Knowledge Sharing Desk


Q 1 ) Can a person paying tax under composition scheme make exports or supply goods to SEZ ?

No, because exports and supplies to SEZ from Domestic Tariff Area are treated as inter-State supply. A person paying tax under composition scheme cannot make inter-State outward supply of goods.



Q 2 ) Under the GST regime, will benefit of exemption from all duties available under Advance authorization scheme, EPCG scheme and duty credit scrips such as Merchandise Exports from India Scheme (MEIS) & Service Exports from India Scheme (SEIS) will continue?

The benefits under Advance authorization scheme, EPCG schemes continued till 31st March 2019 &MEIS schemes shall be restricted only to Basic Customs Duty, Safeguard Duty, Transitional Product Specific Safeguard Duty and Anti-dumping Duty in respect of goods leviable to IGST.



Q 3 ) Is there also a change under the GST regime in respect of filing of application for fixation of brand rate of Drawback for supplies to SEZ units and SEZ Developers?

Prior to 1st July 2017, applications for fixation of brand rate for supplies to SEZ units and SEZ Developers used to be filed with the jurisdictional Commissioner of Central Excise. With effect from 1st July 2017, applications for fixation of brand rate will be required to be filed with the Commissioner of Customs having jurisdiction over the principal place of business of the DTA supplier. This shall be applicable even for exports made prior to 1st July 2017 for which application for fixation of brand rate is yet to be filed.



Q 4 ) On re-export of imported goods, drawback of all duties paid at the time of importation was admissible earlier, as per the rates prescribed in this regard. What will be the position in respect of re-export made after 1st July 2017, of the goods imported prior to 1st July 2017? After 1st July 2017, IGST and Compensation Cess will also be payable on the imported goods. If such imported goods on which IGST and Compensation Cess were paid, are re-exported, whether Drawback of IGST and Compensation Cess will also be granted?

Drawback under Section 74 of the Customs Act, 1962 is available for duties paid at the time of importation. Therefore, whatever duties / taxes are paid at the time of importation of goods, Drawback of the same will be granted. Drawback of Basic Customs Duty plus Additional Duty of Customs (CVD) plus Special Additional Duty (SAD) paid on the goods imported prior to 1st July 2017 will be paid even if the re-export is made after 1st July 2017. Similarly, in respect of the goods imported after 1st July 2017, Basic Customs Duty plus IGST plus Compensation Cess will be paid and Drawback of all of these would be paid on re-export of such imported goods.



Q 5 ) Applications for fixation of brand rate used to be filed with jurisdictional Commissioner of Central Excise having jurisdiction over the factory where export goods were manufactured. Under GST regime, will there be any change regarding filing of application for fixation of brand rate?

With effect from 1st July 2017, applications for fixation of brand rate shall be filed with the Commissioner of Customs having jurisdiction over place of export of goods i.e the port/Airport/ICD etc. where Shipping Bill was filed. This shall be applicable even for exports made prior to 1st July 2017 for which application is yet to be filed. In case exports are from multiple places, application shall be filed with the Commissioner of Customs having jurisdiction over any one of the places of export of goods.



Q 6 ) We are engaged in the manufacture of exempted excisable goods for export. We availed input stage rebate used in the manufacture of exported goods. How would our case be dealt under GST law if our supply remains an exempt supply?

Under IGST law a person engaged in export of goods which is an exempt supply is eligible to avail input stage credit for zero rated supplies. Once goods are exported, refund of unutilized credit can be availed



Q 7 ) M/s XYZ is engaged in export of goods only having exports of approx. Rs. 5 crores and no clearances for home consumption are affected. M/s XYZ was not required to be registered under Central Excise. Whether M/s XYZ would be required to get itself registered under GST?

Yes, because exports have been treated as inter-State supplies under IGST Law.



Q 8 ) Will export of goods to Nepal and Bhutan treated as zero rated and thereby qualify for all the benefits available to zero rated supplies under the GST regime?

Export of goods to Nepal or Bhutan fulfils the condition of GST Law regarding taking goods out of India. Hence, export of goods to Nepal and Bhutan will be treated as zero rated and consequently will also qualify for all the benefits available to zero rated supplies under the GST regime. However, the definition of 'export of services' in the GST Law requires that the payment for such services should have been received by the supplier of services in convertible foreign exchange.



