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

Updated on: May 15th, 2023


7 min read

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Many businesses get confused if the export of goods or services or zero-rated supply gets covered under e-invoicing. An exporter either exports under LUT/bond without paying tax or exports by paying tax and later claiming a refund of it. The article attempts to clarify this in detail.

Latest updates on e-invoicing

10th May 2023
The CBIC notified the 6th phase of e-invoicing, applicable to businesses with a turnover exceeding Rs.5 crore in any financial year from 2017-18 w.e.f. 1st August 2023.

6th May 2023
The GST department has deferred the time limit of 7 days to report the old e-invoices on the IRP portals by three months. Further, the department is yet to announce the new implementation date.

13th April 2023
As per the GST Network's advisories dated 12th April 2023 and 13th April 2023, taxpayers with annual turnover equal to or more than Rs.100 crore must report tax invoices and credit-debit notes to IRP within 7 days of invoice date from 1st May 2023.

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

Exports are classified into direct exports, deemed exports, and 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 export 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 fieldDescriptionWhether 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 CodeReport additional currency, if any, in which all invoice amounts can be given, along with INR. Optional
Supplier State CodeState Code of the Supplier as per GST System. The list is updated at https://www.icegate.gov.i n/Webappl/STATE_EN QMandatory
Recipient_ GSTINURP: In case of exports or if supplies are made to unregistered personsMandatory
Place of Supply (State Code)The list is updated at https://www.icegate.gov.i n/Webappl/STATE_EN QMandatory
Recipient State Code

State Code of the recipient.

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

Country Code of Export

Code of the country of export as per the list

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

Port CodeFor export supply, code can be mentioned as per the Indian Customs EDI system. Optional
Shipping Bill NumberFor export supply, shipping bill number can be mentioned as per the Indian Customs EDI system. Optional
Shipping Bill DateFor export supply, shipping bill date can be mentioned as per the Indian Customs EDI system.Optional
Export Duty AmountAmount of export duty in INR should be mentioned.Optional
Supplier Can Opt RefundThis 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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