Export by Law, Not by Invoice Date

| Last updated: 05 August 2026

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Following the amendment to the IGST Act on 30.03.2026, a key question arises for service exporters: does the date of service completion or the invoice date determine if a transaction qualifies as an export? This article clarifies that the legal character of a service as an export is determined by the law in effect at the time the service was supplied, not by later invoicing or payment dates. While invoice and payment dates are important for compliance, they cannot retroactively change the nature of a completed supply.

Introduction: The Date That Decides the Export Character The omission of the special place-of-supply provision for intermediary services under Section 13(8)(b) of the Integrated Goods and Services Tax (IGST) Act, 2017, effective 30.03.2026, has raised an important transitional question for exporters of services. If a commission service was provided to a foreign client before 30.03.2026, but the invoice was issued and payment was received after 30.03.2026, can the supplier claim that the transac

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About the Author

Raj Jaggi

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CA. Raj Jaggi is a Chartered Accountant based in New Delhi, primarily practising in the field of Goods and Services Tax (GST) consultancy, litigation support, and advisory services. After being associated with the leading indirect tax firm A.K. Batra and Associates for nearly 19 years, from June 2007 to March 2026, he ... Read more

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