Exporters for any country are the most respected community as they earn foreign currency for the nation. On 1st July 2017, when the whole nation was celebrating GST, the Exporters looked totally confused and perplexed. The reason being Notification No. 15/2017-Central Tax dated 01.07.2017 and Circular No. 26/2017-Cus dated 01.07.2017 (copy enclosed) prescribes the following new procedure for export of goods/services. It stated that in case of export without payment of IGST, a Bond or LUT in Form GST RFD-11 is required to be furnished prior to export to the jurisdictional Commissioner. It further stated that the exports must be under Tax Invoice. The procedure of preparation of ARE-1 is discontinued. Export Invoice should have endorsement as “Supply meant for Export on Payment of IGST” or “Supply meant for Export under bond without payment of IGST”. Interestingly, the exporters could not locate the Bond format RFD 11 on the much hyped GST common portal of GSTN.

The Exporters were told that Sealing of Containers by CBEC Officials discontinued. Only self-sealing of containers are permitted and thus they were supposed to inform the premises, factory, warehouse or any other place where container stuffing is to be carried out to the jurisdictional Customs Officer. Even the Shipping Bills will be linked to the system and the same will be generated based on the GSTIN. However, practically none of the said things worked. Majority of the Exporters were running from pillar to post to ensure that the formalities were completed so that their export consignments are not held up. Thus on 7th July, they came out with another instruction as Various communications have been received from the field formations and exporters that difficulties are being faced in complying with the procedure prescribed for making exports of goods and services without payment of integrated tax with respect to furnishing of bonds/Letter of Undertaking. Therefore, the said procedure was again changed and offline bonds / LUT were allowed to be filed with the jurisdiction AC/DCs. Further it was clarified that the existing practice of sealing the container with a bottle seal under Central Excise supervision or otherwise would continue till 01st September, 2017 and such sealing shall be done under the supervision of the officer having physical jurisdiction over the place of business where the sealing is being done. Thus on 1st July the GST regime which was implemented, a U turn was made in just one week and almost the same old practice was adopted. This shows the lack of coordination between the Customs, GST and Commerce Ministry and a sheer lack of preparedness at all the fronts.

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