Q 9 ) Would GST be payable on goods not intended to be sold, taken out for participation in overseas exhibitions and trade fairs and brought back into India as these goods are meant for exhibition only ?

GST is not payable in such cases. Exporters will need exhibition participation letter and no foreign exchange involved letter from the concerned bank for the purpose of exchange control requirements. At the time of re-import, identity of goods imported with export goods needs to be established to seek exemption from import duty in accordance with Customs provisions. IGST will be exempted at the time of re-import in view of exemptions granted under Customs.



Q 10 ) Will drawback at higher rate be available to handicraft exporters who do not avail Input Tax Credit (ITC) like presently available to those who do not avail CENVAT credit?

No. There will be no difference in rate of Drawback for exporters not availing ITC in GST regime. In GST regime, drawback will be admissible only at lower rate determined on the basis of customs duties paid on imported materials used in the manufacture of export goods. However, as an export facilitation measure, for the transition period of 3 months from July to September, 2017, drawback at higher composite rates will continue to be granted subject to the condition that no input tax credit of CGST/IGST is claimed, no refund of IGST paid on export goods is claimed and no CENVAT credit is carried forward.



Q 11 ) Whether goods sent by a taxable person to a job worker be treated as supply and will they be liable to GST?

No, the goods sent by a registered person to a job worker is not a supply, as there is no transfer of title and no consideration for the goods is involved. In terms of section 143 of the CGST Act, 2017 a registered taxable person (the principal), after following the prescribed procedure, may send any inputs or capital goods, without payment of GST, to a job worker for job work and the principal shall either i) bring back such inputs or capital goods after completion of job work or otherwise within the prescribed period i.e. 1 year in case of inputs and 3 years in case of capital goods, or ii) Supply such inputs or capital goods, within such prescribed period, on payment of tax within India, or with or without payment of tax for export, as the case may be. If the goods or, capital goods, as the case may be, are not returned to the principal within the time specified above, the same shall be deemed to have been supplied by the principal to the job worker on the date the goods were sent out to the job worker and the principal shall be required to pay tax accordingly on such supplies.



Q 12 ) Will Deemed export drawback and TED refund be available under GST regime for deemed exports?

The following provisions would apply under the GST regime for the deemed exports in relation to the refund of the Terminal Excise Duty (TED) and Drawback (DBK). 1. No TED refund would be available as the central excise duty is subsumed under the GST. However, for the items covered under Schedule four of Central Excise Act, 1944, the TED refund would be available, provided the items are eligible for supply under the said category of the deemed exports under chapter 7 of the FTP, and there is no exemption from payment of excise duty. 2. The drawback as provided under Chapter 7 would be limited to the refund of basic custom duty only.



Q 13 ) Will Invalidation and ARO be available under Advance Authorisation or EPCG scheme post GST implementation?

ARO : For items covered under the GST, No Advance Release Order (ARO) facility will be available in Advance Authorisation and EPCG scheme. For items not covered under the GST (Listed in the Schedule 4 of Central Excise Act, 1944 read with The Taxation Laws (Amendment) Act 2017 No 18 of 2017, with effect from July 1, 2017) ARO would be available. Invalidation : Invalidation facility will be available for both Advance Authorisation and EPCG schemes, but applicable GST would need to be paid while making local procurement, using an invalidation letter. Input Tax Credit (ITC) of the GST paid on such local procurement can be availed as per CGST Rules 2017. Please also refer to DGFT Trade Notice No.11/2018 dated 30.06.2017.



Q 14 ) What type of duties can be paid using MEIS or SEIS scrips now? Can we use these scrips to pay GST?

For items covered under the GST, scrips can be used for payment of Basic Custom Duty, Safeguard Duty, Transitional Product Specific Safeguard Duty, and Antidumping Duty. For items not covered under the GST (specified in Fourth Schedule to Central Excise Act 1944 covering specified petroleum products, tobacco etc.), in addition to the Basic Custom Duty, Safeguard Duty, Transitional Product Specific Safeguard Duty, and Antidumping Duty, scrips can also be used for payment of duties like central excise, CVD/ SAD. The scrips cannot be used for payment of any type of GST.



Q 15 ) What are the GST refund options available to the exporters?

