Deemed exports
Section 147, CGST Act
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Section 147 lets the Government notify certain supplies of goods as DEEMED EXPORTS (e.g. supplies to EOUs/advance-authorisation holders) even though goods do not leave India, with refund benefits.
What this means in practice
The parts that actually decide cases — the things a practitioner checks first.
Deemed exports are notified under Notification 48/2017-Central Tax: supplies against advance authorisation, to an EPCG holder, to an EOU, and gold supplied by a bank or PSU against advance authorisation.
Tax IS payable on a deemed export – the benefit is that either the supplier or the recipient can claim the refund, with a declaration from the other that he will not.
Deemed exports are not zero-rated: no LUT route, and no refund of unutilised credit on that account.
Questions people actually ask
Real questions we get on this provision, answered straight.
We supply to an EOU. Can we supply without paying tax under an LUT?+
No. A deemed export is not a zero-rated supply – you must charge tax on the invoice. The refund is then claimed either by you or by the EOU, with a declaration from the other party that it will not claim it.
The exact words of the law
326 characters, uneditedReproduced from the CBIC text. We explain it above — but you should always be able to read it yourself.
Read the full provision+
What changed, and when
The amendment trail, newest first — because the version that applies to your case depends on the period.
2017-07-01 · Commenced
Provision as originally enacted in the CGST Act, 2017 (Act 12 of 2017) and brought into force w.e.f. 01-07-2017.
Where this comes from
Text reproduced from the Central Board of Indirect Taxes and Customs, as available on 2026-09-05. The explanation and practice notes above are GSTZone’s own, written for this hub. If you spot anything out of date, tell us and we’ll fix it — this hub is checked daily against CBIC.
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