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Indian GST-registered manufacturers exporting goods should keep one linked transaction file: the executed export contract or purchase order and amendments; production, stock and input-tax records; the correctly endorsed export invoice; shipping and transport documents; GST returns; and evidence for the chosen IGST, bond or letter-of-undertaking (LUT) route and any refund. The file must let an auditor trace the same buyer, goods, quantity, value, destination, invoice and shipment through the contract, factory records, GST reporting and Customs evidence.
This is a baseline for direct goods exports from India. Product restrictions, destination rules, regulated goods and special export schemes can require additional documents. It does not treat a manufacturer’s domestic sale to a merchant exporter as the manufacturer’s own zero-rated export.
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Build one file for each export contract or order
Use a unique file or electronic folder for every contract, purchase order or shipment series. A useful index connects these groups:
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- Production, raw-material, stock and inventory-movement evidence.
- Supplier invoices and other documents supporting input tax credit (ITC).
- Export tax invoice, packing list and related delivery documents.
- Shipping bill or bill of export, transport document and export confirmation.
- GSTR-1 export details, the relevant GSTR-3B or other applicable return evidence, and refund or LUT/bond records.
- Product- or destination-specific licences, certificates, NOCs and scheme documents, where applicable.
The purpose is not merely to store paperwork. It is to prove that the goods described in the agreement were manufactured or sourced, invoiced, reported, exported and, where claimed, refunded under the same transaction terms.
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GST books, manufacturing records and stock trail
Section 35 of the Central Goods and Services Tax (CGST) Act requires registered persons to keep records of production or manufacture, inward and outward supplies, stock, ITC availed, and tax payable and paid. The Act is available at CBIC’s CGST Act text. The CGST Accounts and Records Rules add supporting records such as invoices, delivery challans, credit and debit notes, vouchers and relevant e-way bills; see the CBIC accounts and records rules.
Production and input-to-output evidence
For each export batch, retain monthly production accounts showing quantitative raw materials or services used and quantities manufactured, including waste and by-products. Preserve batch sheets, bills of materials, job-work records, quality or inspection records used in the ordinary course, and the stock movement from opening balance through receipts, production, losses, write-offs, dispatch and closing balance. The records should show how the finished quantity on the export invoice came from available stock and production.
Purchases and ITC support
Keep supplier tax invoices and other eligible tax documents supporting ITC, together with purchase registers, goods-receipt evidence and payment or adjustment records used by your accounting system. Maintain supplier and buyer details, the premises where goods are held, advance accounts and invoice registers required by the applicable rules. If a supplier document is amended, retain the original and the correction so the ITC trail remains understandable.
Electronic records and backups
The accounts rules permit electronic records but require them to remain usable and reproducible. Keep a controlled backup in a form that can be restored within a reasonable period if records are destroyed by accident or natural causes. Record who can alter data, preserve audit logs where your system provides them, and periodically test restoration rather than assuming a backup is readable.
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Export GST invoice: particulars and endorsement
An export invoice must state the applicable endorsement: “SUPPLY MEANT FOR EXPORT ON PAYMENT OF IGST” or “SUPPLY MEANT FOR EXPORT UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF IGST”. The wording and export particulars are set out in the CBIC tax-invoice rules.
Retain the final invoice and its system record with:
- Exporter and recipient legal names and addresses.
- Delivery address and country of destination.
- Invoice number and date, item description, HSN or other applicable classification, quantity, unit value and total value.
- The application-for-removal number and date where the export-invoice rule requires that information in place of the ordinary recipient GSTIN detail.
- Currency, tax treatment, packing references and the contract or purchase-order identifier.
Keep cancelled and revised invoices with a clear reason and link to the replacement. The invoice, packing list and shipping bill should use compatible descriptions, quantities, values and marks; unexplained differences create avoidable Customs and refund questions.
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Customs and transport evidence for goods exports
DGFT’s Foreign Trade Policy Chapter 2 identifies the ordinary goods-export document set as:
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| Document | What to retain | Control to perform |
|---|---|---|
| Transport document | Bill of lading, airway bill, lorry receipt, railway receipt or postal receipt, as applicable | Match consignor, consignee, packages, weight, destination and shipment reference to the invoice and shipping bill. |
| Commercial invoice and packing list | Combined invoice-cum-packing list, or separate commercial invoice and packing list | Match item descriptions, quantities, net and gross weights, values and package counts. |
| Shipping bill or bill of export | Filed declaration and final electronic or paper copy, including number and date | Match exporter, invoice number and date, value, port, destination and declared goods. |
Keep electronic filing acknowledgements, amendments, examination or clearance records and the export manifest or report when they support an export or refund claim. Authorities may require more documents for restricted goods, policy conditions, NOCs or product-specific compliance. Check the current rule for the product and destination; the three-document baseline is not universal.
