A deemed export is a sale of goods made in India where the goods do not leave India, but the law treats the sale like an export for some benefits. Under GST, only four supplies are deemed exports: goods sold against an Advance Authorisation, capital goods sold against an EPCG Authorisation, goods sold to an Export Oriented Unit (EOU), and gold sold by a bank or PSU against an Advance Authorisation.
Deemed exports are not zero rated. The supplier charges GST at the normal rate, and then either the supplier or the buyer claims that GST back as a refund. This guide covers the meaning, examples, the GST rate, the EOU procedure, both refund routes, GSTR-1 reporting and the Foreign Trade Policy list. We checked every rule on this page against the law on 22 October 2026.
- Deemed exports are goods made in India that stay in India. The law (section 147 of the CGST Act) lets the government notify such sales as deemed exports. Services can never be deemed exports.
- Only four supplies are notified (Notification 48/2017-Central Tax): against an Advance Authorisation, capital goods against an EPCG Authorisation, to an EOU, and gold by a bank or PSU against an Advance Authorisation.
- GST is charged at the normal rate. You cannot supply deemed exports under an LUT, and there is no 0.1% rate for them.
- The tax comes back as a refund. Either the buyer claims it, or the supplier claims it if the buyer takes no input tax credit and gives two written undertakings.
- The refund must be claimed within 2 years from the date the return for those deemed exports is filed.
- The supplier shows deemed exports in GSTR-1 Table 6C.
- From 8 October 2024, the rule that stopped buyers of deemed exports from exporting on payment of IGST and claiming it back (rule 96(10)) is gone.
What is a deemed export under GST?
Section 147 of the CGST Act lets the government, on the GST Council's advice, "notify certain supplies of goods as deemed exports, where goods supplied do not leave India, and payment for such supplies is received either in Indian rupees or in convertible foreign exchange, if such goods are manufactured in India."
So a supply is a deemed export only when all of these are true:
- It is a supply of goods. The GST Council says deemed exports are "supplies of goods manufactured in India (and not services)".
- The goods are made in India.
- The goods stay in India. They go to a buyer in India, not abroad.
- Payment comes in Indian rupees or convertible foreign currency. Both are allowed.
- The supply is one of the four notified in Notification 48/2017-Central Tax (next section).
Why does the law have deemed exports? The buyers on the list use the goods to make products for export. Treating their purchases like exports lets the GST paid on them come back as a refund, so it does not add to the cost of the export.
Deemed export meaning in Hindi: deemed export yaani "maana gaya niryaat". Maal India mein hi rehta hai, lekin kanoon kuch faaydon ke liye use export jaisa maanta hai.
The 4 deemed export supplies under GST
Notification 48/2017-Central Tax (18 October 2017) lists the only four supplies that are deemed exports under GST.
| Supply | Who the buyer is | What the buyer holds |
|---|---|---|
| 1. "Supply of goods by a registered person against Advance Authorisation" | A business that will use the goods (inputs) to make goods for export | An Advance Authorisation from the DGFT for "import or domestic procurement of inputs on pre-import basis for physical exports" |
| 2. "Supply of capital goods by a registered person against Export Promotion Capital Goods Authorisation" | A business buying machines or other capital goods to make goods for export | An EPCG Authorisation from the DGFT for capital goods "for physical exports" |
| 3. "Supply of goods by a registered person to Export Oriented Unit" | An EOU, or a unit in an Electronic Hardware, Software or Bio-Technology Technology Park (EHTP, STP or BTP) | Approval as an EOU, EHTP, STP or BTP unit under the Foreign Trade Policy |
| 4. Supply of gold by a bank or Public Sector Undertaking "against Advance Authorisation" | An exporter holding an Advance Authorisation | An Advance Authorisation. Only banks and PSUs named in Notification 50/2017-Customs can make this supply |
EOU full form in GST: EOU means Export Oriented Unit. Notification 48/2017 counts four kinds of units as an EOU: "an Export Oriented Unit or Electronic Hardware Technology Park Unit or Software Technology Park Unit or Bio-Technology Park Unit".
