Place of Supply

XYZ (Japan) will be selling the goods to PQR(India) i.e. Invoice of XYZ will be on PQR. PQR further issues an Invoice on ABC (India)). ABC will be further selling the goods / issuing the invoice on EFG (Sri Lanka). However, the goods will be physically moved from XYZ(Japan) to EFG (Sri Lanka). Will this be treated as an export for PQR and whether PQR had got any GST liability on this?

Replies (5)
Quick Summary
This discussion explores the Place of Supply for goods moving directly from Japan to Sri Lanka, with an Indian entity (PQR) acting as an intermediary. The core question is whether this constitutes an export for PQR and if GST is applicable, given the goods never physically entered India. The consensus leans towards it being merchant trading under Schedule III, meaning it's neither a supply of goods nor services, and therefore no GST liability arises for PQR.

I think this will be considered as export by ABC.
It is goods on the vehicle the transaction covered under high sea sales
No...... it not being Export .
In term of Section 7 of IGST Act , goods neither cross the frontier of Indian Custom & As per Section 2(5) of IGST Act , export means taking goods out of India , but since the goods never came to India & hence there is no question of Export arises.

So it's is Merchant trading cover under Schedule III , neither the supply of Goods nor Supply of Services.
It is High sea transaction no gst applicable

DEAR SUNIL

ITS NOT HIGH SEA SALE. THERE IS DIFFERENCE BETWEEN MERCHANT TRADING & HIGH SEA SALE.

IN HIGH SEA SALE : THE GOODS COME TO INDIA BUT IT IS BEING SOLD BEFORE IT REACHES THE CUSTOM FRONTIERS.

MERCHANT TRADING : THE GOODS NEVER GET ENTER INTO INDIA

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