The Tool Desk
Outbyte PC Repair FREEClear out junk files and repair common Windows errorsFree Scan →Outbyte Driver Updater FREEFix the driver behind crashes, sound loss and screen glitchesFind Drivers →There is no single certificate that proves an export of services under Indian GST. You need a transaction file that allows a reviewer to verify all five conditions in section 2(6) of the IGST Act: the supplier is in India, the recipient is outside India, the place of supply is outside India, consideration was received through a permitted route, and the parties are not merely establishments of the same legal person. The file should connect the contract, actual work, invoice, place-of-supply analysis and payment trail. A refund claim adds a specific requirement to report invoice numbers and dates with the relevant BRCs or FIRCs.
What “export of services” means for GST
Export treatment is a cumulative legal test, not a label applied because a customer has a foreign address or because money arrived from an overseas bank. The five conditions appear in section 2(6) of the Integrated Goods and Services Tax Act, 2017 (IGST Act). Read the official text at CBIC’s IGST Act page.
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| Condition | What your records should demonstrate |
|---|---|
| Supplier location | The taxable person supplying the service is located in India. |
| Recipient location | The recipient that receives the service is located outside India. |
| Place of supply | The applicable section 13 rule places the supply outside India. |
| Consideration | Payment has been received in the manner permitted by the IGST Act and applicable Reserve Bank of India (RBI) rules. |
| Separate establishments | Supplier and recipient are not establishments of the same person treated as distinct persons. |
Each condition needs evidence that is consistent with the others. A foreign-currency invoice, for example, does not cure a place-of-supply exception or a payment from the wrong entity.
The practical evidence file to maintain
The law does not publish one universal checklist naming every contract, email or work log. These documents are prudent substantiation: they make the statutory facts auditable and help reconcile your GST return, accounts and bank records.
#1 Best Overall
1. Supplier and recipient identity
- Your GST registration certificate or master-data extract showing the Indian supplier’s legal name, address and GSTIN.
- A signed service agreement, purchase order or engagement letter naming the customer’s legal entity, overseas business or residence address and the contracting establishment.
- Customer onboarding or due-diligence records identifying the entity that actually receives the service. Preserve incorporation details, tax-identification information or an official customer profile when available.
- Evidence explaining any different billing, contracting and receiving entities. If a parent company pays for a subsidiary’s service, document that relationship and why the named recipient is the recipient for GST purposes.
These records support the supplier and recipient-location conditions; they do not by themselves establish the place of supply.
2. What service was actually supplied
- The signed scope of work, statement of work, purchase order and amendments.
- Deliverables such as reports, designs, software releases, support tickets, training attendance or other outputs appropriate to the engagement.
- Dated correspondence, acceptance messages, milestone certificates or customer sign-off.
- Time sheets, work logs or ticket histories where the service is delivered over time.
- A short internal cross-reference linking each deliverable or milestone to the relevant invoice line and service period.
Keep records proportionate to the engagement. The purpose is to show what service was supplied, rather than to accumulate every email ever exchanged.
3. Place-of-supply analysis
Write a brief transaction-specific note identifying the section 13 provision that applies, the facts supporting it and any exception considered. Attach the contract clause and recipient records on which the conclusion relies. Section 13 generally uses the recipient’s location, but exceptions can move the place of supply to India. The current statutory text is on CBIC’s IGST Act page.
A foreign customer is therefore only one fact in the analysis. A note that simply says “customer is overseas” is not enough when the service is intermediation, relates to property or events, requires physical presence, or falls under another special rule.
4. Payment and remittance trail
- The issued invoice and an invoice-to-payment reconciliation showing amount, currency, value date and deductions.
- Bank statements, inward-remittance advice, payment processor records or other bank evidence that identifies the payer and beneficiary.
- Available Bank Realization Certificates (BRCs), Foreign Inward Remittance Certificates (FIRCs) or equivalent bank documentation appropriate to the payment route.
- An explanation for partial receipts, set-offs, credit notes, withholding, bank charges, a different payer or a payment received in several instalments.
