Answer

GST

Export of services refund queries on FIRC and BRC

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  1. Facts

    For export of services, proof of receipt of payment in convertible foreign exchange or as permitted by RBI is needed, such as FIRC, BRC or bank statements. Each invoice should be linked to its payment.

  2. Provisions and law

    • Sec 2(6), IGST Act 2017Conditions for a supply to be export of services, including receipt of payment in foreign exchange
    • Rule 89, CGST Rules 2017Refund application in RFD-01 with the documents and statements prescribed for each refund type
  3. Analysis

    Example: Statement 3 lists 20 invoices worth Rs 40 lakh, but FIRCs are consolidated monthly by the bank. Prepare a mapping sheet: invoice number, date, amount in foreign currency, FIRC or bank credit reference, and INR value. Bank charges deducted abroad should be explained. A clear mapping usually resolves the query.

  4. Conclusion

    1. Prepare an invoice-to-payment mapping sheet
    2. Attach FIRCs, BRCs or bank statements
    3. Explain short receipts due to bank charges
    4. Submit with RFD-09 or the fresh application

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Reply to refund deficiency memo RFD-03 and notice RFD-08

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