EOU and deemed exports

GSTR-2B reconciliation for export oriented units: deemed export and Bill of Entry matching

By gstr2bmatch.in Editorial Team · Updated 17 October 2026 · 9 min read

Export Oriented Units (EOUs) manage two distinct procurement streams that demand separate reconciliation paths in GSTR-2B. Domestic inputs procured under deemed export benefits appear in Table 4(A)(5), whereas direct overseas imports transmitted from ICEGATE populate Table 4(A)(1). Matching both streams prevents wrongful input tax credit claims, eliminates supplier disclaimer disputes under Rule 89(2)(g), and protects refund approvals in Form GST RFD-01.

Operating an Export Oriented Unit requires navigating a distinct indirect tax framework compared to standard domestic enterprises or Special Economic Zone (SEZ) units. Unlike supplies to SEZ developers or units, which qualify as zero-rated supplies under Section 16 of the IGST Act and can move without payment of tax under a Letter of Undertaking, domestic sales to EOUs do not enjoy statutory zero-rating. Instead, procurement from the Domestic Tariff Area (DTA) constitutes a deemed export under Section 147 of the CGST Act, requiring domestic suppliers to charge full GST upfront. Coupled with physical imports cleared through customs ports, accounting teams in EOUs must reconcile two entirely different data feeds within their monthly GSTR-2B.

Statutory distinction between physical imports and deemed exports

The substantive foundation for deemed exports is established under Section 147 of the CGST Act. This section empowers the Central Government to notify specific supplies of goods manufactured in India where the goods do not leave the country, but payment is received in Indian rupees or convertible foreign exchange:

“The Government may, on the recommendations of the Council, notify certain supplies of goods as deemed exports, where goods supplied do not leave India, and payment for such supplies is received either in Indian rupees or in convertible foreign exchange, if such goods are manufactured in India.” Section 147, CGST Act 2017

To implement this provision for EOUs, the Government issued Notification No. 48/2017-Central Tax on 18 October 2017. Serial Number 3 of the notification table explicitly lists "Supply of goods by a registered person to Export Oriented Unit" as a notified deemed export. This classification creates a critical compliance bifurcation:

  1. Physical overseas imports: Cleared on a Bill of Entry through customs under Section 12 of the Customs Act, with Integrated GST levied under Section 3(7) of the Customs Tariff Act. Customs port data transmits electronically from ICEGATE to the GST portal.
  2. Domestic DTA procurements: Treated as deemed exports under Section 147. The DTA supplier issues a standard tax invoice charging CGST and SGST (for intra-state supplies) or IGST (for inter-state supplies) and uploads the record in their Form GSTR-1.
  3. Input services: Services supplied to an EOU do not qualify as deemed exports. Under Section 147 and Notification No. 48/2017-Central Tax, deemed export benefits apply strictly to supplies of goods manufactured in India. Services follow standard B2B ITC rules under Section 16 of the CGST Act.

For more details on managing exports under LUT for services and goods, consult our dedicated guide on export of services without payment of tax under LUT.

Mapping EOU inward supplies into GSTR-2B tables

Because physical imports and domestic deemed exports follow separate statutory mechanisms, they settle into distinct tables within your auto-generated GSTR-2B statement and subsequent Form GSTR-3B summary return, as detailed in the GSTN GSTR-3B User Manual:

Procurement category Underlying document GSTR-2B table GSTR-3B table destination
Direct overseas import of goods Bill of Entry filed on ICEGATE GSTR-2B Table 4(A)(1) (Import of goods) Table 4(A)(1) Import of goods
Import of goods from SEZ units Bill of Entry for home consumption GSTR-2B Table 4(A)(1) (Import of goods from SEZ) Table 4(A)(1) Import of goods
Domestic DTA deemed export (Goods) Tax invoice from registered DTA vendor GSTR-2B Table 4(A)(5) (B2B Inward supplies) Table 4(A)(5) All other ITC
Regular domestic input services Tax invoice for freight, legal, maintenance GSTR-2B Table 4(A)(5) (B2B Inward supplies) Table 4(A)(5) All other ITC
Reverse charge supplies (RCM) Payment voucher / GTA consignment note GSTR-2B Table 4(A)(3) (Inward supplies liable to RCM) Table 4(A)(3) Inward RCM credit

When multi-locational manufacturing setups operate units across different states, review our technical walk-through on GSTR-2B reconciliation for multiple GSTINs to track branch transfers and ISD allocations.