- Exchange-rate and conversion workings used in your GST accounts, retained with the reconciliation.
BRCs and FIRCs are specifically named in the evidence statement for an export-of-services refund claim. They are not described in the cited material as the only document that can prove payment for every GST purpose; retain the strongest bank trail available for your route.
5. Separate-establishment evidence
Review whether the overseas recipient is a separate legal person or an establishment of the same person as the Indian supplier. Preserve group-structure charts, incorporation records, branch registrations, inter-company agreements and the relevant contract. A head office and branch, or another relationship treated as distinct persons, can defeat the fifth export condition even though the receiving office is abroad. The statutory definition and examples are in the IGST Act and CBIC’s sectoral FAQs.
Rank #3
Invoice documents and accounting records
Your invoice must satisfy the applicable CBIC invoice rules. The rules prescribe, among other particulars, the supplier’s name, address and GSTIN; a unique consecutive serial number and invoice date; recipient particulars as applicable; the accounting code for services; a description; taxable value; and relevant tax particulars. Service invoices ordinarily must be issued within 30 days from the date of supply, subject to the rule’s exceptions and the version applicable to the transaction. Check the current rules at CBIC’s GST Invoice Rules page.
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- Use a serial sequence that is unique and consecutive for the applicable financial year and entity.
- Describe the service consistently with the agreement, deliverable and accounting code.
- Show the overseas recipient’s details required for the transaction, and retain the source records used to establish its location.
- Keep copies of original invoices, revised invoices, credit notes and debit notes together with the reason for each adjustment.
The accounts-and-records rules require registered persons to maintain true and correct accounts of exported services and relevant documents. They expressly refer to invoices, credit and debit notes, receipt and payment vouchers, and refund vouchers. Maintain a consistent ledger-to-invoice-to-bank trail and retain records for the period required by the rules applicable to the taxpayer and transaction period. The rules are available at CBIC’s Accounts and Records Rules page.
How place-of-supply exceptions change the evidence you need
Section 13’s general recipient-location rule is subject to material exceptions. Before calling a supply an export, classify the service and document why the relevant sub-section applies.
| Service situation | Why it needs special checking | Evidence to retain |
|---|---|---|
| Intermediary, broker or facilitation service | The statute has a specific rule; the commercial fact that the customer is abroad does not settle the result. | Agreement showing your role, the parties to the underlying transaction, activities performed and the section 13 analysis. |
| Services by specified financial institutions to their account holders | A specific place-of-supply provision can apply instead of the general rule. | Account-holder status, service description and the institution’s relevant customer records. |
| Short-term hiring of a means of transport | The statute provides a special rule for specified hiring services. | Hire contract, period, vehicle or vessel details and customer location. |
| Goods made physically available, or services requiring a person’s physical presence | Location of performance or availability can control the place of supply. | Site records, travel or attendance evidence, delivery and possession records. |
| Immovable property, events and transport | Property location, event location or transport-related facts can displace the general rule. | Property address, venue contract, itinerary, route and performance dates. |
| Online information and database access or retrieval services | Special statutory provisions apply and may require different customer evidence. | Customer-status data, access logs and the facts used for the applicable provision. |
CBIC’s FAQ discusses a broker serving non-resident clients and a foreign firm facilitating software sales. Those examples illustrate why a label such as “commission” or “agency” cannot replace a legal characterization and place-of-supply analysis. See the CBIC sectoral FAQs.
Payment currency, INR receipts and RBI conditions
CBIC Circular No. 88/07/2019-GST explains that export proceeds for services may be realized in Indian rupees where RBI permits the arrangement. It also states that acceptance of a letter of undertaking (LUT) for covered supplies is permissible whether payment is in Indian currency or convertible foreign exchange, provided the arrangement follows applicable RBI guidelines. Read the circular at CBIC Circular No. 88/07/2019-GST.
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1Repair Windows errors before they cause bigger problems2Fix the driver behind crashes, sound loss and screen glitches3Clear out junk files and repair common Windows errorsThis is a qualified permission, not a blanket rule for every rupee payment. Verify the payment route and the RBI conditions in force on the payment date, and keep bank evidence showing how the permitted route was used.
