Answer

GST

Exporter's GSTR-9 reporting of zero-rated sales

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  1. Facts

    Exports and supplies to SEZ are zero-rated and appear in Table 5 if made under LUT without tax, or in Table 4 if made with IGST paid. They must match GSTR-1 and shipping bill or invoice data.

  2. Provisions and law

    • Rule 80, CGST Rules 2017Annual return in GSTR-9 by 31 December after the financial year; GSTR-9C self-certified reconciliation where turnover is above Rs 5 crore
    • Sec 16, IGST Act 2017Exports and supplies to SEZ are zero-rated and can be made under bond or LUT, or with IGST and refund
  3. Analysis

    An exporter of services with Rs 3 crore of LUT exports reports them in Table 5 as zero-rated without payment of tax. If some exports were on IGST payment, those go in Table 4 with the tax. Refunds received during the year do not reduce turnover in GSTR-9. Make sure the LUT was in place for the year, since exports without LUT and without IGST create a demand risk.

  4. Conclusion

    1. Split exports into with-IGST and under-LUT
    2. Match each with GSTR-1 export tables and shipping bills or FIRCs
    3. Fill Tables 4 and 5 accordingly
    4. Keep the LUT acknowledgement for the year in the annual file

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