Reporting Export Details for GST Refunds in GSTR-1 Table 6A

Table 6A of GSTR-1 mandates the reporting of export particulars. Under the Goods and Services Tax (GST) framework, exports are categorized as zero-rated supplies. Entities providing zero-rated supplies receive specific advantages under GST regulations, comparable to those under customs law.

Latest Updates

Recent legislative updates from Budget 2022 have altered crucial compliance deadlines. The window for making amendments or corrections in GSTR-1, including uploading delayed invoices or debit/credit notes for a financial year, has been extended to November 30th of the subsequent year or the annual return filing date, whichever occurs earlier. Additionally, these amendments mandate sequential filing of outward supply details for each tax period.

Definition of Exports Under GST

Under GST, the export of goods signifies their physical movement from India to an international location. The primary legal and procedural framework for such exports is defined by the Customs Act.

For services, GST considers them exported only upon meeting five specific criteria. Unlike goods, the legal and procedural aspects of service exports are exclusively governed by Indian GST law. The five essential conditions are:

• The service provider must be located in India.
• The service recipient must be located outside India.
• The place of supply must be outside India.
• Payment must be received in convertible foreign exchange, or in Indian rupees if permitted by the Reserve Bank of India (RBI).
• The relationship between the service provider and recipient must not be that of a distinct person, as defined by GST law.

This condition clarifies that transactions between a head office and its branch, where one is outside India, do not qualify as exports but rather as interstate supplies, thereby rendering export benefits inapplicable.

Taxes and Duties on Exports

Typically, goods designated for export incur specific taxes and duties, mirroring those applied to imports:

• Basic Customs Duty: Applied at the relevant rate based on the goods' classification, calculated on the assessable value.
• Social Welfare Surcharge: Levied at 10% of the basic customs duty.
• Integrated Goods and Services Tax (IGST): Charged at 18% or the notified GST rate, on the total of the assessable value plus basic customs duty plus social welfare surcharge, unless specifically exempted under customs or GST law.
• Cess: If applicable, charged at the notified rate under GST law on the total of the assessable value plus basic customs duty plus social welfare surcharge.

Service exports are generally liable for IGST and any applicable cess.

It is important to note that Indian GST law classifies all exports as inter-state supplies, meaning only Integrated GST (IGST) applies, not Central GST (CGST) or State/Union Territory GST (SGST/UTGST).

Benefits for Exporters Under GST

Exporters are eligible to claim a refund for IGST paid on most exports, with specific exceptions. If IGST was not paid on exports conducted under a Letter of Undertaking (LUT) or bond, exporters can still seek a refund. In these instances, the accumulated Input Tax Credit (ITC) on raw materials or input services utilized for such exports will be reimbursed.

GST Refund Process for Exported Goods and Services

For GST refunds, taxpayers engaged in exporting goods or services have two primary options:

• Refund of Accumulated Input Tax Credit: This applies when goods or services are exported without IGST payment, under the cover of a bond or Letter of Undertaking (LUT).
• Refund of IGST Paid on Exports: This option is for exports where IGST was paid after setting off available input tax credit, and without a bond/LUT, except in the following situations:
  • Goods exported from India that are subject to export duty.
  • If a drawback is claimed for taxes paid on the export of goods or services.
  • Deemed exports, excluding capital goods exported under the Export Promotion Capital Goods Scheme (Notification 48/2017-Central Tax, dated October 18, 2017).
  • Exporters of goods or services who paid concessional tax for intra-state purchases subsequently used in making such exports (Notification 40/2017-Central Tax (Rate), dated October 23, 2017).
  • Where IGST is exempted for such exports of goods or services from designated areas like Export Oriented Units (EOU), Software Technological Parks (STP), or Hardware Technological Parks (HTP), as notified under customs law (Notifications 78/2017 and 79/2017-Customs, dated October 13, 2017).

In either scenario, the GST refund process requires reporting details in Table 6A of GSTR-1, followed by the submission of the monthly summary return, GSTR-3B. For goods exported with IGST payment, the shipping bill or bill of export serves as the direct application for the IGST refund.

The GST Officer cross-references the shipping bill information provided in the exporter's GSTR-1 with the data available on the ICEGATE portal. If the declarations are found satisfactory, the refund amount is credited to the taxpayer's bank account registered for GST. However, service exporters who paid IGST must additionally complete their refund claim using Form RFD-1 on the GST portal, in conjunction with GSTR-1 and GSTR-3B. A critical prerequisite is to report the Bank Realisation Certificate (BRC/FIRC) number for the export invoice. An Application Reference Number is generated post-submission online, and the GST officer will proceed with the refund claim after verification.

Similarly, the procedure for claiming a refund of accumulated Input Tax Credit (ITC) without IGST payment on exported goods and services largely follows this pattern. This begins with the exporter submitting a Letter of Undertaking (LUT) before initiating exports and adhering to stipulated deadlines. Exporters are required to declare 'zero' for 'Tax amounts' when completing Table 6A and Table 6B of GSTR-1. Following successful export, the accumulated ITC details are reported via Form RFD-01 on the GST portal to initiate the refund application.

A note indicates that under the GST returns system proposed for April 2020, details would be filled invoice-wise in Form ANX-1 and automatically populated into returns like RET-1, RET-2, or RET-3.

Timelines for Claiming GST Refund on Exports

Specific timelines govern the claim process for GST refunds on exports, based on the type of export and the stage of completion:

Guide to Filling Table 6A of GSTR-1 on the GST Portal

Follow these steps to accurately fill Table 6A of GSTR-1 on the official GST portal:

Step 1: Access the GST portal and log in.

Step 2: Navigate to 'Services', then 'Returns', followed by 'Return Dashboard', and finally select 'GSTR-1'.

Step 3: Choose the appropriate month for which you intend to file Table 6A of GSTR-1 and click 'SEARCH'.

Step 4: Click on the 'Table 6A of FORM GSTR-1' tile.

Step 5: Initiate the return filing process by clicking the 'ADD INVOICE' button.

Step 6: On the 'Exports – Add Details' page, input the particulars for each invoice and click 'SAVE'. The tile will display the count of added invoices, and taxpayers retain the option to modify these invoices.

• Enter the invoice generation date in the 'Invoice Date' field.
• Provide the alphanumeric six-character 'port code' as stipulated by ICEGATE.
• The 'Shipping Bill No./Bill of Export No.' field requires the unique shipping bill number, including the location code, generated during shipping. This number can serve as the invoice identifier and must be a numeric value between 3 and 15 digits.
• Complete the 'Shipping bill date' in its designated field.
• Report the 'total invoice value', representing the total amount for all supplied goods or services.
• From the 'GST payment' dropdown list for each invoice, select either 'WPAY' (with payment of IGST on exports) or 'WOPAY' (without payment of IGST on exports).
• For the query 'Is the supply eligible to be taxed at a differential percentage (%) of the existing rate of tax, as notified by the government?', either check the box to confirm or leave it blank.
• Populate the 'Taxable Value' field with the value subject to GST, net of GST.

Note: The 'amount of tax' fields automatically populate based on the 'Taxable Value' entries and can be edited. This functionality is only available when exports are made with tax payment.

Step 7: Complete the remaining sections of GSTR-1 before submitting the return.

Step 8: The saved invoices will be displayed under 'Processed Invoices'. You can edit or delete an invoice using the respective buttons under 'Actions'. After verifying all entered invoices, click the 'FILE RETURN' button.

Step 9: Tick the verification checkbox and select the 'Authorised Signatory' from the dropdown menu. Proceed to file the return using either DSC (Digital Signature Certificate) or EVC (Electronic Verification Code).