Choose and document the GST export route
CBIC describes two principal routes in its Sectoral FAQs: pay IGST on export and seek a refund, or export without IGST payment under a bond or LUT. Neither route is automatically preferable for every exporter; cash flow, eligibility and current rules determine the practical choice.
| Feature | IGST-paid export | Bond/LUT export without IGST |
|---|---|---|
| Tax at export | IGST is paid on the export supply. | No IGST is paid at export under the applicable bond or LUT. |
| Refund mechanism | Refund is linked to the shipping bill and export invoice after the goods are exported and return conditions are met. | Refund may concern accumulated ITC, subject to the applicable refund rules and supporting evidence. |
| Core file evidence | Shipping bill, corresponding invoice, export manifest or report evidence, GSTR-1 export data and the relevant return evidence. | Valid LUT or bond and filing evidence, invoices, return data and documents supporting any accumulated-ITC refund. |
| Cash-flow consideration | Tax is funded until the eligible refund is processed. | Less tax paid at export, but eligible ITC and refund conditions must be documented. |
IGST refund file
Rule 96 material in the CBIC GST Refund Rules treats the shipping bill as the refund application when its conditions are met. Retain the shipping bill, matching export invoice, evidence that the export manifest or report was filed, and proof that the required GSTR-3 or GSTR-3B return was furnished. Preserve the GSTR-1 export-invoice details and Customs confirmation that the goods were exported. Keep a statement or report linking each shipping-bill or bill-of-export number and date to the invoice number and date.
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Keep the LUT or bond, acceptance or filing acknowledgement, relevant invoices, return data and evidence supporting any refund of accumulated ITC. Refund forms and portal instructions can change, so verify the document list for the specific claim before filing. The LUT is not a substitute for the export invoice, shipping bill, transport proof or GST reporting.
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Contract, purchase order and amendment records
Retain the signed export contract or accepted purchase order and every amendment. Include technical specifications, approved samples or tolerances, price schedules, currency, payment terms, delivery point, destination, packaging requirements, inspection terms, insurance and the agreed allocation of freight, risk and export responsibilities. Keep correspondence that approves changes to quantity, price, description, delivery date or destination.
The contract file supports Customs declarations as well as commercial administration. The Customs Act wording reproduced in DGFT material says export declarations of value, quality and description certify conformity with the export contract entered into with the buyer or consignee; the relevant DGFT page is available here. A contract does not replace the GST invoice or Customs declaration. It gives those documents the agreed commercial baseline against which discrepancies can be investigated.
Reconcile the transaction before shipment and filing
- Freeze the commercial version. Mark the executed contract or purchase order and all approved amendments as the controlling version. Do not ship against an obsolete specification or price.
- Trace the goods. Link the production batch, raw-material consumption, finished-stock entry and packing record to the quantity and description being exported.
- Validate the invoice. Check the export endorsement, invoice number and date, destination, currency, value, quantity, classification and removal-application details where applicable.
- Cross-check Customs data. Compare the invoice and packing list with the shipping bill or bill of export and the transport document before final submission.
- Reconcile GST reporting. Confirm that the export invoice number, date, value and tax treatment reported in GSTR-1 agree with the invoice and the relevant return.
- Complete the route evidence. For IGST-paid exports, capture manifest or export confirmation and refund linkage. For LUT or bond exports, capture the valid instrument, acknowledgement and any ITC-refund records.
- Close the index. Record the contract identifier, invoice, production references, shipping bill, transport document, return period and refund or LUT evidence in one index, then lock the completed file against unapproved edits.
How long must the records be kept?
Section 36 of the CGST Act states: “Every registered person required to keep and maintain books of account or other records in accordance with the provisions of sub-section (1) of section 35 shall retain them until the expiry of seventy-two months from the due date of furnishing of annual return for the year pertaining to such accounts and records.” Calculate the date from the applicable annual-return due date for the relevant financial year; do not count 72 months from the invoice date. Confirm the current consolidated provision before authorising destruction.
If the records relate to an appeal, revision or other proceeding before an authority, tribunal or court, or to an investigation for an offence under Chapter XIX, retain them for one year after final disposal or for the ordinary period, whichever is later. Keep records at the registered places of business as required, or ensure that the prescribed location and access requirements are met.
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Cases needing extra care
Regulated products and special destinations
Pharmaceuticals, food, chemicals, dual-use items, plant or animal products, dangerous goods and other controlled categories can require licences, certificates, testing records, NOCs or destination-specific declarations. Special economic-zone, incentive, drawback or other schemes can add their own evidence. Identify the product and destination before accepting the order and add the required documents to the same indexed file.
Manufacturer supplying a merchant exporter
A manufacturer’s sale to a merchant exporter is a domestic supply unless a specific legal provision says otherwise. The merchant exporter’s later shipment may be the zero-rated export, but that does not turn the manufacturer’s invoice into an export invoice or make the manufacturer eligible to claim the merchant exporter’s refund. Keep the domestic GST invoice, dispatch and delivery evidence, and any documents required for the particular concessional or procurement arrangement separately from the merchant exporter’s Customs file.
Amended or split shipments
When one order ships in parts, maintain a shipment schedule linking each invoice, packing list, shipping bill, transport document and production batch to the relevant contract line. If prices, quantities or destinations change, retain the amendment approval and explain the effect on open invoices, returns and refund claims.
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- Using a domestic invoice endorsement on an export shipment.
- Allowing invoice, packing-list and shipping-bill descriptions or quantities to diverge without a documented correction.
- Keeping the shipping bill but not the transport document or export-manifest evidence needed for refund support.
- Claiming ITC without retaining the supplier tax document and receipt or accounting trail.
- Destroying records 72 months after the invoice instead of calculating from the annual-return due date.
- Deleting superseded contracts or amendments, leaving no explanation for changed value, quantity or destination.
- Treating the ordinary three-document export set as sufficient for restricted goods or a special scheme.
A disciplined index and a reconciliation performed before filing are the simplest ways to expose these gaps while the transaction can still be corrected.
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