Mold cost invoice in GST return

Dear Sir/Madam,

We seek your guidance regarding the GST and deemed export implications of the following transaction:

1. An Indian manufacturer has developed a mould as per the requirements of our customer located in Germany.
2. The manufacturer has raised an invoice on our company (GST registered in India) for the mould cost.
3. We have subsequently raised an invoice on the German customer for the mould cost added our profit.
4. The ownership of the mould belongs to the German customer.
5. The mould will remain in India and will be retained at the Indian manufacturer's premises for production of parts/components for the German customer.
6. The mould will not be physically exported outside India.
7. Payment from the German customer will be received in INR.
8. We have not charged GST on the invoice raised to the German customer.

We would appreciate your opinion on the following:

• Whether this transaction qualifies as a deemed export under the Foreign Trade Policy or GST provisions.
• Whether the supply made by us to the German customer can be treated as export of goods, export of services, or any other category under GST.
• Whether GST is applicable on the invoice raised to the German customer.
• If GST is applicable, what would be the correct tax treatment and compliance requirements.
• Any risks, documentation requirements, or precautions that we should consider.

Please let us know if you require copies of the purchase order, invoices, or any additional documents for your review.

Thank you for your assistance.