Who is eligible for deemed export benefits?

You are eligible for deemed exports if you supply goods made in India to a notified buyer and receive payment in INR or free foreign exchange. The supply must also fall in a category listed under the FTP or notified under GST.

Here is the simple checklist.

• The supply must be of goods, not services. A service supplied to an EOU or an Advance Authorisation holder does not count.

• The goods must be made in India. The FTP treats a supply as a deemed export only if the goods are manufactured in India.

• The buyer must be a listed entity. Supplies must be made directly to the entities listed in Para 7.02. A middleman in between can break eligibility.

• Payment must come in INR or free foreign exchange.

• GST must be paid on the supply. You cannot supply a deemed export under LUT or bond.

• Full payment must be received before you file an FTP claim.

Who can claim the GST refund, the supplier or the recipient?

Either one can claim, but not both on the same invoice. The supplier can claim only where the recipient does not take input tax credit on the supply and gives an undertaking allowing the supplier to claim. Decide this before the supply, and not after.

Special procedure for supplies to EOU, STP, EHTP and BTP units

Supplies to these units follow extra safeguards. The recipient unit gives prior intimation in a prescribed form before the supply. After receiving the goods, it endorses the tax invoice and sends a copy to the supplier and the tax officers. The endorsed invoice is treated as proof of the deemed export supply.

Documents you will need

Keep these ready at the time of supply, not at the time of filing.

• Tax invoice for the supply

• Statement of invoices with number and date

• Copy of the buyer's Advance Authorisation, EPCG Authorisation or EOU approval, as applicable

• Endorsed invoice from the recipient, where required

• The recipient's undertaking that it has not taken ITC, if the supplier is claiming

• The deemed export declaration in Statement 5B, which forms part of Annexure I of Form RFD-01

• Proof of full payment, for FTP claims

Notification No. 49/2017-Central Tax lists the evidence the supplier must produce when claiming a refund. Read it once before filing.

What are the benefits of deemed exports?

The main benefits of deemed exports are a refund of GST paid, deemed export drawback, Advance Authorisation or DFIA, and a refund of Terminal Excise Duty (TED). Which one you get will depend on the category of supply you fall under.

Even though your goods never leave India, the law treats you as someone who helped an export happen. So, here is what that means in practice.

1. Refund of GST paid

You can get back the GST you paid on a deemed export supply. GST is charged on the invoice first, and the refund comes later.

Either the supplier or the recipient can claim this refund through Form GST RFD-01, but both cannot claim on the same invoice. This matters because it stops tax from sitting in your account as a cost. For a manufacturer who sells in bulk to export-linked buyers, that is a big relief for working capital.

2. Advance Authorisation, Advance Authorisation for annual requirement and DFIA

Deemed exports can make you eligible for Advance Authorisation or DFIA under the Foreign Trade Policy. These let a manufacturer get inputs for export production without paying duty on them. These are among the benefits listed for deemed exports in Para 7.03 of the FTP.

3. Deemed export drawback

Deemed export drawback gives you back the duty that went into the inputs you used. It refunds the duty paid on inputs used to manufacture and supply goods under a deemed export. You claim it through Form ANF-7A on the DGFT portal. The result is a lower duty cost inside your product, which helps you price better.

4. Refund of Terminal Excise Duty (TED)

A TED refund returns the excise duty paid on the goods you supplied, but only for certain products. It applies only to excisable goods specified in the Fourth Schedule of the Central Excise Act, 1944. Check whether your goods fall in that list before you count on this benefit.

Benefits at a glance

How to claim deemed export benefits (Step by step)

You claim deemed export benefits in two places. The GST refund is filed on the GST portal using Form RFD-01. FTP benefits such as TED refund and drawback are filed on the DGFT portal using Form ANF-7A. The two claims have different conditions, so treat them as separate processes.

To claim the GST refund, you confirm that your supply is notified, pay GST on the invoice, collect your evidence, decide who will claim the refund, and file Form GST RFD-01 online.

