Export of services — RBI-permitted Indian-rupee receipt: section 2 of the IGST Act, 2017

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GST›IGST Act, 2017›Section 2, definitions

Export of services requires the supplier to be in India and both the recipient and place of supply to be outside India. The supplier must receive payment in convertible foreign exchange or RBI-permitted Indian rupees. The supplier and recipient must also not be merely establishments of a distinct person under the specified IGST Explanation.^[1]

Quick facts

Section 2, IGST Act, 2017

Export of services — RBI-permitted Indian-rupee receipt

Provision
Act	Integrated Goods and Services Tax Act, 2017
Subject	Export of services — RBI-permitted Indian-rupee receipt
Clauses	2(6)
Amendments
Amendments	1 footnote in the CBIC text (table)
Structure 2(6)(i)-(v)Export of services — convertible foreign exchange receipt 2(6)(i)-(v)Export of services — RBI-permitted Indian-rupee receipt
Source
Law text	CBIC tax information portal, served on 12 August 2021^[1]
Questions reviewed	Prashant Prakash, 22 September 2026

Text

The text below is these clauses of the section as served by the CBIC tax information portal on 12 August 2021, with the portal's own amendment footnote markers (shown as small numerals before a bracket) and its footnotes.^[1] The Act as published in the Gazette of India is the legal source.

Clause 2(6), verbatim (show)

(6) "export of services" means the supply of any service when,-

(i) the supplier of service is located in India;

(ii) the recipient of service is located outside India;

(iii) the place of supply of service is outside India;

(iv) the payment for such service has been received by the supplier of service in convertible foreign exchange ¹[or in Indian rupees wherever permitted by the Reserve Bank of India]; and

(v) the supplier of service and the recipient of service are not merely establishments of a distinct person in accordance with Explanation 1 in section 8;

1. Inserted by s. 2 of the Integrated Goods and Services Tax (Amendment) Act, 2018 (No. 32 of 2018) - Brought into force w.e.f. 01st February, 2019.

2(6)export of services

"export of services" means the supply of any service when,- (i) the supplier of service is located in India; (ii) the recipient of service is located outside India; (iii) the place of supply of service is outside India; (iv) the payment for such service has been received by the supplier of service in convertible foreign exchange or in Indian rupees wherever permitted by the Reserve Bank of India; and (v) the supplier of service and the recipient of service are not merely establishments of a distinct person in accordance with Explanation 1 in section 8;Section 2(6)

The supplier-location, recipient-location and place-of-supply conditions must all be met. Payment must be received by the supplier in convertible foreign exchange or Indian rupees wherever RBI permits. The parties must not be merely establishments of a distinct person under Explanation 1 to section 8.

Questions to answer on the file

Questions a reviewer answers from the engagement file, grouped by the part of the section they come from. They describe what the section asks; they do not decide it.

Export of services — convertible foreign exchange receipt 2(6)(i)-(v)

Questions to answer on the file11 questions

Is the thing supplied a service?
Is the independently established supplier location outside India?
Is the independently established recipient location outside India?
Is the independently established place of supply outside India?
Has payment for the service been received?
Was the payment received by the supplier of that service?
Is the received payment in convertible foreign exchange?
Do the supplier and recipient belong to the same person?
If so: is the supplier an establishment of that person for section 8?
If question 8 is answered yes: is the recipient an establishment of that person for section 8?
Are the supplier and recipient merely the same person’s India and overseas establishments?

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Export of services — RBI-permitted Indian-rupee receipt 2(6)(i)-(v)

Questions to answer on the file12 questions

Is the thing supplied a service?
Is the independently established supplier location outside India?
Is the independently established recipient location outside India?
Is the independently established place of supply outside India?
Has payment for the service been received?
Was the payment received by the supplier of that service?
Is the received payment in Indian rupees?
If so: does the applicable Reserve Bank permission cover this rupee receipt?
Do the supplier and recipient belong to the same person?
If so: is the supplier an establishment of that person for section 8?
If question 9 is answered yes: is the recipient an establishment of that person for section 8?
Are the supplier and recipient merely the same person’s India and overseas establishments?

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Amendment history

The CBIC text carries 1 footnote. The table gives each in the source's own terms. Effective dates are as the footnotes state them.^[1]

Amendments to section 2 as footnoted in the CBIC text
Note	Change
1	Inserted by s. 2 of the Integrated Goods and Services Tax (Amendment) Act, 2018 (No. 32 of 2018) - Brought into force w.e.f. 01st February, 2019.^[2]

References

Central Board of Indirect Taxes and Customs. "Section 2. Export of services — RBI-permitted Indian-rupee receipt". Integrated Goods and Services Tax Act, 2017, CBIC tax information portal, with amendment footnotes 1 to 1. Retrieved 12 August 2021.
The Integrated Goods and Services Tax (Amendment) Act, 2018. Cited in CBIC footnote 1.

External links

IGST Act, 2017, Section 2 on the CBIC tax information portal