Only these four. A sale is not a deemed export under GST just because the buyer is an exporter. The buyer must hold one of these authorisations or approvals, and the sale must be the kind the notification lists.
Deemed export examples
Made-up example 1 (Advance Authorisation). A yarn maker in Ludhiana sells yarn to a garment exporter in Tiruppur. The exporter holds an Advance Authorisation for that yarn. The sale is a deemed export. The yarn maker charges GST on the invoice.
Made-up example 2 (EPCG). A machine maker in Rajkot sells a cutting machine to a factory in Surat. The factory holds an EPCG Authorisation for the machine. The sale is a deemed export of capital goods.
Made-up example 3 (EOU, same State). A packaging maker in Pune sells boxes worth ₹1,00,000 to a 100% EOU, also in Pune. Say the boxes carry 18% GST (check the real rate for your goods). The invoice shows CGST ₹9,000 and SGST ₹9,000. Later, either the EOU or the packaging maker claims the ₹18,000 back as a refund.
What is not a deemed export under GST
- A supply to a SEZ unit or SEZ developer. It is a zero rated supply, like an export, and can be made under an LUT. It is not in the deemed export list.
- A sale to a merchant exporter at 0.1% GST. That is a separate concession for goods the buyer exports within 90 days. It is not in the deemed export list.
- Services, even to an EOU. Only goods can be deemed exports.
- A normal sale to an exporter who has no Advance Authorisation or EPCG Authorisation for those goods and is not an EOU.
- Projects and UN bodies that are on the Foreign Trade Policy's own deemed export list but not in Notification 48/2017 (see the Foreign Trade Policy section below).
Deemed export vs export vs SEZ supply
| Export | Supply to a SEZ unit or developer | Deemed export | |
|---|---|---|---|
| Do the goods leave India? | Yes | No, they go into the SEZ | No |
| Services allowed? | Yes | Yes | No, goods only |
| GST on the sale | Zero rated: no GST under an LUT, or pay IGST and get it back | Zero rated, for "authorised operations": the same two ways | GST at the normal rate |
| LUT allowed? | Yes | Yes | No |
| How the tax comes back | Refund of unused credit, or of the IGST paid | Same as exports | Refund of the GST paid, claimed by the supplier or the buyer |
| GSTR-1 table | 6A | 6B | 6C |
Exports and SEZ supplies are zero rated under section 16 of the IGST Act. Our guide to zero rated, nil rated and exempt supplies explains what that means. Deemed exports are not zero rated: the GST Council says they "are not zero rated supplies by default, unlike the regular exports".
GST rate on deemed exports, and the 0.1% mix-up
The GST rate is the normal rate for the goods. There is no special rate for deemed exports. The GST Council says deemed export supplies "can be made on payment of tax and cannot be supplied under a Bond/LUT".
CGST and SGST, or IGST? Our reading: deemed exports follow the normal rules. If the buyer is in your State, you charge CGST and SGST. If the buyer is in another State, you charge IGST. The GST portal's refund form for buyers takes the refund from IGST first, then CGST and SGST, so both kinds of tax can be refunded.
"0.1% GST on deemed exports" is a mix-up. The 0.1% rate is for goods sold to a merchant exporter who exports them within 90 days (Notification 40/2017-Central Tax (Rate) and 41/2017-Integrated Tax (Rate)). It is a different scheme from deemed exports. Our guide to GST on exports explains the merchant exporter conditions.
Is a deemed export zero rated? No. Is an LUT needed for a deemed export? No, an LUT cannot be used at all. GST is charged and refunded later.
How to make a deemed export supply
Supplies to an EOU (Circular 14/14/2017-GST):
- Form A before the sale. The EOU gives "prior intimation in a prescribed proforma" (Form A) to you, to your jurisdictional GST officer and to its own jurisdictional GST officer.