Step 1: Confirm your supply is a notified deemed export

Check that your supply falls in a category notified under Section 147 of the CGST Act, 2017. If it is not in the list, it will not qualify for the GST refund, even if it looks like an export-linked sale.

Step 2: Issue the invoice and charge GST

Make the supply on a tax invoice and charge GST. Do not supply under LUT or bond. This is the most common place where suppliers go wrong, so double-check before you raise the invoice.

Step 3: Collect your evidence

Gather the tax invoice, the buyer's authorisation or approval, the endorsed invoice where required, and the recipient's undertaking if the supplier will claim.

Step 4: Decide who will claim, the supplier or the recipient

Settle this before you file, and get it agreed in writing. Only one party can claim against a given invoice.

Step 5: File Form GST RFD-01

The refund application is filed in Form GST RFD-01, and the process can be completed online. Attach the statement of invoices with the number and date of each invoice, along with your supporting documents.

Step 6: Track the application and respond to queries

Once you submit, you get an ARN. The application is then assigned to a refund processing officer. If the officer asks for more documents, reply quickly. Delays here are the usual reason a refund takes longer than expected.

Time limit for the GST refund: The application must be filed within two years, counted from a date linked to the return for those supplies. Do not wait until the last month. File as soon as your documents are ready.

How to claim FTP benefits (TED refund and deemed export drawback)

To claim FTP benefits, you identify your category under Para 7.02. Then, wait for full payment, and file Form ANF-7A online on the DGFT portal, with one application per category.

Step 1: Identify your category under Para 7.02

Your category decides which benefit you can claim and which extra conditions apply.

Step 2: Wait until you receive full payment

Do not file early. Claims can be filed only after payment is received in full, for the supplies covered in the main categories. Keep proof of the full payment ready.

Step 3: File Form ANF-7A on the DGFT portal

The supplier or the recipient of the goods makes the online application in Form ANF-7A through the DGFT website.

Step 4: File one application per category

A December 2025 DGFT notice (35/2025-26) says each ANF-7A application must relate to only one category of supply, and a single application for several categories is not allowed. If you made supplies under two categories, file two applications.

Step 5: Attach the prescribed documents

Upload the documents asked for in the form, such as invoices, proof of payment and the buyer's authorisation or approval.

Step 6: Receive the benefit after verification

The authority checks your application and documents. Once approved, you receive the benefit that applies to your category.

Quick summary: GST refund vs FTP claim

Worked example: GST refund on a deemed export

This is an illustration with simple numbers, not a real case.

A manufacturer in Gujarat supplies machine parts worth ₹10,00,000 to a company that holds an Advance Authorisation. Assume the GST rate is 18%.

The key point is that GST is paid first and refunded later. So, always plan your cash flow for that gap.

Common mistakes while claiming deemed export benefits

Most rejected claims come from a handful of avoidable errors. Here are the ones to watch for.

1.Treating deemed exports as zero-rated

Many suppliers assume no GST applies and supply under LUT, just like a physical export. Deemed exports are not zero-rated, so GST is charged on the supply. Charge GST on the invoice and claim it back as a refund later.

2.Both parties claiming on the same invoice

If the recipient takes ITC or files the refund, the supplier cannot claim for the same invoice. Agree in writing who will claim before the supply is made, so the claim does not get stuck later.

3.Filing ANF-7A before full payment

FTP claims can be filed only after payment is received in full, for the main categories of supply. A claim filed early can be rejected or sent back, and you lose time.

4.Mixing categories in one ANF-7A application

A December 2025 DGFT notice says each application must cover only one category of supply under Para 7.02. If you supplied under two categories, file two separate applications.

5.Confusing the FTP and GST definitions

A supply may qualify for a GST refund but not for an FTP benefit, or the other way round. Check both lists before you claim, so you do not plan around a benefit you cannot get.

