Transportation of goods through Courier mode

[V Rajalakshmi]

An exporter engages a courier persons to transport their goods outside country

Supplier one – using SAC 996812 –charges IGST of 18%

Supplier 2 – uses SAC 996799 charges – 9% of sgst and 9% CGST

Q 1Whetthe the proviso to sec 12 (8) applicable to courier person engaging in the transportation of goods or the proviso applicable only to transporter alone.

Q 2 what is the correct place of supply for goods sent outside country through courier mode

Q 3 Whether the recipient is eligible to claim ITC irrespective of the SAC used by the supplier, ?

[Ravinesh Sinha]

Ans 1-Section 12(8) of IGST is also applicable for courier

Ans-2 place of supply for goods sent outside country through courier mode shall be the location at which such goods are handed over for their transportation as section 13(9) excludes courier services .

Ans-3 ITC should not be denied on basis of SAC only

[Shilpi Jain]

Section 12(8) specifically includes courier also.

Section 13 will not be applicable for cases where service provider and recipient are both within India. so for second query place of supply should be outside India as per section 12.

Credit should not be denied merely because it is pos outside India. That was not the intention of the amendment. Though will have to see in GSTR-2B if it will be shown as ineligible credit and what will be the department view and stand

[AdvMurari Kumar]

Dear Shilpi JI,

AS Per 2B ITC Availability is Yes.

AI Summary

Place of supply for couriered exports: handover location governs tax treatment and input tax credit remains available.
IGST treatment applies to courier persons engaged in cross-border carriage; the place of supply for goods sent abroad by courier is the location where goods are handed over to the courier, and input tax credit should not be denied solely because of the SAC used or because the place of supply is outside India, though GSTR-2B presentation and department views may affect practical availability.