Foreign currency on an invoice does not make a service an export. All statutory conditions must be satisfied together.
Prepare a transaction-by-transaction export test before treating supply as zero-rated.
Review contract and scope.
Contract and statement of work.
Using foreign address alone.
Section 2(6) of the IGST Act sets cumulative conditions: supplier in India, recipient outside India, place of supply outside India, permitted foreign-exchange receipt and no prohibited distinct-establishment relationship.
Place-of-supply rules can produce an Indian location for intermediary, performance-based, immovable-property or event services even where the customer is overseas.
FIRC, BRC or bank realisation supports receipt but does not prove recipient or place of supply.
| Area | What to establish | Operating rule |
|---|---|---|
| Parties | Supplier and real recipient. | Use contract substance. |
| Place | Applicable IGST place-of-supply rule. | Document analysis. |
| Payment | Convertible forex or permitted INR. | Link bank credit. |
| Relationship | Separate persons versus distinct establishments. | Review group structure. |
GST control should connect five records: commercial contract, tax invoice, movement or service evidence, accounting entry and portal return. A filing that cannot be traced back to all five records is difficult to defend.
Every reconciliation should have a clear opening balance, current-period additions, corrections, reversals, payments and closing balance. Avoid unexplained plugs that make the total match but do not identify the invoice or legal reason.
Portal data is important but not conclusive by itself. GSTR-2B, e-invoice, e-way bill and ledger data should be read with the statute, rules, notifications, contracts and actual supply evidence.
Keep original source files and final filed versions. Screenshots help explain a portal event but should not replace downloaded returns, JSON, signed invoices, acknowledgements or bank records.
For material exposure, prepare a written position memo stating facts, issue, law, alternatives, conclusion, amount and approval. The memo should record uncertainty rather than hide it.
Export and refund files should link invoice, shipping or service evidence, foreign-currency realisation, returns, ledger and claim statement. One unmatched identifier can delay the entire claim.
Age unrealised export invoices and unresolved refund queries separately so tax exposure and cash-flow exposure are visible.
Start with the GST portal record, responsible business owner and tax working. Where the issue is operational, correct the source system and retain the acknowledgement. Where it is legal or disputed, obtain a reasoned professional position before payment, reply, refund or appeal.
Track the statutory or portal deadline separately from internal approval. Preserve helpdesk tickets, ARN, hearing requests, orders and payment records so a later reviewer can reproduce the entire path.
Before filing or replying, prepare a one-page issue sheet showing GSTIN, tax period, transaction type, amount, applicable provision, portal form, evidence owner and due date. This prevents different teams from solving different versions of the same problem.
Reconcile tax by CGST, SGST, IGST and cess rather than only by total. A total can match even when the wrong tax head, state or period has been used, which can still create interest, cash-flow and customer-credit consequences.
Build an exception register with five statuses: identified, evidence pending, vendor or customer action, tax treatment approved and closed. Every exception should retain its original amount even after correction so the audit trail remains visible.
Test the position against the counterparty’s records. Customer ITC, vendor GSTR-1, transporter data, marketplace statements and bank receipts can expose differences that are invisible in the taxpayer’s own ledger.
The final approval should record who reviewed the legal position and who approved the return, reply, payment, refund or appeal. Material GST decisions should not remain buried in informal email chains.
Prepare an invoice-level claim statement that ties export or inverted-duty data to GSTR-1, GSTR-3B, shipping or service evidence and electronic ledgers.
Track rejected, withheld and sanctioned amounts separately. A partial sanction should not be recorded as full closure if the balance remains disputed.