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Impact of e-Invoicing on SEZ, Deemed Exports and Export Invoices

Updated on :  

08 min read.

Under GST Law, the export of goods or services is considered as zero-rated supply, and thus GST is not levied. An exporter has two options:

  1. Export under LUT/bond without payment of tax.
  2. Export by paying tax and claim a refund of it later.
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Latest updates on e-invoicing

24th February 2022
The e-Invoicing system will get extended to those annual aggregate turnover of more than Rs.20 crore up to Rs.50 crore starting from 1st April 2022, vide notification no. 1/2022

30th June 2021
The CBIC has issued a notification seeking to waive the penalty imposed on non-compliance of dynamic QR code provisions for B2C invoices between 1st December 2020 and 30th September 2021.

1st June 2021
CBIC has notified vide Central Tax Notification no.23 dated 1st June 2021 that the e-invoicing system shall not apply to a government department and local authority.

30th March 2021

The CBIC has issued a notification seeking to waive the penalty imposed on non-compliance of dynamic QR code provisions for B2C invoices between 1st December 2020 and 30th June 2021, provided the said person complies with the provisions of the said notification from 1st July 2021.


Applicability of e-Invoicing on SEZ, Deemed Exports & Exports

Exports are classified into direct exports, deemed exports, exports from SEZ units or SEZ developers. E-invoicing is applicable to export transactions to automate the refund mechanism to exporters under the following cases:

  1. Refund of the unutilised input tax credit on exports made without payment of tax.
  2. Refund on exports services provided with payment of tax.
  3. Refund of unutilised ITC with regards to sales made to SEZ Unit/SEZ Developer without payment of tax
  4. Refund of tax payment on supplies made to SEZ Unit/SEZ Developer.
  5. Refund to the supplier/recipient of taxes paid on account of deemed export supplies. Some of the examples of deemed exports are supplies made to export-oriented units, United Nations, mega power projects/nuclear projects through competitive bidding.

Note: As per notification no. 61/2020, SEZ units are exempted from issuing e-invoices. No exemption is available for SEZ developers.

Workflow Changes due to e-Invoicing in raising Export Invoices

With the introduction of e-invoicing, all B2B invoices are verified electronically by the GSTN for use on the GST portal. A unique identification number is issued against each invoice by the Invoice Registration Portal (IRP).

Exporters can continue furnishing information for availing incentives. The details include duty drawback serial number, advance/EPCG authorisation, and MEIS declaration details in invoice output. Thus, registration on the IRN portal will not have any impact on the exports invoices.

Also, in the e-invoice schema as notified by CBIC vide notification no. 60/2020 dated 30th July 2020, there are some additional fields for exports for which data can be taken from the bill of entry in ICEGATE such as additional currency code, place of supply, country code of export, port code, shipping bill number, date, export duty amount, etc.

Below is the list of exclusive fields to be reported by exporters in the e-invoice:

Name of the field

Description

Whether mandatory/optional?

Supply type code

He has to select the code of supply:

  • Supply to SEZ with payment 
  • Supply to SEZ without payment 
  • Export with payment 
  • Export without payment 
  • Deemed Export

Mandatory 

Additional Currency Code

Report additional currency, if any, in which all invoice amounts can be given, along with INR.

Optional

Supplier State Code

State Code of the Supplier as per GST System. The list is updated at https://www.icegate.gov.i n/Webappl/STATE_EN Q

Mandatory

Recipient_ GSTIN

URP: In case of exports or if supplies are made to unregistered persons

Mandatory

Place of Supply (State Code)

The list is updated at https://www.icegate.gov.i n/Webappl/STATE_EN Q

Mandatory

Recipient State Code

State Code of the recipient.

The list is updated at https://www.icegate.gov.i n/Webappl/STATE_EN Q

Mandatory

Country Code of Export

Code of the country of export as per the list

https://www.icegate.gov.i n/Webappl/COUNTRY_ ENQ

Optional

Port Code

For export supply, code can be mentioned as per the Indian Customs EDI system.

Optional

Shipping Bill Number

For export supply, shipping bill number can be mentioned as per the Indian Customs EDI system.

Optional

Shipping Bill Date

For export supply, shipping bill date can be mentioned as per the Indian Customs EDI system.

Optional

Export Duty Amount

Amount of export duty in INR should be mentioned.

Optional

Supplier Can Opt Refund

This field is for mentioning whether the supplier can exercise the option of claiming a refund.

Optional

Important Note for e-Invoicing Registration as an Exporter

At the time of registration on the IRP as an exporter, one needs to select the type of exporters such as regular export, deemed export, supplies from SEZ unit or SEZ developer. Exporters can use the existing invoice format for e-invoicing along with additionally capturing the QR code.

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