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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.

Latest updates on e-invoicing

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.

8th March 2021
The CBIC has notified that e-Invoicing will be applicable from 1st April 2021 for businesses with an aggregate turnover of more than Rs.50 crores (in any financial year from FY 2017-18 onwards).

29th November 2020
The CBIC 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 31st March 2021, provided the eligible registered person complies with these provisions from 1st April 2021.

10th November 2020
The taxpayers having an aggregate turnover exceeding Rs.100 crore should implement e-invoicing from 1st January 2021.

1st October 2020
The applicable taxpayers have been given a grace period of 30 days for generating an Invoice Reference Number (IRN). However, this grace period is valid for the invoices issued between 1st October 2020 to 31st October 2020.

30th September 2020
Now, the aggregate turnover should be checked from FY 2017-18 till FY 2019-20, for checking the applicability of e-invoicing. Also, the date of implementation of the dynamic QR Code for B2C invoices has been extended until 1st December 2020.

30th July 2020
1. A new refined format of e-invoice has been notified by CBIC adding 20 new fields and removing 13 fields. Certain fields have undergone changes in character length as well.
2. e-Invoicing system shall apply to those taxpayers with an annual turnover exceeding Rs 500 crore instead of Rs 100 crore.
3. Special Economic Zones (SEZ) units shall also be exempted from issuing e-invoices.

23rd March 2020
The implementation of e-invoicing and the QR code has been deferred to 1st October 2020.
Exemption from e-Invoicing and QR code has been granted to sectors such as insurance, banking, financial institutions, NBFCs, GTA, passenger transportation service and movie tickets.

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-invoice. 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


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


Additional Currency Code

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


Supplier State Code

State Code of the Supplier as per GST System. The list is updated at n/Webappl/STATE_EN Q


Recipient_ GSTIN

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


Place of Supply (State Code)

The list is updated at n/Webappl/STATE_EN Q


Recipient State Code

State Code of the recipient.

The list is updated at n/Webappl/STATE_EN Q


Country Code of Export

Code of the country of export as per the list n/Webappl/COUNTRY_ ENQ


Port Code

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


Shipping Bill Number

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


Shipping Bill Date

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


Export Duty Amount

Amount of export duty in INR should be mentioned.


Supplier Can Opt Refund

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


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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