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GST Classification Master

Import, Export and Zero-Rating Rate Test

Imports attract IGST at the border under Customs; exports are zero-rated under Section 16 IGST Act via LUT or pay-and-refund. Place of supply decides which rule applies.

Legal cut-off: 19 July 2026Updated: 28 July 2026Robots: index,followAuthors: CA Nikhil Gupta and Kajri Singh
Professional classification master. Imports attract IGST at the border under Customs; exports are zero-rated under Section 16 IGST Act via LUT or pay-and-refund. Place of supply decides which rule applies.
Finin2min answer: Imports are taxed, not exempted — IGST is levied on the value of imported goods under Section 5(1) of the IGST Act read with Section 3 of the Customs Tariff Act, and collected by Customs at the point of import alongside basic customs duty. Exports are the opposite: a "zero-rated supply" under Section 16 of the IGST Act, meaning GST is not charged AND the exporter can still recover input tax credit — either by exporting under a Letter of Undertaking (LUT) without paying IGST and claiming a refund of accumulated ITC, or by paying IGST on the export and claiming a refund of that IGST. Getting the place-of-supply and the export/import classification wrong is what turns a zero-rated or import transaction into an unexpectedly taxable or double-taxed one.

Imports: IGST at the Border, Not Inside GST Returns

Import of goods is treated as an inter-State supply, attracting IGST under Section 5(1) of the IGST Act, 2017, read with Section 3(7) of the Customs Tariff Act, 1975. IGST on imported goods is assessed and collected by Customs at the time of clearance, along with Basic Customs Duty (BCD) — it is not self-assessed and paid through a regular GSTR-3B like a domestic supply. The importer takes credit of this IGST based on the Bill of Entry, which functions as the tax invoice for import ITC purposes. Import of services, by contrast, is typically taxed under reverse charge by the Indian recipient rather than collected by Customs.

Exports: Zero-Rated Supply — Two Routes

RouteHow it worksWhat you recover
Export under LUT (no IGST paid)File a Letter of Undertaking; export without charging or paying IGSTRefund of accumulated, unutilised input tax credit attributable to the export
Export with IGST paymentPay IGST on the export supply as if it were taxable, then claim it backRefund of the IGST actually paid on the export

Both routes are genuinely "zero-rated" under Section 16 of the IGST Act — the exporter does not bear GST as a final cost either way. The LUT route avoids a cash outflow-and-refund cycle and is the more commonly used option for regular exporters; the pay-and-refund route is sometimes used where LUT eligibility conditions are not met or a specific commercial reason favours it.

Place of Supply: Why It Decides Whether GST Applies at All

Before applying any rate or exemption, confirm the place of supply. A transaction that looks like an export or import on paper only qualifies for zero-rating or import-IGST treatment if the place-of-supply rules under the IGST Act actually classify it as a cross-border supply — an intermediary arrangement, a supply completed entirely within India despite an eventual export, or a service performed for a foreign recipient but consumed in India can each fall outside the export/zero-rating treatment even though the invoice says "export."

Eight-stage method

  1. Define the supply and transaction date.
  2. Collect technical, commercial and contractual evidence.
  3. Determine goods/services and composite/mixed character.
  4. Classify under HSN/SAC using statutory interpretation rules.
  5. Match the current rate or exemption entry.
  6. Apply RCM, cess, place-of-supply and State counterparts.
  7. Calculate tax and test invoice/return reporting.
  8. Approve, archive and monitor later amendments.

Minimum review note

The conclusion should state the HSN/SAC, exact notification serial, rate components, conditions, effective date, contrary entries considered and supporting documents.

Primary sources

Finin2min Q&A

Can an HSN chapter determine the GST rate?

No. The exact heading, description, exclusions, conditions, notification entry and effective date must be matched.

Can a GST Council recommendation be applied directly?

No. Identify the implementing notification and commencement date.

Does a portal rate search replace classification?

No. It is an aid; the tariff, notification and evidence control the legal conclusion.

When should a rate page be indexed?

Only after exact current entry text, amendments, conditions, examples and reviewer approval are complete.

Finin2min rate-use note. Educational and professional reference. Verify the exact current notification entry, tariff notes, conditions, effective date, State counterpart and binding law before invoicing or filing.