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For an Indian IT or consulting firm, a customer or project located abroad does not by itself make a service an export under GST. Before applying zero-rated treatment or seeking a refund, identify the actual recipient and relevant establishments, check the applicable place-of-supply rule, and establish that every export-of-services condition is met. The checklist below sets out the records and review steps to work through for each service flow. It reflects official CBIC and GST Portal materials checked on 9 October 2026; the right treatment depends on the firm’s legal structure and transaction facts.
1. Build a transaction map before classifying supplies
Start with the service flow, not the customer’s country or the name on a purchase order. A firm may contract with one entity, perform work for another establishment, and receive payment through a different route. Those facts can matter to export status and place of supply. Create a record for each contract, statement of work, invoice, or materially different service arrangement so reviewers can see who is involved and what was supplied.
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Record the parties, establishments and service
For each flow, capture the Indian supplier and its relevant GSTIN, the contractual recipient, the establishment that actually receives the service, and the country and address of each relevant establishment. Note whether the overseas office is a branch or another kind of entity, and record the legal relationship between it and the Indian supplier. Describe the service specifically enough to identify what the firm agreed to do and where the recipient receives it; a generic description such as “IT services” may not explain the underlying transaction.
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1Repair Windows errors before they cause bigger problems2Scan for outdated or missing drivers - takes under a minute3Clear out junk files and repair common Windows errorsKeep the agreement, statement of work, service-delivery evidence, invoice and payment or remittance records together. Record the invoice currency and the payment route as part of the factual file. These documents help substantiate the transaction and let a reviewer test whether the paperwork is consistent with the service actually performed.
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Keep contractual and operational facts distinct
Do not treat the contracting party as automatically identical to the service recipient. Write down both the entity that signed or pays under the contract and the establishment that actually receives the service, along with the basis for identifying each. This is a factual distinction for the analysis, not a shortcut that determines the GST outcome on its own. The CBIC sectoral FAQ discusses export-of-services conditions and relevant IT/ITES place-of-supply questions.
2. Test whether the service qualifies as an export
Apply the export-of-services test separately to each supply. The CBIC sectoral FAQ identifies these conditions: the supplier is in India; the recipient is outside India; the place of supply is outside India; the required receipt of payment is satisfied; and the supplier and recipient are not merely establishments of a distinct person. An overseas customer or overseas project alone does not establish that all of these conditions are met.
Examine the overseas-branch relationship
Where the Indian firm supplies services to an overseas branch or office, determine its legal identity and relationship to the Indian supplier before treating the supply as an export. The distinct-establishment condition is material: the fact that an establishment is abroad does not, by itself, show that it is a separate recipient for this test. Gather the relevant corporate and contractual facts, then have a qualified Indian GST practitioner assess how they apply to the specific arrangement.
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Do not infer the result from a group-company label, a billing address or the location of the work alone. The firm needs to assess the actual supplier-recipient relationship as well as the other export conditions. The CBIC Circular 199/11/2023-GST addresses services between offices in different Indian States treated as distinct persons and questions about common input services. Its clarification concerns the Indian State-to-State office setting; it should not be treated as a blanket answer to the separate overseas-branch question.
Document the conclusion and its basis
For each flow, retain the facts considered, the export-condition analysis, and the supporting records. If the firm cannot establish a condition from the contract, establishment records, service evidence or payment documentation, flag the issue for review instead of assuming export treatment. Keep distinct flows separate where recipient, service, payment arrangement or establishment facts differ.
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3. Determine place of supply using the applicable rule
Place of supply is governed by the Integrated Goods and Services Tax Act, 2017, and the default rule for services has statutory exceptions. Section 13(2) states that “The place of supply of services except the services specified in sub-sections (3) to (13) shall be the location of the recipient of services.” That default wording expressly leaves room for the specified exceptions, so it is not safe to apply it without first checking whether an exception governs the particular service.
Check the service and recipient facts
Identify the service being supplied and the recipient’s location or establishment relevant to receiving it. Then check the applicable statutory rule rather than assuming that the location of the Indian delivery team, the invoicing office or the person making payment settles place of supply. The IGST Act material contains the statutory provisions, while the CBIC sectoral FAQ points to recipient location under sections 12 and 13 for IT/ITES questions.
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Repair common Windows errors and clear accumulated junk for a smoother, more stable PC - no reinstall needed.Free scan · no reinstallThe same FAQ says that, for an unregistered recipient whose address is not available in the supplier’s records, place of supply is the supplier’s location. Treat that as a fact-specific rule to check where those circumstances apply, not as a general replacement for identifying the recipient and reviewing the applicable provision. Keep evidence of the address and recipient information used in the analysis.
4. Reconcile Indian GST registrations and shared services
Map the firm’s Indian offices and GST registrations by State, including head-office and branch activities. A firm with multiple State registrations should identify which registration makes or receives each supply and how centrally procured services are used. Review inter-office services, cross-charges and common expenses as connected but distinct compliance questions; the overseas branch analysis does not resolve the treatment of Indian registrations.
Review common input services
For expenses shared among Indian offices, retain supplier invoices and a documented allocation working showing the offices or registrations to which a service relates. The CBIC sectoral FAQ discusses common services attributable to multiple States and allocation to distinct persons. Circular 199/11/2023-GST also addresses common input-service questions in its Indian State-to-State setting. Use those materials for the issues they cover, while checking the firm’s facts and current rules rather than assuming every overseas or domestic arrangement is identical.
