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Issue ID: 120486
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What is the definition of service provider ? For service export promotion council

Date 23 Sep 2025
Replies 4 Replies
Views 658 Views
Zero-rated supply classification for hotel services affects GSTR-3B reporting and EPCG export-obligation treatment.
Hotels can meet EPCG export obligations by earning foreign exchange supported by FIRC/BRC for specified services listed in the EPCG application; these services are not deemed exports. Forum responses conflict on GST treatment: some treat such supplies as zero-rated exports to be shown in GSTR-3B table 3.1(b), while others treat accommodation to foreigners as B2C with place of supply in India and not zero-rated, to be declared in table 3.1(a). (AI Summary)

What is the procedure to fulfil export obligation against EPCG license issued to hotel( service provider) ? 

in which columns of GSTR-3B, supply will be r reflected showing service provide to foreigners? 

Is it will be counted as deemed export or not ? 

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Replied on Sep 23, 2025
1.

Your have three questions:

Export obligation under EPCG for hotels is met by earning foreign exchange from from tourists (supported by FIRC/BRC).

In GSTR-3B, report under 3.1(b) as Zero-rated supply (exports) under Section 2(6) of the IGST Act.

No deemed export. In fact, it is treated as Export of Services (Zero-rated supply).

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Replied on Sep 23, 2025
1.1.

Thanks sir ji, A SERVICE PROVIDER have more than 200 licenses issued in the last five financial years but in GSTR-3B and 9 have zero digits in zero rated supply. 

also getting EODC from DGFT. 

How is it possible ? 

Or is not necessary to show in GSTR3b in case of EPCG OR SERVICE PROVIDER?

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Replied on Sep 28, 2025
2.

While you got your EPCG you would have mentioned the exports that you will do to fulfil the export obligation.

THose services alone can be regarded.

Export under FTP and GST is different.

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Replied on Sep 29, 2025
3.

In this case, I am assuming you are hotel (and also EPCG holder) and providing accommodation services to the foreigners. These supplies are considered for fulfilment of export obligation, since the export definition under FTDR Act is satisfied. But this is not considered as zero-rated supply under GST since the place of supply is India. It is neither considered as deemed exports. It is a regular GST B2C supply and to be declared in table 3.1(a) of GSTR-3B.

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