- Tax invoice with GST. You supply the goods "under tax invoice", charging GST at the normal rate.
- The EOU endorses the invoice. On receiving the goods, the EOU endorses (signs) the tax invoice and sends copies to you and to both GST officers. "The endorsed tax invoice will be considered as proof of deemed export supplies."
- The EOU keeps Form B records. It keeps digital records in the Form B format and gives the month's Form B to its GST officer by the 10th of the next month.
Supplies against an Advance Authorisation or EPCG Authorisation:
- Tax invoice with GST to the authorisation holder, at the normal rate.
- Proof of receipt. If you, the supplier, will claim the refund, you need an acknowledgment from the buyer's jurisdictional tax officer that the buyer received the goods (Notification 49/2017-Central Tax).
Deemed export invoice format. The rules give no special wording for a deemed export invoice. It is a normal tax invoice with GST. Our reading: also write "Supply regarded as deemed export under Notification 48/2017-Central Tax" and the buyer's authorisation or EOU approval number on it. It helps the officer match the refund.
Deemed export refund: supplier or recipient
The GST charged on a deemed export comes back as a refund to either the buyer (the recipient) or the supplier, never both (rule 89(1) of the CGST Rules). Decide before the sale who will claim.
| Buyer (recipient) claims | Supplier claims | |
|---|---|---|
| When it can be used | For any deemed export supply | Only if the buyer takes no input tax credit on these invoices and gives the undertakings below (rule 89(1)) |
| Buyer's input tax credit | The buyer takes the credit in its return, then claims it as a refund | The buyer must not take the credit |
| Undertakings | From the buyer: the refund is only for the invoices in Statement 5B, it is not more than the credit taken in the return, and the supplier has not claimed it (Circular 147/03/2021-GST) | From the buyer: "no input tax credit on such supplies has been availed", and the buyer "shall not claim the refund" (Notification 49/2017-Central Tax) |
| Proof of receipt | Our reading: keep the endorsed invoices and the authorisation | Advance Authorisation or EPCG: acknowledgment by the buyer's jurisdictional tax officer. EOU: copy of the tax invoice signed by the EOU (Notification 49/2017) |
| Form | Form GST RFD-01 on the GST portal, refund type "On account of Refund by Recipient of deemed export", with Statement 5B | Form GST RFD-01, refund type for suppliers of deemed exports, with Statement 5B |
| Ledger | The amount is taken out of the buyer's electronic credit ledger when it files | The supplier gets back the tax it paid |
Time limit: 2 years. The refund must be claimed within 2 years from the "relevant date" (section 54(1), CGST Act). For deemed exports, that is "the date on which the return relating to such deemed exports is furnished" (section 54, Explanation 2(b)).
How fast. The officer must decide a complete claim within 60 days (section 54(7)). Our reading: deemed exports do not get the 90% provisional refund that section 54(6) gives for zero rated supplies, because they are not zero rated.
If the buyer claims, three more points:
- It is a refund of tax paid, not normal input tax credit. CBIC says the credit used for it "is not ITC in terms of the provisions of Chapter V", is not limited by section 17, and is kept out of the "Net ITC" used to work out export refunds (Circular 172/04/2022-GST).
- Enough balance in the credit ledger. Since 8 May 2025, the portal shows the electronic credit ledger balance and does not allow a refund larger than that balance.
- All returns filed. Since the same date, all returns due up to the date of the refund claim (GSTR-1, GSTR-3B and others) must be filed. Claims no longer have to be filed in date order.
Our reading: if the buyer already takes credit on all its purchases, the buyer route is simpler. If the buyer does not want to tie up its credit, it gives the undertakings and the supplier claims. Put the choice in the purchase order. Our GST refund guide explains the general refund steps, and our guide to the GST electronic ledgers explains the credit ledger.