An exporter would be eligible to claim refund under one of the following two options, namely - (a) He may export under bond, without payment of IGST and claim refund of unutilized input tax credit in; (b) He may export on payment of IGST and claim refund of IGST paid on goods and services exported. The SEZ developer or SEZ unit receiving zero rated supply can claim refund of IGST paid by the firm making supply to SEZ.



Q 16 ) What categories of supplies have been covered as the Zero rated supplies under the IGST Act?

“Zero rated supply” under Section 16 of the IGST Act, 2017 means any of the following supplies of goods or services or both, namely: (a) export of goods or services or both; or (b) supply of goods or services or both to a Special Economic Zone developer or a Special Economic Zone unit.



Q 17 ) Whether a registered person will have to approach two authorities - Centre as well as State for various permissions, audit etc. under the Act?

No, a registered person needs to approach only one tax authority for all practical purposes. Each registered person would have one tax administration office, either of the Centre or of the State. Legal provisions (called cross-empowerment) have been made to ensure that one tax authority can discharge all functions under CGST, SGST/IGST/UTGST Act in relation to a registered person. The registered person would be informed of the tax administration concerned with him. A common registration is granted for the purposes of CGST, SGST/UTGST and IGST.



Q 18 ) What is destination-based consumption tax?

When a supply originates in one State and is consumed in another State, tax can accrue to either of the two States. In a destination based consumption tax, taxes accrue to the State where the supply is consumed. In origin based tax, the tax accrues to the State where the supply originates. GST is basically a destination based consumption tax. For example, if a car is manufactured in Chennai but is purchased eventually by a consumer in Mumbai, SGST (or the State component in IGST) would accrue to Maharashtra and not to Tamil Nadu.



Q 19 ) Is an agriculturist liable to registration?

No. An agriculturist, to the extent of supply of produce out of cultivation of land is not liable to registration.



Q 20 ) What is the most important precaution to be taken to avail the facility of threshold exemption?

An MSME availing threshold exemption should not be making any inter-State supply of goods,though the MSME may receive supply from other States.



Q 21 ) I am engaged exclusively in the business of supplying goods or services which are exempt from GST. Am I liable for registration?

No. A person dealing with only exempted supplies is not liable to registration irrespective of his turnover. Section 23(1)(a) of the GST Act refers : (1) The following persons shall not be liable to registration, namely:–– (a) any person engaged exclusively in the business of supplying goods or services or both that are not liable to tax or wholly exempt from tax under this Act or under the Integrated Goods and Services Tax Act; (b) an agriculturist, to the extent of supply of produce out of cultivation of land. (2) The Government may, on the recommendations of the Council, by notification, specify the category of persons who may be exempted from obtaining registration under this Act.



Q 22 ) If I register voluntarily though my turnover is less than prescribed threshold limit, am I required to pay tax on supplies made post registration?

Yes. If you obtain voluntary registration despite the turnover being below prescribed threshold, you would be treated as a normal taxable person and would need to pay tax on supplies even if they are below the threshold for registration. You will also be entitled to take input tax credit.



Q 23 ) In which State will a person be registered?

A person liable to be registered has to apply for registration in each State from where he makes or intends to make outward supplies under GST. Within each State, generally only one registration is required to be obtained, although the taxpayer is free to obtain more than one registration within a State also.



Q 24 ) Who is liable to issue a ‘tax invoice’ and how many copies are required to be issued?

Every registered person (other than a registered person availing the benefit of composition or a registered person supplying exempted goods or services) supplying goods or services or both is required to issue ‘tax invoice’. Invoice should be issued in triplicate. The original copy is meant for buyer, duplicate for transporter and triplicate copy for record of the seller. A registered person under composition scheme or supplying exempted goods or services shall issue a bill of supply instead of a tax invoice.



Q 25 ) What details are to be contained in a ‘tax invoice’?

The tax invoice shall contain details as specified in rule 46 in this regard. The key details specified in the rules are - name, address and GSTIN of the supplier and the recipient (if registered), a unique number of the invoice and the date of issue, description of goods, value of goods, rate of tax, amount of tax and signature.



Q 26 ) When should a tax invoice be issued for goods?

Tax invoice for goods shall be issued on or before the time of removal/delivery of goods. In case of continuous supply of goods, it shall be issued on or before the time of issue of statement of accounts /receipt of payment.



