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Deemed exports under GST: Meaning, eligibility criteria, taxation, and refund claim process
Deemed exports under GST refers to transactions where goods are supplied within the country but treated as exports for tax purposes. Learn more in this blog.
Are you missing out on GST refunds for your domestic supplies? Many businesses assume that all exports involve cross-border trade, but that’s not always the case. In India, some transactions qualify as exports even when goods don’t leave the country. These are known as deemed exports under GST.
This blog explains deemed exports under GST — what they are, how they differ from regular exports, eligibility, GST rates, invoice format, and refund claims. It also covers key supply categories and required documentation.
This blog explains deemed exports under GST — what they are, how they differ from regular exports, eligibility, GST rates, invoice format, and refund claims. It also covers key supply categories and required documentation.
What is deemed exports under GST?
Under Section 147 of the Central Goods and Services Tax (CGST) Act, deemed export under GST refers to certain notified supplies of goods that do not leave India but are still treated as exports. These supplies are considered as such because payment is received in Indian rupees or convertible foreign exchange, and goods are manufactured in India.
Unlike typical exports, deemed exports are not exempt from GST. Instead, suppliers must pay GST on these supplies but are eligible to claim a refund of the tax paid, subject to specific conditions.1
Unlike typical exports, deemed exports are not exempt from GST. Instead, suppliers must pay GST on these supplies but are eligible to claim a refund of the tax paid, subject to specific conditions.1
Places determined for deemed exports supply
For deemed exports, “place of supply” refers not to geography but to designated recipients in India, such as notified units or projects vital to export promotion. Based on GST Council recommendations, the government specifies these supply categories, where goods stay within India yet support the export ecosystem. They include:
● Supply to Advance Authorization (AA) holders.
● Supply to Export Promotion Capital Goods (EPCG) holders.
● Supply to Export Oriented Units (EOUs), Electronic Hardware Technology Parks (EHTPs), Software Technology Parks (STPs), and Bio-Technology Parks (BTPs).
● Supply of gold by a bank or Public Sector Undertaking (PSU) against Advance Authorization.2
Conditions to qualify for deemed export under GST
To qualify as a deemed export, the following conditions must be satisfied:
● Only goods (not services) manufactured or produced within India are eligible.
● Supplied goods need not leave the Indian territory.
● Payment must be received in Indian rupees or convertible foreign exchange.
● Supply must be notified by the government as deemed export.
● Relevant documentation, such as a Letter of Undertaking (LoU), must be furnished.
● The tax must be paid on these goods but either the supplier or recipient can claim a refund.3
Additional conditions for deemed exports to EHTP / STP / BTP units
For transactions to be considered as deemed exports under GST in the case of EHTP / STP / BTP units or EOUs, certain additional conditions must be met:
● Prior information:
The recipient must provide prior intimation by filing Form A, informing the supplier and relevant GST officers about the details of the goods procured.
● Pre-approval by development commissioner:
The transaction must be pre-approved by the Development Commissioner.
● Tax invoice and supply:
The supplier can issue a tax invoice and proceed with supplying the goods.
● Endorsement of tax invoice:
Upon receiving the goods, the recipient should endorse the tax invoice and send a copy to the supplier and relevant GST officers.4
How are deemed exports taxed under GST?
Unlike physical exports, deemed exports are taxable supplies under GST. Suppliers are required to charge GST at the applicable deemed export GST rate. However, the tax paid can be claimed as a refund either by:
● The supplier (if the recipient does not avail ITC)
● The recipient (if the supplier chooses not to claim the refund)
The applicable GST on deemed export generally aligns with the standard rate for the goods being supplied unless notified otherwise.
Documents required to claim refund on deemed exports
To claim refunds on deemed export GST, the following documents are typically required:
● A detailed statement with invoice-wise data on deemed exports
● Copy of a signed tax invoice for each transaction
● Acknowledgment of receipt from the jurisdictional tax officer/authorized recipient
● Letter of Undertaking (LoU) affirming that no ITC or refund is being claimed again on the same supply by the recipient.6
● Copy of a signed tax invoice for each transaction
● Acknowledgment of receipt from the jurisdictional tax officer/authorized recipient
● Letter of Undertaking (LoU) affirming that no ITC or refund is being claimed again on the same supply by the recipient.6
Reporting requirements in GSTR–1 and GSTR–3B for deemed export
Under the GST framework, deemed exports must be accurately reported in the supplier’s GST returns to ensure transparency and enable refund processing.
In GSTR-1, which captures the details of outward supplies:
In GSTR-1, which captures the details of outward supplies:
● The supplier must report all deemed export transactions in Table 6C – Deemed Exports.
● This table is specifically meant for notifying supplies treated as deemed exports by the government.
● It requires key details such as GSTIN of the recipient, invoice numbers, invoice dates, taxable value, and the applicable tax amount.
In GSTR-3B, which is a summary return:
● The supplier should include the taxable value of deemed exports in Table 3.1(a) – Outward taxable supplies (other than zero-rated, nil-rated and exempted).
● The tax paid on such deemed export supplies should also be reported here under the respective GST heads (CGST, SGST, IGST).7
Procedure to claim a refund on deemed exports under GST
Suppliers or recipients eligible under deemed export under GST can claim a refund of the tax paid by filing an application through the GST portal. Here is a breakdown of the documents and steps involved in filing a refund for deemed export in GST:
Step 1: Prepare a detailed statement of supplies
Compile an invoice-wise statement (Form 5B), including the GSTINs of both supplier and recipient, invoice details, description and value of goods, and total GST paid.