6.Missing the two-year deadline

The GST refund application must be filed within two years, counted from a date linked to the return for those supplies. A late claim is usually lost, so file well before the last month.

7.Recipient exporting on payment of IGST

Where the supplier has availed the deemed export benefit, the recipient cannot export on payment of integrated tax. Recipients should check this before they plan their own exports.

8.Assuming services qualify

Only goods are covered under deemed exports. If you supply a service, plan for regular GST treatment instead.

9.Missing or incomplete evidence

A refund depends on documents like the endorsed invoice and authorisation copies. Collect them when you make the supply, so you are not chasing them months later.

How does Infinity help exporters receive payments?

Many businesses that supply deemed exports also export directly, and those direct exports bring in foreign currency. Getting that money in your bank account at a minimum cost, and with the right paperwork, matters just as much as claiming your refunds on time.

Infinity is an AD-1 certified, RBI-regulated platform that helps Indian exporters, freelancers, agencies and SaaS businesses receive international payments. For exporters, here is what stands out:

• 0.5% all-inclusive fee, with no separate FX markup and no additional GST

• Free FIRA, generated automatically, which serves as proof of your foreign inward remittance

• 24-hour settlement into your Indian bank account

• 50+ currencies and 160+ countries supported

• A dedicated account manager to help when something needs attention

• A mobile app to track your payments on the go

Getting started with Infinity is quick. You can sign up in about 2 minutes, complete KYC the same day, receive bank details in multiple currencies, and start receiving international payments seamlessly.

If you are new to export paperwork, read our guide on FIRA vs FIRC for exporters and our explainer on what is DGFT.

FAQs

1. What are deemed exports, who is eligible and what are the benefits?

Deemed exports are domestic supplies of Indian-made goods to notified buyers, that are treated as exports for benefit purposes. Suppliers (and sometimes recipients) are eligible if the supply falls in a notified category and payment is received in INR or free foreign exchange. The benefits include a GST refund, deemed export drawback, Advance Authorisation or DFIA, and a TED refund on eligible goods.

2. What are deemed exports?

Deemed exports are supplies of goods manufactured in India that do not leave the country but are treated as exports under the FTP or GST law. Deemed exports cover only goods, and not services.

3. Is GST charged on deemed exports?

Yes. Deemed exports are not zero-rated by default, so GST applies to the supply. The tax paid can be claimed back as a refund.

4. Are services covered under deemed exports?

No. Only supplies of goods manufactured in India qualify as deemed exports under both the FTP and GST law.

5. Who can claim the GST refund on deemed exports, the supplier or the recipient?

Either of one can claim the GST refund, and not both for the same invoice. The supplier can claim only where the recipient does not take ITC and gives an undertaking allowing the supplier to claim the refund.

6. Is a deemed export the same as a zero-rated supply?

No. A zero-rated supply, such as a physical export, can be made without paying GST under LUT or bond. A deemed export is a taxable supply where GST is paid first and refunded later.

7. What is the time limit to claim a deemed export refund?

The GST refund application in Form RFD-01 must be filed within two years. It is counted from a date linked to the return for those supplies. FTP claims follow the timelines in the Handbook of Procedures, so check those for your category.

8. Can both the supplier and the recipient claim the refund?

No. Only one party can claim against a given invoice. So, its better to agree in advance about who will file it.

9. What is Form ANF-7A?

ANF-7A is the online application form on the DGFT portal that is used to claim FTP deemed export benefits, such as TED refund and deemed export drawback.

Conclusion

Deemed exports reward suppliers who help others export, even when their own goods never leave India. The benefits of deemed exports are real: a GST refund, drawback, Advance Authorisation and TED refund. But the rules differ between FTP and GST, and even a small mistake in category, payment timing or claim filing can cost you the refund.

Check your category first, keep your evidence ready, agree on who will claim, and file within the deadline. Also, if you receive international payments, Infinity helps you with receiving your international payments at a flat 0.5% all-inclusive fee, with a free FIRA for your records.

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