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Repair common Windows errors and clear accumulated junk for a smoother, more stable PC - no reinstall needed.Free scan · no reinstallKeep an engagement-level file that connects the overseas contract and work performed to the export invoice, payment received, GST return, refund calculation and input tax credit records. If you export without paying IGST, also retain the filed Letter of Undertaking (LUT) or bond. An invoice alone does not establish that a service qualifies as an export or substantiate the full refund claim.
Build a document file for each overseas engagement
Organise records so a reviewer can trace each claimed amount from the parties and services in the contract through delivery, invoicing, receipt, return reporting and the refund calculation. The following separates evidence expressly addressed in GST rules from practical supporting records; it is not a CRO-specific list of documents that must all be attached to every application.
| Record | What to retain | Why it matters |
|---|---|---|
| Contract and service-delivery evidence | Signed master services agreement, statements of work, amendments, purchase or work orders, milestone schedules, deliverables, client approvals or acceptance, and material correspondence. | Supports who contracted with whom, the agreed scope, what the CRO actually did and who received the service. These are prudent substantiation records, not a verbatim prescribed CRO checklist. |
| Export tax invoices | Sequential invoice records and copies, with the applicable export endorsement, recipient name and address, delivery address and destination country particulars. | Supports the supply and its reporting. The invoice particulars and endorsement are addressed by the tax-invoice rules. |
| LUT or bond, if using the no-IGST route | The relevant FORM GST RFD-11 LUT or bond and its filing acknowledgement. | Rule 96A requires the LUT or bond before making an export supply under this route. |
| Payment and remittance records | Bank Realisation Certificate (BRC) or Foreign Inward Remittance Certificate (FIRC) details linked to invoice number, date, amount, currency and receipt date; retain bank advice and remittance records explaining grouped or split receipts, charges, deductions, advances and currency conversion. | Refund rules call for invoice details alongside relevant BRC/FIRC details for export-of-services claims. Supporting bank records help reconcile differences between invoice and net remittance. |
| Returns and refund application | GSTR-1 filing details, relevant return acknowledgements, RFD-01 application and schedules, invoice-wise export statement, refund calculation, notices and responses, and any sanction or deficiency orders. | Shows what was reported and how the requested amount was calculated and processed. |
| Accounting and input-tax-credit records | Sales, tax, input-tax and ITC accounts; inward tax invoices; credit and debit notes; and a reconciliation linking eligible ITC to the refund claimed. | CBIC record rules address accounts of input services used and services supplied, as well as audit-trail links to source documents and financial accounts. |
Check whether the CRO service meets the export-of-services test
Under the conditions described in CBIC’s sectoral FAQ, a service is an export of services when all of the following apply:
- The supplier is located in India.
- The recipient is located outside India.
- The place of supply is outside India.
- Consideration is received in convertible foreign exchange, or in Indian rupees where the Reserve Bank of India permits it.
- The supplier and recipient are not merely establishments of the same person.
An overseas client or a contract labelled “clinical research” does not, on its own, prove that these conditions are met. Review the operative agreements and actual workflow: identify who supplies each service to whom, whether the CRO acts as principal or arranges a supply between other parties, and how the recipient and place of supply are determined. Intermediary classification can depend on those facts; without the particular contract and service model, a conclusion for an individual CRO engagement cannot be made.
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Use the right records for the zero-rating route
The GST Portal describes two broad zero-rating routes. They have different payment and refund mechanics, so retain records that match the route used and verify eligibility under the rules applicable to the claim.
| Route | IGST payment | Refund sought | Key records |
|---|---|---|---|
| Export under LUT or bond | No IGST paid at export, subject to the route’s conditions. | Eligible unutilized ITC. | Filed RFD-11 LUT or bond and acknowledgement; export invoices and reporting; payment evidence; ITC records; and the refund statement and calculation. |
| Export on payment of IGST | IGST paid on the export supply. | IGST paid, subject to applicable rules and restrictions. | Export invoices and reporting, records evidencing payment and the refund calculation and application applicable to this route. |
For service suppliers using the LUT or bond route, Rule 96A sets a payment condition: consideration must be received in convertible foreign exchange, or Indian rupees where RBI permits, within one year from the invoice date unless a further period is allowed. If the condition is not met, tax and interest consequences may arise. Track invoice dates against receipts and retain evidence of any permitted extension.
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Reconcile invoices, receipts and the refund period
For an export-of-services refund, the refund rules call for a statement with invoice numbers and dates and relevant BRC/FIRC details. Under the unutilized-ITC route, the rules define export turnover of services by reference to payments received during the relevant period, completed services for which an advance was received earlier, and advances for services not completed during that period.
Therefore, do not assume that an invoice date alone determines which period a service amount belongs in. Reconcile invoice-level records with receipt dates, service completion, returns and ledgers, and document how the refund calculation treats advances, partial receipts and any differences between gross invoices and net bank receipts.
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Report export invoices and preserve the filing trail
Keep the GSTR-1 filing details and return acknowledgements with the corresponding invoice schedule. GST Portal guidance says export invoices may be reported in GSTR-1 before shipping-bill details are available; those details can be added by amendment in a later period. Preserve the original filing and any subsequent amendment so the refund file explains changes to reported export particulars.
For service invoices, the general time limit in the tax-invoice rules is 30 days from the supply, subject to specified exceptions. The export invoice rules also prescribe the endorsement appropriate to the route:
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- IGST-paid route: “SUPPLY MEANT FOR EXPORT ON PAYMENT OF IGST”
- LUT or bond route: “SUPPLY MEANT FOR EXPORT UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF IGST”
Apply the wording and required recipient, delivery and destination particulars to the relevant invoice, and retain its sequential record with the return data and engagement file.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Keep the evidence connected, not just collected
A useful control is an invoice-wise reconciliation that links the engagement and deliverable to the invoice, relevant receipt evidence, GSTR-1 entry, refund statement and corresponding ITC records. Keep explanations and supporting bank records for split or grouped receipts, deductions and amendments alongside that reconciliation. This makes it easier to show how the CRO applied the export conditions and arrived at the amount claimed, without treating every supporting workpaper as a separately prescribed refund attachment.
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GST rules and notifications can change, and the proper route or export classification may depend on the specific transaction. Check the applicable requirements for the refund period before filing; obtain transaction-specific tax advice where the parties’ roles or intermediary treatment are uncertain.
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