sale to merchant exporter

Well an expert in export import would be able to give you an explanation of this. google search "greenchannelinterport" and call on the number given on the website.

The goods sold to the Merchant exporter is neither export sale nor domestic sale till certian fixed condition are fulfilled.Prior to GST when any goods is purchased by merchant exporter he was required to give "H" Form to the Manufacturer supplier along with requisite documents as required under CT1 Form procedures as per Central Excise Act.The Merchant exporter was required to submit to the supplier of the Goods duly filed and signed Form 'H" along with copy of Bill of Lading.Similarly the Merchant exporter was required to submit ARE1 signed by the Customs Autorities of port of export along with copy of  shipping bill and Bill of Lading.

Similarly,after GST the certain condition nas per the Notification No. 40/2017-Central Tax (Rate) are required to be fulfilled for considering the suppy as Export sale.

So, the supply made to the Merchant exporter is neither export sale nor domestic sale but it is a supply "in the course of export" till requisite condition are fulifilled otherwise the supply will be said to be a domestic sale.