Where to show deemed exports in GSTR-1 and GSTR-3B
| Return | Where | Who |
|---|---|---|
| GSTR-1 | Table 6C, "Deemed exports" (under Table 6, "Zero rated supplies and Deemed Exports") | The supplier, invoice by invoice |
| GSTR-3B | Row 3.1(a), "Outward taxable supplies (other than zero rated, nil rated and exempted)". GSTR-1 Table 6C fills this row | The supplier |
Deemed exports go in row 3.1(a), not 3.1(b), because tax is paid on them. Row 3.1(b) is only for zero rated supplies (GSTR-1 Tables 6A and 6B).
The refund statement (Statement 5B) is checked against what the supplier reported in GSTR-1. Our reading: a supplier who puts a deemed export in the normal B2B table instead of Table 6C can hold up the refund, so correct it before the claim.
Bought as deemed exports, then exporting? The 2024 change
Many buyers of deemed exports (EOUs and Advance Authorisation holders) then export their own goods. Until 7 October 2024, rule 96(10) of the CGST Rules said that a person "claiming refund of integrated tax paid on exports" should not have received supplies under Notification 48/2017 (deemed exports), the 0.1% merchant exporter notifications, or some customs exemptions. So such an exporter could not export on payment of IGST and claim it back. It had to export under an LUT.
From 8 October 2024, Notification 20/2024-Central Tax removed rule 96(10), and rules 89(4A) and 89(4B) that went with it. Our reading: an exporter who buys goods as deemed exports can now choose either way to export: under an LUT, or on payment of IGST with a refund of that IGST.
For exports before 8 October 2024, and for cases still open, the courts are still deciding how the old rule applies. Ask a CA about those periods.
Deemed exports under the Foreign Trade Policy
The Foreign Trade Policy (FTP) 2023 of the DGFT has its own, longer list of deemed exports (Chapter 7). It defines deemed exports as "transactions in which goods supplied do not leave country, and payment for such supplies is received either in Indian rupees or in free foreign exchange".
| By a manufacturer | By a main contractor or sub-contractor |
|---|---|
| Goods against an Advance Authorisation (or an Advance Authorisation for annual requirement, or a DFIA) | Goods to projects financed by multilateral or bilateral agencies or funds |
| Goods to an EOU, STP, EHTP or BTP unit | Goods to projects or purposes where imports are allowed at zero basic customs duty |
| Capital goods against an EPCG Authorisation | Goods to the United Nations or international organisations for official use |
| Goods to nuclear power projects |
FTP benefits are not GST benefits. The FTP benefits for deemed exports are an Advance Authorisation (or DFIA), Deemed Export Drawback, and a refund of terminal excise duty on excisable goods listed in Schedule 4 of the Central Excise Act, 1944. For GST, the FTP itself says: "The benefits of GST and conditions applicable for such benefits would be as specified by the GST Council and as per relevant rules and notification." So for GST, only the four supplies in Notification 48/2017 count. A supply to a UN body or a funded project can be a deemed export under the FTP but not under GST.
Imports by Advance Authorisation holders, EPCG holders and EOUs follow customs rules. They are not deemed exports, and this guide does not cover them.
Documents checklist for deemed exports
| Document | Buyer claims the refund | Supplier claims the refund |
|---|---|---|
| Tax invoice with GST | Yes | Yes |
| Form A from the EOU (EOU supplies) | Yes | Yes |
| Invoice endorsed by the EOU (EOU supplies) | Yes | Yes, a copy signed by the EOU |
| Acknowledgment by the buyer's jurisdictional tax officer (Advance Authorisation or EPCG supplies) | Our reading: not needed | Yes |
| Buyer's undertakings: no credit taken, no refund claimed by the buyer | No | Yes |
| Buyer's undertaking: only Statement 5B invoices, not more than the credit taken, supplier has not claimed | Yes | No |
| Statement 5B (list of invoices) | Yes | Yes |
| Copy of the buyer's Advance Authorisation, EPCG Authorisation or EOU approval | Our reading: keep it | Our reading: keep it |
| Supplier's GSTR-1 showing the invoices in Table 6C | Our reading: check it first | Yes |
Our reading: a bank realisation certificate (BRC or e-BRC) is not on the GST evidence list for deemed exports, because payment can be in rupees. Keep your normal bank records.