Common mistake: Treating domestic procurement for EOUs as exempt or zero-rated. DTA suppliers who erroneously file invoices under Table 6A (Exports) or Table 6B (SEZ supplies) of Form GSTR-1 cause these records to vanish from your regular B2B GSTR-2B tables. Domestic deemed export invoices must be reported under Table 4A/4B of GSTR-1 with the deemed export flag checked.

Reconciliation path 1: ICEGATE Bill of Entry matching in Table 4(A)(1)

Physical imports cleared through customs ports auto-populate into GSTR-2B Table 4(A)(1) via an automated data pipeline between ICEGATE and GSTN. While this automation eliminates manual entry errors, timing mismatches and transmission failures remain frequent operational hurdles.

  1. Verify GSTIN mapping: Ensure your 15-digit GSTIN is correctly linked to your Import Export Code (IEC) in the customs EDI system. A mismatch between the IEC entity name and GST registration details prevents automatic transmission.
  2. Out of Charge (OOC) cut-off dates: Data transmits to GSTN only after the proper customs officer grants Out of Charge (OOC). If an import receives OOC on the 13th of October, it might not integrate before GSTR-2B generation on the 14th of October, pushing the record into November GSTR-2B.
  3. Amendment handling: If a Bill of Entry is amended post-clearance (for example, reassessment of customs value or differential duty), the revised IGST amount updates in Table 4(A)(1) only after supplementary transmission from ICEGATE.
  4. Manual fetch utility: If a cleared Bill of Entry is missing from GSTR-2B, access the GST portal navigation: Services → User Services → Search BoE. Enter the port code, Bill of Entry number, and date to initiate an on-demand pull from ICEGATE.

Reconciliation path 2: domestic deemed exports and Rule 89(1) disclaimers

Reconciling domestic supplies received under deemed export benefits requires synchronizing accounting records with the refund mechanism chosen under the third proviso to Rule 89(1) of the CGST Rules:

“Provided further that in respect of supplies regarded as deemed exports, the application may be filed by, - (a) the recipient of deemed export supplies; or (b) the supplier of deemed export supplies in cases where the recipient does not avail of input tax credit on such supplies and furnishes an undertaking to the effect that the supplier may claim the refund” Rule 89(1), CGST Rules 2017

This statutory rule creates two mutually exclusive refund routes. The accounting treatment in your books and the reconciliation in GSTR-2B must align strictly with the agreed route:

Route A: Supplier claims the deemed export refund

When commercial contracts dictate that the domestic supplier claims the refund of GST paid on deemed export supplies, the recipient EOU must never avail input tax credit on that invoice. In this scenario:

  1. The supplier reports the invoice in Form GSTR-1 as a deemed export supply and pays the output tax liability in Form GSTR-3B.
  2. The invoice auto-populates in the recipient EOU's GSTR-2B Table 4(A)(5).
  3. The EOU must not claim this ITC in Table 4(A)(5) of Form GSTR-3B. Instead, the credit must either be left unavailed or reversed in Table 4(B)(2) to prevent double benefit.
  4. The EOU issues a formal undertaking and disclaimer certificate to the supplier confirming that credit has not been availed, enabling the supplier to file Form GST RFD-01 under Rule 89(2)(g).

Route B: Recipient EOU claims the deemed export refund

When the EOU pays the invoice value along with GST to the supplier and undertakes the refund filing independently:

  1. The EOU verifies that the invoice is reflected and eligible in GSTR-2B Table 4(A)(5).
  2. The EOU avails ITC in Table 4(A)(5) of Form GSTR-3B, or alternatively, claims a direct refund of the tax paid on deemed export supplies without availing ITC.
  3. The supplier furnishes an undertaking confirming that they have deposited the tax in the Government treasury and have not claimed a refund of the said tax amount.

