GST refund on account of accumulated ITC for exports without payment of tax

CBIC circular 23.03.2020 requires exporters to compare export prices with domestic sales price of same product by similar sellers.

Any resolution for below issues ??

1. In case of CIF contract, insurance and freight component is apportioned to various product categories based on weight/value etc. However no such huge expenses incur in case of domestic sales

2. The export prices could differ in a big way if the export is done through air instead of sea.

3. It is possible that the goods exported are not sold in domestic market at all by same seller as well any other seller.

4. Its difficult to find similar placed sellers as there could be differences like volume,capital,workforce.

5. Export and domestic product and pricing database comes at very high costs.

What are the exporters practically submitting to the GST officials for sanction of their refund?
Replies (3)
Quick Summary
This discussion addresses the difficulties exporters face when claiming GST refunds on accumulated Input Tax Credit (ITC) for exports without payment of tax, particularly concerning the requirement to compare export prices with domestic sales prices. Key issues raised include the apportionment of CIF costs, price variations due to shipping methods, the absence of domestic sales for some exported goods, and the impracticality of finding comparable sellers and maintaining extensive pricing databases. The thread seeks practical approaches exporters are using to satisfy GST officials and explores potential solutions for more effective valuation methods.

This is definitely very problematic. Proper valuation methods will have to be prescribed like that existent in customs act for these provisions to be successful.
Dear Raj C Doshi , can quote the circular & issued under custom or GST, because I do find the same .
Yes
I think the such comparison is made only in case of Import , when goods being import with low price & to control unfair competition in domestic market, the govt impose Anti Dumping Duty.
Notification No. 16/2020-Central Tax dt. 23.03.2020.

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