Step 2: Obtain acknowledgment from the tax officer
After delivering the goods, secure an official acknowledgment from the jurisdictional GST officer or the authorized recipient. This proof is mandatory and confirms the legitimacy of the deemed export supply.
Step 3: Attach copy of signed tax invoice
Include clear, signed copies of tax invoices for each deemed export transaction. Ensure invoices are as per the official GST invoice format and mention their “deemed export” status.
Step 4: Submit application on GST portal
Once all documents are organized:
● Log in to the official GST portal.
● Navigate to Services > Refunds > Application for Refund.
● Choose the appropriate refund type – “Refund by Supplier/Recipient of Deemed Export.”
● Upload all supporting documents, including the detailed statement, tax invoices, acknowledgments, and other necessary documents.
● Submit the application.
The system generates an Application Reference Number (ARN) for tracking. A GST officer will review your claim, supporting documents, and invoices, possibly requesting clarifications if required.
● Log in to the official GST portal.
● Navigate to Services > Refunds > Application for Refund.
● Choose the appropriate refund type – “Refund by Supplier/Recipient of Deemed Export.”
● Upload all supporting documents, including the detailed statement, tax invoices, acknowledgments, and other necessary documents.
● Submit the application.
The system generates an Application Reference Number (ARN) for tracking. A GST officer will review your claim, supporting documents, and invoices, possibly requesting clarifications if required.
Step 5: Refund processing
Once the officer is satisfied with all documents and compliance requirements, the GST refund amount is credited directly to the applicant’s bank account registered under GST.8
Conclusion
Deemed export under GST is an important provision for Indian suppliers, offering a powerful way to recover taxes and encourage manufacturing for the export market even when goods stay within India. By adhering to eligibility and documentation criteria, and utilizing the GST portal’s streamlined refund facility, Indian businesses can access government incentives that bridge the gap between domestic and export supplies.
Amazon Global Selling: Easy e-commerce exports and hassle-free shipping
If you are a business owner and you want to sell your products to the world, Amazon Global Selling enables you to list and sell ‘Made in India’ products on 18 Amazon global marketplaces. As an e-commerce export program, Amazon Global Selling provides support and guidance at every step of your export journey, connecting you to Amazon’s Service Provider Network for tailored compliance, payments, and logistics support.
Registered sellers can choose to ship their products by themselves through Merchant Fulfilled Network (MFN) or they can opt for Fulfillment by Amazon (FBA) and outsource order fulfillment to Amazon including packing, storage, delivery, and returns. Amazon Global Selling simplifies the process of international shipping to the world, helping businesses navigate customs and reach a vast audience.
Registered sellers can choose to ship their products by themselves through Merchant Fulfilled Network (MFN) or they can opt for Fulfillment by Amazon (FBA) and outsource order fulfillment to Amazon including packing, storage, delivery, and returns. Amazon Global Selling simplifies the process of international shipping to the world, helping businesses navigate customs and reach a vast audience.
Frequently Asked Questions
1. When and how will the RFD-01 refund be processed?
After submitting a refund application in Form RFD-01 and receiving an Application Reference Number (ARN), the application is assigned to a Refund Processing Officer for review. Once approved by the jurisdictional authority, the refund amount is issued. Taxpayers can track the progress of their refund application using the monitor status feature.
2. What is the time limit for filing a refund claim for deemed exports under GST?
The refund claim for deemed exports under GST can be filed within two years from the date of filing the return. It is important to adhere to this time limit to ensure timely processing of the refund application.
3. Can deemed exports be done on a GST composition scheme?
No, suppliers registered under the GST composition scheme are not eligible to make deemed exports. Composition dealers cannot charge GST or issue tax invoices, which disqualifies them from refund eligibility under deemed export provisions.
Published on July 29, 2023.
Updated on September 25, 2025.
Sources:
1. https://www.mygstrefund.com/blog/deemed-exports-under-gst-guide/
2. https://taxguru.in/goods-and-service-tax/deemed-exports-gst-complete-detailed-analysis.html
3. https://www.mygstrefund.com/blog/deemed-exports-under-gst
4. https://cleartax.in/s/gst-taxation-deemed-exports#h4
5. https://www.credlix.com/blogs/a-complete-guide-to-deemed-exports-under-gst
6. https://www.credlix.com/blogs/a-complete-guide-to-deemed-exports-under-gst
7. https://cleartax.in/s/gst-taxation-deemed-exports#h6
8. https://cleartax.in/s/refund-process-under-gst#h3
Updated on September 25, 2025.
Sources:
1. https://www.mygstrefund.com/blog/deemed-exports-under-gst-guide/
2. https://taxguru.in/goods-and-service-tax/deemed-exports-gst-complete-detailed-analysis.html
3. https://www.mygstrefund.com/blog/deemed-exports-under-gst
4. https://cleartax.in/s/gst-taxation-deemed-exports#h4
5. https://www.credlix.com/blogs/a-complete-guide-to-deemed-exports-under-gst
6. https://www.credlix.com/blogs/a-complete-guide-to-deemed-exports-under-gst
7. https://cleartax.in/s/gst-taxation-deemed-exports#h6
8. https://cleartax.in/s/refund-process-under-gst#h3
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