“The supply of services, however, to Nepal or Bhutan will be deemed to be export of services only if the payment for such services is received by the supplier in convertible foreign exchange.”
CBIC, Circular No. 88/07/2019-GST
Do not generalize the ordinary INR clarification to supplies involving Nepal or Bhutan; apply the qualification in the circular and the rules relevant to the transaction.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Extra documents when claiming a GST refund
A refund claim for export of services has an express evidence requirement beyond ordinary substantiation. The refund rules call for a statement containing the number and date of invoices and the relevant BRCs or FIRCs, as applicable. The rule text is available at CBIC’s GST Refund Rules page.
Recommended Free Tools
- Build an invoice register listing every invoice included in the claim, its date, taxable value, currency and corresponding return period.
- Match each invoice to the BRC, FIRC or other relevant remittance record. Record the certificate number, date, amount and bank reference.
- Reconcile partial receipts, deductions, credit notes, foreign-exchange conversion and receipts spanning more than one invoice.
- Exclude invoices whose export conditions, payment evidence or place-of-supply analysis cannot be supported.
- Retain the underlying contract, delivery evidence, ledger and bank statement in the same indexed file in case the refund application is examined.
The exact electronic portal workflow, declarations and supporting uploads can vary by claim type and current procedure. Confirm the version in force when filing rather than relying on an old screenshot or checklist.
A step-by-step method for building a defensible file
- Identify the transaction. Assign an internal reference that appears on the contract, work papers, invoice register and reconciliation.
- Confirm the parties. Capture the Indian supplier’s GST details, the overseas recipient’s legal identity and the establishment that receives the service.
- Classify the service. Compare the actual activities with the agreement and accounting code. Flag agency, brokerage, facilitation, property, event, transport, physical-presence and online-service features.
- Write the place-of-supply note. Cite the applicable section 13 rule, explain the facts and address any exception.
- Preserve performance evidence. Save deliverables, acceptance, dated correspondence and proportionate work logs, then link them to invoice lines.
- Check the invoice. Verify the required particulars, serial sequence, date, service code, description and value under the applicable invoice rules.
- Reconcile payment. Match the invoice to bank evidence and available BRC/FIRC records; explain differences and confirm the RBI-permitted route, including any INR qualification.
- Run the distinct-person check. Document why the recipient is not an establishment of the same person as the supplier.
- Add refund material if applicable. Prepare the invoice-number/date statement and matched BRC/FIRC schedule required by the refund rules.
- Index and lock the file. Keep a read-only final copy with an index, version dates and an audit trail for later credit notes or additional receipts.
Common reasons evidence fails
- Relying on the customer’s address alone: A foreign address does not prove the place of supply or the recipient that actually received the service.
- Calling every commission an export: Intermediary and facilitation services require their own statutory analysis.
- Ignoring group structure: A foreign branch or other establishment of the same person can fail the distinct-establishment condition.
- Keeping only a foreign-currency invoice: The invoice says what you billed; it does not prove performance, place of supply or realization.
- Accepting an unmatched remittance: A bank credit with no invoice reference, or a payment from an unexplained third party, leaves the consideration trail incomplete.
- Using an outdated RBI assumption: INR treatment depends on the permitted route and the rules applicable at the time.
- Preparing the refund schedule late: Missing invoice dates, certificate references or reconciliation details can delay or weaken a refund claim.
What to review before relying on the file
Check amendments to the IGST Act, invoice rules, refund rules and accounts-and-records rules; notifications affecting exports; current portal instructions; and RBI permissions applicable to the payment date and route. Where the service has mixed features or the recipient’s establishment is unclear, obtain transaction-specific professional advice and preserve the factual analysis with the documents.
The strongest file is coherent: the contract describes the same service that the deliverables show, the invoice uses the same parties and description, the place-of-supply note fits the actual activity, and the bank record identifies the consideration for those invoices. That coherence—not one magic certificate—is what makes export treatment explainable in an audit or refund review.
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