Q 27 ) In case of supply of exempt goods or when tax is paid under Composition Scheme, is the registered person required to issue a tax invoice? How a bill of supply is different from a tax invoice?

No. In such cases, the registered person shall issue a Bill of Supply and not a tax invoice. The bill of supply is different from a tax invoice both in name and details contained. While most of the details to be provided in a bill of supply are similar to tax invoice, the bill of supply does not contain the rate of tax and the amount of tax charged as the same cannot be collected.



Q 28 ) If goods are transported in semi-knocked down condition, when shall the complete invoice be issued?

When goods are transported in semi-knocked down condition, the complete invoice shall be issued before dispatch of the first consignment. Delivery challan shall be issued for subsequent consignments. Original copy of invoice shall be sent along with the last consignment.



Q 29 ) What is the form in which an intimation to pay tax under the composition scheme needs to be made by the taxable person?

Composition scheme is optional and intimation that option has been availed should be made electronically in Form GST REG-01 by a new taxpayer. A person who has already obtained registration and opts for payment under composition levy subsequently needs to give intimation electronically in Form GST CMP-02.



Q 30 ) A person availing composition scheme during a financial year crosses the turnover of Rs. 150 Lakh / Rs. 75 Lakh during the course of the year i.e. say, he crosses the turnover of Rs. 150 Lakh/ Rs. 75 Lakh in December? Will he be allowed to pay tax under composition scheme for the remainder of the year i.e. till 31st March?

No. The option to pay tax under composition scheme shall lapse from the day on which his aggregate turnover during the financial year exceeds Rs. 150 Lakh/ 75 Lakh. Once he crosses the threshold, he shall file an intimation for withdrawal from the scheme in FORM GST CMP-04 within seven days of the occurrence of such event. He shall also furnish a statement in FORM GST ITC-01 containing details of the stock of inputs and capital goods as per the rules in this regard. This would help him join the input tax credit chain and avail credit of tax that he has paid on his inputs/goods lying in stock on the day he crosses over.



Q 31 ) How is a manufacturer under the composition scheme required to bill his supply? Can a registered person, who purchases goods from a composition manufacturer, take input tax credit?

A manufacturer opting to pay tax under the composition scheme cannot issue a tax invoice to his buyer but would issue a Bill of Supply. He cannot collect any tax on supplies made by him on his Bill of Supply and is required to show only the price charged for the supply. Consequently, the registered person buying goods from a composition manufacturer cannot take input tax credit.



Q 32 ) Can a person paying tax under composition scheme make exports or supply goods to SEZ?

No, because exports and supplies to SEZ from Domestic Tariff Area are treated as inter-State supply. A person paying tax under composition scheme cannot make inter-State outward supply of goods.



Q 33 ) Can a service provider opt for composition scheme?

Yes. With effect from 01.04.2019, suppliers of service only or suppliers of service and goods together can opt for composition scheme for first clearances up to ? 50 Lakh. The rate of composition tax in such cases is fixed at 6%.



Q 34 ) Who should issue Bill of Supply?

The following registrants should issue Bill of Supply: A. Composition Dealer A taxpayer whose turnover is less than Rs 1.5 crores* (Rs. 75 lakhs for north-east states and Uttarakhand) can opt for composition scheme. A dealer opting for composition scheme has to deposit tax on their receipts themselves, they are not allowed to collect any tax from their buyers. The GST has to be paid out of pocket by the composition dealer. They cannot charge GST in the invoice. Thus a composition dealer has to raise a Bill of Supply instead of a Tax Invoice. The composition dealer has to mention the words ‘composition taxable person not eligible to collect taxes on supplies’ on the Bill of Supply. *CBIC has notified the increase to the threshold limit to Rs. 1.5 crores. The notification comes into effect from 1st April 2019. B. Exporters An exporter is also not required to charge GST on their invoice. This is because exports supplies are zero-rated. Hence a taxpayer exporting goods can issue a Bill of Supply in place of a tax invoice. The dealer has to mention the following in their Bill of Supply- “Supply Meant For Export On Payment Of IGST” “Supply Meant For Export Under Bond Or Letter Of Undertaking Without Payment Of IGST” C. Exempted Goods Supplier When a registered dealer supplies exempt goods or services they are required to issue a Bill of Supply. For example, when a registered taxpayer provides unprocessed agricultural products they have to issue a Bill of Supply instead of a tax invoice.


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