GST.
GST on the trade flow — imports, exports, SEZ/EOU supplies, refunds, notices
CGST / IGST Acts 2017 · CGST Rules rr.89–96B · Schedule III
Engagement models: Annual retainership · Project-based mandates · One-time representations & opinions

Structure
Positions settled before the transaction
<1 day
Senior advisor first response
01 / 03 · BEFORE THE TRANSACTION
Structure — getting in, on the right terms
Zero-rating done deliberately (LUT in RFD-11)
LUT under rule 96A or export with payment and refund under rule 96 — chosen on your credit position and cash cycle; SEZ supplies with the Specified Officer's endorsement your refund will later need.
Place of supply for cross-border services
The s.13 default and its exceptions, the intermediary question, and how the contract is written so the export-of-services conditions in s.2(6) are actually met — payment in convertible currency, distinct persons and all.
Import IGST and credit
IGST at the port under s.3(7) of the Customs Tariff Act, credit through the Bill of Entry data in GSTR-2B, and the reverse-charge position on imported services under s.5(3) of the IGST Act.
Schedule III transactions — high-seas, in-bond sales
Merchant trade, high-sea sales and sales of goods in a customs bonded warehouse before clearance for home consumption — structured so the documents evidence the transaction the Schedule describes.
SEZ, EOU and deemed-export supplies
The GST treatment of SEZ, FTWZ and EOU procurement, DTA sales by zone units, deemed exports to EOUs and Advance Authorisation holders, and job-work movements — where GST, Customs and the SEZ Rules meet.
02 / 03 · DURING OPERATIONS
Operate — keeping the benefit
Refunds pursued to credit, not just to filing (RFD-01, deficiency memos)
RFD-01 prepared to the rule 89(4) formula with the turnover and net-ITC positions the officer will test; deficiency memos in RFD-03 answered without restarting the clock avoidably; provisional refund and s.56 interest claimed where due.
Shipping-bill refunds that actually flow (GSTR-1 ↔ ICEGATE)
The ICEGATE–GSTN matching that stalls rule 96 refunds — invoice and port-code mismatches, GSTR-1 table 6A errors, EGM gaps — found and cured, and rule 96B realisation tracked against EDPMS.
Credit protection — s.16(4) time limits, s.17(5) blocks
ITC eligibility and GSTR-2B reconciliation, blocked credits under s.17(5), the s.16(4) time limit and the relaxations in s.16(5)–(6), and the import-IGST credit trail from Bill of Entry to return.
SEZ, EOU and deemed-export refunds
Refunds by the DTA supplier or the recipient on deemed-export supplies under Notification 48/2017-CT, and the endorsement and declaration set each requires.
Returns, e-invoicing and s.65 audits by design
GSTR-1 export and SEZ tables, e-invoice fields that carry through to the shipping bill, and records built for the s.65 audit rather than reconstructed for it.
03 / 03 · WHEN CHALLENGED
Defend — when the department disagrees
Pre-notice (DRC-01A) and the first reply
DRC-01A intimation answered so the notice never issues, or narrowed before it does; the s.73 / 74 / 74A reply built on limitation, on the merits and on quantification together.
Audits, DGGI and summons
s.65 audit findings answered before they harden into a notice; s.70 summons, statements and the DGGI investigation record handled from the first appearance.
Refund rejections and credit reversals
RFD-06 rejections and ITC-reversal demands appealed under s.107 on the specific ground the officer took — usually a formula, an endorsement or a time-limit point that has a statutory answer.
Detention of goods in transit (s.129)
s.129 detentions of export or zone-bound cargo — the notice, the seven-day clocks and the choice between paying under protest and contesting, made with the shipment's deadline in view.
Appeals and the pre-deposit ladder (ss.107, 112)
APL-01 to the Appellate Authority within three months; APL-05 to the GST Appellate Tribunal; the ten-per-cent deposits and their caps computed correctly, and refunded with interest when you win.
The trade side of GST — credits and refunds on imports, exports and zone supplies protected, processed and defended.
A senior advisor replies within one business day, not a call centre.