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Check input-tax-credit support
Reconcile input tax credit (ITC) records against supplier invoices, the firm’s books and relevant portal records. For each credit, establish its business use and eligibility under the rules applicable to the taxpayer and period. Where an expense is shared, preserve the allocation basis and supporting invoice so the amount claimed by each registration can be traced. The available facts do not establish which credits any particular firm may claim; that depends on its supplies, use of services and applicable requirements.
5. Apply invoice controls to services and exports
For taxable services, CBIC’s invoice rules generally require an invoice within 30 days from the supply, subject to exceptions for specified suppliers. Confirm which rule and any exception applies to the particular supplier and transaction before setting a control or treating a late invoice as compliant. The CBIC invoice rules provide the relevant requirements.
Check export invoice particulars
Export invoices require the applicable export endorsement and the recipient’s name and address, delivery address, and country of destination. Check that the invoice details agree with the contract and the establishment identified as receiving the service. If the agreement, delivery information and invoice point to different entities or destinations, investigate the discrepancy and keep the explanation with the transaction file rather than relying on an unsupported assumption.
Maintain a complete invoice trail
Link each invoice to its contract or statement of work, evidence that the service was supplied, and payment documentation. Retain amendments and explanations for changes to recipient, address, scope or invoice particulars. This allows the outward-supply return and any later refund file to be reconciled to the underlying transaction instead of treating the return entry as the only record.
6. Prepare outward-supply reporting from reconciled records
Use the firm’s applicable return obligations and reporting period to prepare outward-supply information. The GST Portal describes online and offline preparation and filing of GSTR-1. It also explains that data from registered e-invoices populates relevant GSTR-1 tables. Portal population is a data-transfer feature, not a substitute for checking whether the entries match the books and transaction evidence.
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Reconcile before filing
Compare the portal’s populated or prepared invoice details with the accounting records, contracts, export documentation and amendments. Resolve differences in recipient, value, classification or other reported particulars before filing where possible, and preserve the reconciliation and correction trail. The GST Portal GSTR-1 manual describes return preparation; separate GSTR-1 guidance covers the export/refund routes described by the portal.
Confirm what applies to this taxpayer and period
Do not infer filing frequency, e-invoicing applicability or a due date from a generic checklist. Those details must be confirmed for the firm’s category and the relevant tax period, including any operative changes or extensions. Maintain a filing calendar based on that review, then retain filed returns, acknowledgements and reconciliations with the period’s supporting records.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.7. Select and document the export refund route
GST Portal guidance describes two export routes: supply without payment of IGST and claim a refund of eligible ITC, or pay IGST and claim a refund of that tax. The firm should compare them against its eligibility, cash-flow needs and documentary requirements under current rules. The route cannot be selected responsibly from the fact that a service is billed abroad; first establish that export treatment is available, then verify the procedural conditions for the intended route.
| Route described in GST Portal guidance | What the firm seeks to recover | Review before choosing |
|---|---|---|
| Supply without payment of IGST | Refund of eligible input tax credit | Confirm eligibility, required supporting records and current procedural conditions. |
| Pay IGST on the export supply | Refund of the IGST paid | Confirm eligibility, cash-flow timing, matching requirements and current procedural conditions. |
The portal identifies the routes but does not establish which is preferable for a particular firm. Compare the cash tied up, timing and documentation burden using the company’s own facts and current requirements; do not assume either route is universally available or better.
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Assemble the refund evidence
CBIC’s refund rules describe FORM GST RFD-01 and supporting documentary evidence. Build a refund file from the transaction records already maintained: relevant invoices, contracts, service evidence, payment records, reconciliations and documents required for the selected route. Verify current eligibility, procedural conditions and any applicable matching requirements before filing. The CBIC refund rules should be checked alongside current portal instructions.
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8. Keep a period-by-period compliance file
Organize records so a reviewer can move from a contract to the service, invoice, return entry and any refund claim without reconstructing the transaction from scattered files. Keep records by tax period and registration, and make amendments and reconciliation workings traceable to the original entry.
- Contracts, statements of work and service-delivery evidence.
- Recipient and establishment details, including the basis for identifying the service recipient.
- Invoices, invoice amendments and applicable export endorsements.
- Payment and remittance records supporting the transaction analysis.
- Books-to-portal reconciliations, GSTR-1 records and filed-return acknowledgements.
- Supplier invoices, ITC eligibility reviews and shared-service allocation workings.
- Applicable LUT or bond and refund documents, where relevant to the route used.
Set calendar reminders only after confirming the taxpayer’s actual filing category and current deadlines. The official materials summarized here do not establish a particular firm’s filing frequency or the deadlines applicable to it.
9. Escalate questions that depend on the company’s facts
A qualified Indian GST practitioner should review any flow where the legal identity of an overseas office, the recipient of the service, the place-of-supply exception, payment evidence or Indian registration treatment is uncertain. The review should cover the actual contracts and operating arrangements, not just invoice labels. It should also confirm the export/refund method and the operative requirements for the relevant period.
This checklist identifies decision points; it does not determine that a particular supply qualifies as an export, that a specific GST return or registration applies, or that a firm can claim a refund. The sources provide statutory material, official FAQs, portal instructions and a circular, not a conclusion for a company whose legal form, turnover, registrations, contracts, payment records and prior filings are unknown.
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