Audit and notice risk: If your EOU avails ITC in Form GSTR-3B Table 4(A)(5) while your domestic supplier simultaneously files Form GST RFD-01 to claim a cash refund of the same tax, the GST portal flags a dual claim. Both entities will face scrutiny notices in Form DRC-01A or Form DRC-01, accompanied by mandatory recovery with 18% annual interest under Section 50.

Worked example: procurement arithmetic and disclaimer flow

Consider an Export Oriented Unit, Bharat Aero Components EOU (Karnataka), manufacturing precision turbine valves for global export. In October 2026, the unit procures materials across three channels:

  1. Direct import: Specialized alloy plates imported from Germany under Bill of Entry No. 8921470 dated 04 October 2026. Assessable customs value: ₹25,00,000. IGST paid via ICEGATE: ₹4,50,000 (18%). Basic customs duty: Nil under EOU exemption notification.
  2. Domestic deemed export (Route A - Supplier refund): Forged steel flanges procured from Apex Forgings Ltd (Maharashtra) under Tax Invoice AF-2026-118 dated 08 October 2026. Value: ₹15,00,000. IGST charged: ₹2,70,000 (18%). Agreement specifies that Apex Forgings claims the deemed export refund.
  3. Domestic deemed export (Route B - EOU refund): Heat-treated fittings procured from Deccan Precision Tools (Karnataka) under Tax Invoice DP-542 dated 11 October 2026. Value: ₹8,00,000. CGST: ₹72,000, SGST: ₹72,000 (Total ₹1,44,000). Agreement specifies that Bharat Aero Components claims the refund.
  4. Domestic factory services: Factory security and calibration services from local vendors under tax invoices totaling ₹2,00,000 with CGST of ₹18,000 and SGST of ₹18,000 (Total ₹36,00,000).
Document reference Supplier / Channel Taxable value Tax amount GSTR-2B reflection GSTR-3B treatment
BoE 8921470 German Alloy Supplier ₹25,00,000 ₹4,50,000 (IGST) Table 4(A)(1) Claim ₹4,50,000 in Table 4(A)(1)
INV AF-2026-118 Apex Forgings Ltd ₹15,00,000 ₹2,70,000 (IGST) Table 4(A)(5) Do NOT claim ITC; issue disclaimer
INV DP-542 Deccan Precision Tools ₹8,00,000 ₹1,44,000 (CGST+SGST) Table 4(A)(5) Claim ₹1,44,000 or file Statement 5B
INV SEC-104 Local Security Agency ₹2,00,000 ₹36,000 (CGST+SGST) Table 4(A)(5) Claim ₹36,000 in Table 4(A)(5)

In this reconciliation cycle, Bharat Aero Components verifies that total credit in GSTR-2B Table 4(A)(5) stands at ₹4,50,000 (₹2,70,000 + ₹1,44,000 + ₹36,000). However, because Apex Forgings will file for the deemed export refund on Invoice AF-2026-118, Bharat Aero Components strictly avails only ₹1,80,000 (₹1,44,000 + ₹36,000) in Table 4(A)(5) of Form GSTR-3B. Claiming the entire ₹4,50,000 would violate the third proviso to Rule 89(1) and invite severe departmental recovery proceedings.

Mandatory documentation under Circular No. 14/14/2017-GST

To substantiate deemed export transactions during departmental audits, EOUs must adhere to the compliance safeguards prescribed by CBIC Circular No. 14/14/2017-GST:

  1. Form-A prior intimation: The recipient EOU must issue a prior intimation in Form-A bearing a running serial number. This document specifies the description, quantity, and value of goods approved by the Development Commissioner, and must be submitted to the supplier and both jurisdictional GST authorities before dispatch.
  2. Invoice endorsement: Upon receiving the physical consignment at the EOU bonded warehouse, the unit must endorse the supplier's original tax invoice certifying physical receipt and send stamped copies back to the supplier and jurisdictional officers.
  3. Digital register in Form-B: The EOU must maintain an electronic stock ledger in Form-B with an audit trail, tracking the receipt, utilization in export production, and removal of deemed export goods. Monthly digital extracts must be provided to the jurisdictional tax officer.

