Export and SEZ Invoices: The Endorsement That Refunds Depend On

Export and SEZ Invoices explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.

An export invoice is an ordinary tax invoice with two additions. Both are prescribed, and both are checked at the refund stage before anything else is examined.

The proviso to Rule 46 requires an invoice for the export of goods or services to carry one of two endorsements — "SUPPLY MEANT FOR EXPORT / SUPPLY TO SEZ UNIT OR SEZ DEVELOPER FOR AUTHORISED OPERATIONS ON PAYMENT OF INTEGRATED TAX" or "...UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX" — and to contain, in place of the ordinary recipient particulars, the name and address of the recipient, the address of delivery, and the name of the country of destination.

Match the endorsement to the route

Section 16(3) of the IGST Act gives a zero-rated supplier two routes, and the endorsement must match the one actually used.

With payment of IGST. The supplier charges IGST on the invoice and claims refund of the tax paid — under Rule 96 for goods, where the shipping bill is deemed to be the refund application, and under Rule 89 for services.

Endorsement: "...ON PAYMENT OF INTEGRATED TAX".

Without payment, under bond or LUT. No tax is charged, and the supplier claims refund of unutilised input tax credit under Rule 89(4).

Endorsement: "...UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX".

An invoice carrying the wrong endorsement contradicts the refund claim on its face, and that is the first thing a deficiency memo in RFD-03 picks up.

The recipient particulars for an export

For a domestic supply to an unregistered recipient, Rule 46(e) requires name, address, address of delivery and the State name and code.

For an export, the proviso substitutes:

• name and address of the recipient;
• address of delivery; and
• name of the country of destination.

The country of destination is the item most often omitted, and it is the one that ties the invoice to the shipping bill.

What else the export invoice must carry

No place of supply State code. The place of supply for an export of goods is outside India under s.11(b) of the IGST Act; for services, under s.13. There is no Indian State to name.

IGST rate and amount, where the with-payment route is used. Zero, where the LUT route is used — with the endorsement explaining why.

The LUT reference, in practice, where the without-payment route is used. Not prescribed by Rule 46, but expected in a refund file and required by Rule 96A, which governs the export of goods or services under bond or LUT.

Currency and exchange rate. Rule 34(1) applies the customs notified rate to goods and Rule 34(2) the GAAP rate to services, both on the date of the time of supply. Rule 34: which exchange rate applies →

The IRN, where the supplier is covered by e-invoicing. Export invoices are within the e-invoicing scope. An invoice without an IRN →

SEZ supplies: the additional condition

Section 16(1)(b) of the IGST Act zero-rates a supply to an SEZ developer or SEZ unit only "for authorised operations". The endorsement carries those words for a reason.

Two practical consequences:

The supply must actually be for authorised operations. A supply to an SEZ unit for something outside its letter of approval is an ordinary taxable supply.

Evidence is required with the refund. Rule 89(2) lists, for SEZ supplies, an endorsement by the specified officer of the zone evidencing receipt of the goods for authorised operations, or evidence of receipt of services for authorised operations.

The SEZ unit or developer will not endorse a supply outside its authorised operations, which is where an incorrectly characterised supply is discovered.

Deemed exports are different

A deemed export under s.147 is not a zero-rated supply. Tax is charged and paid, and the refund is claimed by either the supplier or the recipient, on the conditions in the deemed export notification and Rule 89(2)(g) and (h).

So a deemed export invoice:

• carries CGST and SGST or IGST as an ordinary domestic supply;
• does not carry the export endorsement;
• must state that the supply is a deemed export, per the conditions notified;
• supports a refund by whichever party claims it, with the other's undertaking not to claim. Deemed exports under GST →

Key takeaways

• Two prescribed endorsements, matching the with-payment and without-payment routes.
• The invoice must carry the name of the country of destination.
• No State code for the place of supply on an export invoice.
• SEZ supplies must be for authorised operations, evidenced by the specified officer's endorsement at the refund stage.
• Export invoices are within e-invoicing and need an IRN where the supplier is covered.
• Deemed exports are taxable supplies and carry no export endorsement.

Read next

• Rule 46: Every Particular a Tax Invoice Must Carry
• Export Invoice Format Under GST: With and Without IGST
• Zero-Rated Supply: Exports and SEZ Under IGST
• Rule 34: Which Exchange Rate Applies

Disclaimer: Positions stated as on 5 September 2026, based on the CGST and IGST Acts and Rules as amended to 31 March 2026 (ICAI Bare Law, 12th edition) and the ICAI Handbook on Invoicing under GST (2025).