Frequently asked questions
What is a deemed export in simple words?
It is a sale of goods made in India where the goods stay in India, but the law treats the sale like an export. Under GST, only four kinds of sales count, all to buyers who make goods for export.
What is deemed export under GST with an example?
A yarn maker sells yarn to a garment exporter who holds an Advance Authorisation for that yarn. The yarn stays in India, but the sale is a deemed export under Notification 48/2017-Central Tax. GST is charged and later refunded.
Is GST charged on deemed exports?
Yes. The supplier charges GST at the normal rate for the goods. Then either the buyer or the supplier claims that GST back as a refund.
What is the GST rate on deemed exports?
The normal GST rate of the goods. There is no special rate. CGST and SGST apply within a State, and IGST between States.
What is 0.1% GST on deemed export?
There is no 0.1% rate for deemed exports. The 0.1% rate is for goods sold to a merchant exporter who exports them within 90 days, under Notifications 40/2017 and 41/2017. That is a different scheme.
Can deemed exports be supplied under an LUT?
No. Deemed exports cannot be supplied under a bond or LUT. GST is paid on the sale and refunded later.
Are deemed exports zero rated?
No. Only exports and supplies to SEZ units or developers are zero rated. Deemed exports carry GST, which is refunded.
What is the difference between export and deemed export?
In an export, the goods or services leave India and the supply is zero rated. In a deemed export, goods made in India stay in India, GST is paid, and the tax is refunded to the supplier or the buyer.
What is the difference between SEZ supply and deemed export?
A supply to a SEZ unit or developer for authorised operations is zero rated and can be made under an LUT. A deemed export is taxed at the normal rate and the tax is refunded later. They go in different GSTR-1 tables: 6B for SEZ, 6C for deemed exports.
Who can claim the deemed export refund?
The buyer can always claim it. The supplier can claim it only if the buyer takes no input tax credit on those invoices and gives written undertakings that it took no credit and will not claim the refund.
What is the time limit for a deemed export refund?
2 years from the date the return relating to those deemed exports is filed (section 54 of the CGST Act).
Where do I show deemed exports in GSTR-1?
In Table 6C, invoice by invoice. In GSTR-3B they go in row 3.1(a) with other taxable sales, not in row 3.1(b).
What documents are needed for a deemed export refund?
Statement 5B with the invoices, the buyer's undertakings, and proof that the buyer received the goods: an acknowledgment by the buyer's tax officer for Advance Authorisation or EPCG supplies, or an invoice signed by the EOU.
Can services be deemed exports?
No. Section 147 of the CGST Act covers only goods made in India. Services, even to an EOU, are not deemed exports.
What is the full form of EOU in GST?
Export Oriented Unit. For deemed exports, it also covers units in Electronic Hardware, Software and Bio-Technology Technology Parks.
Is supply to a merchant exporter a deemed export?
No. A merchant exporter can buy at 0.1% GST under a separate notification, but that supply is not one of the four deemed exports.
What are the benefits of deemed exports?
Under GST, the tax paid on the sale comes back as a refund. Under the Foreign Trade Policy, deemed exports can get an Advance Authorisation, Deemed Export Drawback and a refund of terminal excise duty on some goods.
Hinglish mein sawaal
Deemed export ka matlab kya hai?
Jab India mein bana maal India mein hi bikta hai, lekin kanoon use export jaisa maanta hai, use deemed export kehte hain. GST mein sirf chaar tarah ki sale deemed export hoti hai.
Deemed export par GST lagta hai kya?
Haan. Normal rate se GST lagta hai, LUT nahi chalta. Baad mein buyer ya supplier yeh GST refund le sakta hai.
