Section 147 lets certain domestic supplies be treated like exports so that tax on them can be refunded.
Key points
- Under section 147 of the CGST Act, 2017 the Government may notify supplies of goods as deemed exports, where the goods do not leave India and payment is received in Indian rupees or convertible foreign exchange, if the goods are manufactured in India.
- Notification 48/2017-Central Tax notifies supplies against advance authorisation, capital goods against EPCG authorisation, supplies to export-oriented units, and gold supplied by banks against advance authorisation.
The provisions
147Deemed exports
Statutory text
The Government may, on the recommendations of the Council, notify certain supplies of goods as deemed exports, where goods supplied do not leave India, and payment for such supplies is received either in Indian rupees or in convertible foreign exchange, if such goods are manufactured in India.
*Enforced w.e.f. 1st July, 2017.
- Notification 48/2017-Central Tax
Statutory text as published on the CBIC tax information portal, as on 03.10.2026; the numbered notes record each amendment. Official source
Common questions
- What are deemed exports under GST?
- Domestic supplies of goods notified under section 147 of the CGST Act — such as supplies to EOUs and against advance authorisation — on which tax can be refunded.
Commentary and case notes checked against the judgments and CBIC sources on 04.10.2026.
What it means
Deemed export supplies are taxable; the supplier or recipient claims refund of the tax under section 54 and Rule 89, with the relevant date being the date of the return relating to them.