Sample disclaimer certificate under Rule 89(2)(g)

When the supplier claims the refund under Route A, the EOU must furnish an undertaking formatted along these statutory lines:

To Whomsoever It May Concern UNDERTAKING AND DISCLAIMER CERTIFICATE UNDER RULE 89(1) OF CGST RULES, 2017 We, M/s Bharat Aero Components EOU, holding GSTIN 29AAAAA0000A1Z5 and Letter of Permission (LOP) No. 14/EOU/BLR/2022 valid up to 31 March 2028, hereby solemnly declare and affirm that: 1. We have received the supplies of forged steel flanges covered under Tax Invoice No. AF-2026-118 dated 08 October 2026 for a taxable value of Rs 15,00,000 and Integrated Tax of Rs 2,70,000 from M/s Apex Forgings Ltd (GSTIN 27BBBBB1111B1Z2) under deemed export benefits as per Notification No. 48/2017-Central Tax. 2. We have not availed input tax credit on the aforesaid invoice in Form GSTR-3B for the tax period October 2026 or any other tax period. 3. We have no objection to M/s Apex Forgings Ltd claiming a refund of the integrated tax paid on the said supplies in accordance with Section 54 of the CGST Act read with Rule 89 of the CGST Rules, 2017. For Bharat Aero Components EOU Authorised Signatory Name: Rajesh Sharma Designation: Head of Finance & Taxation Date: 14 November 2026

Reconcile your inward invoices and filter input credit

Separate domestic B2B supplies, deemed export invoices, and ICEGATE import records with exact invoice matching. Identify supplier filings in GSTR-2B, prevent double claims on disclaimer invoices, and prepare clean schedules for Form GST RFD-01. Your GSTR-2B and purchase register files are read in your browser and never uploaded to any server.

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Related guides

Frequently asked questions

Can an EOU receive domestic goods without payment of GST under LUT?

No. Under the GST framework, domestic procurement by an EOU is not zero-rated by default. Supplies of goods to an EOU are treated as deemed exports under Section 147 and Notification No. 48/2017-Central Tax. The domestic supplier must levy applicable CGST and SGST or IGST on their tax invoice. The tax paid can subsequently be claimed as a refund under Rule 89 by either the recipient EOU or the supplier.

Who can claim the refund of tax paid on deemed export supplies to an EOU?

Under the third proviso to Rule 89(1) of the CGST Rules, either the recipient EOU or the registered supplier can claim the refund. If the supplier files Form GST RFD-01, the recipient EOU must not avail input tax credit and must furnish an undertaking and disclaimer certifying that the supplier may claim the refund. If the EOU claims the refund, it avails ITC or files a direct refund application with Statement 5B.

Where does Bill of Entry import data appear in GSTR-2B?

Direct overseas import data transmitted from ICEGATE to the GST portal auto-populates in Table 4(A)(1) of GSTR-2B under Import of Goods. It includes the port code, Bill of Entry number, date, taxable value, and IGST paid. Inward supplies received from domestic suppliers under deemed export appear separately in Table 4(A)(5) as regular B2B inward supplies.

What procedure must an EOU follow before procuring deemed export goods?

Under CBIC Circular No. 14/14/2017-GST, the EOU must issue a prior intimation in Form-A bearing a running serial number approved by the Development Commissioner. Copies must be sent to the supplier, the supplier's jurisdictional GST officer, and the EOU's jurisdictional GST officer. Upon receipt of goods, the EOU must endorse the supplier's tax invoice and maintain digital stock registers in Form-B with an audit trail.

What happens if an imported Bill of Entry is missing from GSTR-2B Table 4(A)(1)?

If a Bill of Entry does not reflect in Table 4(A)(1) of GSTR-2B, verify that your GSTIN was correctly declared on the Bill of Entry filed in ICEGATE. Taxpayers can use the Fetch Bill of Entry details facility on the GST portal to query missing records from ICEGATE before claiming credit in Table 4(A)(1) of Form GSTR-3B.

Last checked: 17 October 2026. Sources: CGST Act Section 147, Notification No. 48/2017-Central Tax, CGST Rules Rule 89, CBIC Circular No. 14/14/2017-GST, GSTN GSTR-3B User Manual.