DDP export valuation: reimbursed delivery costs are included in IGST taxable value unless treated as pure agent reimbursements.

On DDP export supplies, reimbursed costs incurred until delivery, including ocean freight, insurance, foreign import duties and delivery charges, form part of the transaction value for IGST purposes under Section 15 of the CGST Act read with Section 20 of the IGST Act. Where the supplier bears the costs and risks up to destination and the expenses are not shown to be pure agent reimbursements, they are includible in the taxable value of the export supply. The ruling also notes that the refund question was not examined because it fell outside the advance ruling scope.

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Issues: (i) Whether, in exports made on Delivered Duty Paid terms, reimbursed expenses such as ocean freight, insurance, foreign import duties, delivery charges and other costs incurred until delivery are includible in the value of taxable supply for payment of IGST on export of goods.

Analysis: The value of taxable supply is governed by the transaction value under Section 15 of the CGST Act, read with Section 20 of the IGST Act. The value includes taxes, duties and charges levied under other laws, amounts payable by the supplier in relation to the supply, and incidental expenses charged by the supplier at or before delivery. On the facts, the supply was made on DDP terms, the supplier bore all costs and risks till delivery, and the applicant ed that it was not acting as a pure agent. The reimbursed expenses therefore formed part of the amount chargeable for the export supply.

Conclusion: The expenses incurred under DDP terms until delivery are includible in the value of taxable supply for payment of IGST on export of goods, in favour of the Revenue on this issue.

Final Conclusion: The ruling settles the valuation issue by bringing DDP-related reimbursed expenses within the export transaction value, while declining to answer the refund question as outside the advance ruling scope.

Ratio Decidendi: Where the supplier undertakes delivery on DDP terms and bears the costs till the buyer's destination, such expenses are part of the transaction value for IGST purposes unless they are excluded as pure agent reimbursements.

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