Supplies to EOUs and against Advance Authorisation are treated as exports even though goods never leave India — and the tax paid is refundable.
Certain domestic supplies are notified under Section 147 as "deemed exports" — most commonly, supplies to Export Oriented Units (EOUs), or against an Advance Authorisation or EPCG licence. Unlike a real export, the goods never leave India and there's no requirement to receive payment in foreign exchange — but GST is still charged on the invoice at the time of supply.
Because the recipient uses these goods for further export production, the tax charged is refundable — but it can only be claimed once. Either the supplier claims it (with the recipient's written undertaking that they haven't availed ITC and won't also claim), or the recipient claims it directly. Both parties claiming on the same invoice is a guaranteed rejection.
The deemed-export-specific annexure filed with Form RFD-01.
Showing GST charged on the deemed export supply, tying back to the notified category.
Evidence the supply qualifies — a copy of the recipient's Advance Authorisation, EPCG licence, or EOU status.
A signed declaration that the recipient hasn't availed ITC on the supply and won't separately claim the refund.
Certification from the jurisdictional/specified officer confirming receipt of goods, where applicable.
Rule 89(2) declaration on unjust enrichment — self-declaration under ₹2 lakh, CA/CMA certificate above it.
Both supplier and recipient filing for refund on the same invoice — the single most common reason for rejection here.
Supplier claims without attaching the recipient's declaration that ITC wasn't availed.
The transaction doesn't actually fall within a category notified as a deemed export under Section 147.
Tell us on WhatsApp who should claim — supplier or recipient — and we'll handle the filing correctly the first time.
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