Review every statutory export-of-services condition before treating a foreign-customer invoice as an export. Section 2(6) of the IGST Act requires more than an overseas address or foreign-currency receipt. Establish the relevant party locations, place of supply, permitted payment and relationship between establishments, then select the eligible GST route. The evidence should support the actual service contract and supply period, not merely the description “export consultancy” in the item master.
Use the complete export test
| Condition to review | Evidence to organise |
|---|---|
| Supplier located in India | Relevant establishment and registration records |
| Recipient located outside India | Contracting entity, address and establishment facts |
| Place of supply outside India | Current section 13 analysis for the actual service |
| Payment in the prescribed permitted form | Bank evidence and applicable RBI permission for INR receipts |
| Parties not merely covered establishments of a distinct person | Legal-entity and establishment relationship documents |
Record a conclusion for each condition. Passing four does not make the fifth unnecessary, and a purchase order using the word export cannot replace the statutory test.
Identify the real foreign recipient
Read who contracts, receives the service, controls acceptance and owes payment. A foreign parent may negotiate a project for an Indian subsidiary, or an Indian business may settle an overseas entity's obligation. Those arrangements require facts rather than assumptions based on the email domain.
Retain the foreign entity's legal identity and relevant establishment details. Distinguish a separately incorporated related company from the supplier's own overseas establishment. Relationship can create other valuation questions, while the export condition concerns the statutory establishment relationship. Do not classify every group transaction identically merely because the parties share a brand.
Describe the supplied service precisely
Collect the scope, deliverables, rights, service period and acceptance terms. Distinguish work supplied on the business's own account from arrangements that facilitate another supply where relevant. The service classification determines which current place-of-supply provision needs review.
An ordinary remote analysis service, work directly relating to Indian property and services requiring a particular physical performance can raise different questions. Do not assume every service delivered by email follows the general rule. Conversely, the location of the employee's laptop is not automatically the recipient location or place of supply.
Use current place-of-supply law
Where either relevant party location is outside India, section 13 supplies the framework, including specific categories and later amendments. Identify the provision operative for the supply period. Older manuals and consolidated publications can retain superseded wording or show amendments with separate commencement dates.
Keep a short reasoning note with the decisive contract facts. A foreign client paying for a service whose place of supply is in India does not satisfy the outside-India condition merely because payment arrives from abroad. Reopen the analysis when the scope changes rather than copying a previous export invoice indefinitely.
Illustrative remote research engagement
Assume an Indian supplier contracts with an independent overseas business for a remote procurement-research report. The reviewed facts support an outside-India recipient and place of supply, the establishment condition is met and receipts satisfy the permitted-payment condition. The exclusive contract value is ₹6,00,000, with ₹2,00,000 advance and ₹4,00,000 after acceptance.
Link both receipts to the contract and invoices, and keep delivery and acceptance evidence. A valid reviewed LUT route without IGST payment does not make the service value zero. If only the advance has arrived, track the remaining ₹4,00,000 and the relevant GST and foreign-exchange conditions instead of marking payment evidence complete for the entire contract.
Examine payment form and receipt details
The statute permits convertible foreign exchange or Indian rupees where RBI permits. Do not state that every INR receipt fails export status, or that every INR transfer from an overseas-linked account qualifies. Identify the actual arrangement, bank documentation and applicable permission.
Separate gross customer settlement, bank charges, exchange conversion and unpaid commercial amounts. A lower net bank credit can have several explanations. Obtain the bank's supporting advice and customer allocation rather than automatically reducing taxable value or assuming the entire shortfall represents unrecovered export proceeds.
Keep GST and foreign-exchange clocks distinct
Review the current RBI framework for the transaction period and the specific GST route conditions, including Rule 96A where relevant. Their requirements are related but should not be collapsed into one old timeline copied from an earlier checklist. Record the rule, start date, due date and extension evidence applicable to each obligation.
Escalate overdue or uncertain receipts before a condition expires. A promise from the customer to pay later is useful commercial information but does not itself extend a statutory period. Keep any approved extension or bank action with the original invoice references.
Complete the billing and evidence chain
Use the appropriate current Rule 46 endorsement and recipient particulars for the approved route. Compare value, currency, date and treatment across the invoice, ledger and applicable outward-supply data. Review any relevant electronic invoice requirement separately.
Retain the contract, location note, delivery record, acceptance, receipts and route evidence together. An export-service file is complete when each statutory condition can be supported independently and the invoice reflects that conclusion. That gives the business a defensible billing decision without relying on a foreign address, an optimistic payment promise or an outdated general rule.