Question
I am an exporter having office at Delhi. I have export sales from India and Non-GST Sales procured from outside India and sold outside India without touching customs fronties of India. We pay GST on ocean freight on Non-GST Supply in this process. Can we claim refund of GST paid on ocean freight on Non-GST Supply as amended in Schedule III of GST Act 2018 ? What is the effective date of these amendments. Can we claim credit of IGST paid in the months of April - Aug.2018 ?
Answer
As per section 17(2) credit is restricted as
follows:
Where goods or services or both are used by the registered person partly for
effecting taxable supplies including zero-rated supplies under this Act or under
the Integrated Goods and Services Tax Act and partly for effecting exempt
supplies under the said Acts, the amount of credit shall be restricted to so
much of the input tax as is attributable to the said taxable supplies including
zero-rated supplies.
where 'exempt supply' means supply of any goods or services or both which
attracts nil rate of tax or which may be wholly exempt from tax under section
11, or under section 6 of the Integrated Goods and Services Tax Act, and
includes non-taxable supply
As credit is not allowed on Non taxable supply therefore you are not eligible
for credit on Ocean freight related to non GST supply.
Further Section 54 of CGST Act relating to Refund of tax provides that no
refund of unutilised input tax credit shall be allowed in cases other than
(i) zero rated supplies made without payment of tax;
(ii) 'where the credit has accumulated on account of rate of tax on inputs being
higher than the rate of tax on output supplies (other than nil rated or fully
exempt supplies), except supplies of goods or services or both as may be
notified by the Government on the recommendations of the Council
As your case is not covered under any of the above two situations and also you
are not eligible for credit as per section 17 of CGST, so the question of refund
does not arise.
Press release dated 21-7-2018 vide s.no. 9 and CGST Amendment Act 2018 has
covered the following transactions under Schedule III:
a. Supply of goods from a place in the non-taxable territory to another place in
the non-taxable territory without such goods entering into India;
b. Supply of warehoused goods to any person before clearance for home
consumption; and
c. Supply of goods in case of high sea sales.
However till now the same has not been notified by CBIC. It will become
effective only from the date of Notification. As soon as the notification is
issued you will be informed. (Reply dt.06/11/2018)