Compliances for supplies made to Merchant Exporters at concessional GST rate

Vide this Outlook, we intend to apprise you of some compliances generally missed by Merchant Exporters having critical implications on supplier.?

Notification No. 40/2017 - Central Tax (Rate) dated October 23, 2017 provides concessional GST rate of 0.10% for supplies made to Merchant Exporter. This concession is available to supplier subject to following compliances being undertaken by Merchant Exporter:?

·?????????????????Merchant Exporter must export goods within ninety days from date of issuance of Tax Invoice by supplier.?

·?????????????????Merchant Exporter must mention details of supplier on Shipping Bills.?

·?????????????????Merchant Exporter must be registered with Export Promotion Council.?

·?????????????????Merchant Exporter must furnish following documents to jurisdictional officer of supplier:?

-????????????????Copy of purchase order issued by Merchant Exporter?

-????????????????Copy of Shipping Bill, Export General Manifest and Tax Invoice of supplier?

-????????????????Where goods are sent to warehouse for aggregation, copy of endorsed Tax Invoice from warehouse operator.?

NITYA Comments: If any of abovementioned compliance is missed, benefit of concessional rate can be denied to supplier. Recently, department is rigorously checking such compliances during departmental audits. For any missed compliances in past, suppliers need to analyse whether such non-compliance is a procedural miss (which can be condoned by department or in appeal) or differential tax liability may arise in such cases.?

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