-enabled services, but those observations do not resolve every exception or unusual arrangement. Check the applicable statutory provision and transaction facts, particularly where related establishments, intermediaries or multiple kinds of supply are involved.

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Classify the software arrangement before invoicing

The contractual deliverable and its delivery method matter. CBIC’s FAQ treats development and related work as services, while certain pre-developed or pre-designed software supplied on storage media or made available through encryption keys is treated as goods. The label on a contract or invoice is not a substitute for reviewing what the customer actually receives.

Arrangement described in CBIC’s FAQ General treatment in the FAQ What to examine
Development, design, programming, customization, adaptation, upgrading, enhancement or implementation work Service The contracted work, deliverables and actual supply
Pre-developed or pre-designed software supplied on storage media or through encryption keys Goods Whether the transaction is for a product supplied by one of these methods

This is a general classification summary, not a ruling on every licence, subscription, access model or mixed contract. Use the transaction’s facts and current law to determine the treatment.

Choose the export route before adding the endorsement

Official guidance describes two broad zero-rating routes. One involves paying IGST on the export and claiming a refund of the IGST paid; the other involves exporting without payment of IGST under bond or LUT and claiming a refund of eligible accumulated input tax credit. For service exports made without payment of IGST, CBIC’s FAQ says an LUT or bond is required under Section 16(3) of the IGST Act read with Rule 96A of the CGST Rules. CBIC’s sectoral FAQ and IGST Act

Route IGST treatment on export Refund sought Document endorsement
Payment of IGST IGST is paid on the export Refund of IGST paid, subject to applicable conditions “SUPPLY MEANT FOR EXPORT/SUPPLY TO SEZ UNIT OR SEZ DEVELOPER FOR AUTHORISED OPERATIONS ON PAYMENT OF INTEGRATED TAX”
Bond or LUT without payment No IGST is paid on the export Refund of eligible accumulated input tax credit, subject to applicable conditions “SUPPLY MEANT FOR EXPORT/SUPPLY TO SEZ UNIT OR SEZ DEVELOPER FOR AUTHORISED OPERATIONS UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX”

The invoice endorsement must match the route actually used. The two routes have different cash-flow and refund implications; neither is universally preferable. Verify current eligibility, filing requirements, refund conditions, restrictions and return procedures for your circumstances. The IGST Act and CBIC FAQ describe the broad framework, but the FAQ is not a complete current refund checklist.

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Include the required invoice particulars

Rule 46 of the CGST Rules sets out the general particulars for a tax invoice. For an export invoice, check the applicable fields against the current rule and include the export-specific recipient and destination particulars. The live rule also contains the prescribed endorsements and provisions for e-invoicing. CGST Rules, Rule 46

  • Supplier’s name, address and GSTIN.
  • A consecutive serial number unique for the financial year and within the prescribed character constraints, plus the date of issue.
  • Recipient identity and address particulars required by the rule.
  • Service accounting code, description of the service and total value, along with any other applicable particulars.
  • For the export, the recipient’s name and address, delivery address and country of destination.
  • The exact export endorsement for the route selected.

Where the prescribed e-invoice mechanism applies, Rule 46 provides for the relevant IRN and QR-code requirements. Confirm the current rule wording and amendments when creating or updating an invoice template; do not assume a template prepared for one route or software arrangement will suit another.

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Check invoice timing, e-invoicing and returns separately

Invoice timing

CBIC’s invoice-rules page states that a tax invoice for taxable services is generally to be issued within 30 days from the date of supply, subject to specified exceptions. Apply the relevant rule to the facts and service arrangement rather than treating the general period as an answer to every timing question. CBIC invoice rules

E-invoice applicability

E-invoice coverage depends on the prescribed requirements and applicable exemptions. Rule 46 addresses invoice reference number and QR-code particulars where the e-invoice mechanism applies, but the sources cited here do not establish whether a particular exporter is covered. Verify current requirements for your business rather than assuming all exporters have the same status. CGST Rules, Rule 46

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Export reporting

GST portal guidance treats exports generally as zero-rated inter-State supplies and explains their GSTR-1 reporting context. Follow the applicable reporting instructions for the route used and the transaction. GST portal GSTR-1 guidance

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GSTIGSTIndiaInvoicingIT servicesLUTsoftware exports

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