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Indian GST-registered manufacturers exporting goods should maintain one connected file for each contract or order. It should contain the executed agreement and amendments, production and stock evidence, purchase invoices and input-tax-credit support, the correctly endorsed export tax invoice, customs and transport documents, GST returns, and the records supporting the chosen export and refund route. Reconcile the buyer, product description, quantity, value, destination, invoice number and date, and shipping-bill details across every part of the file.
This is a practical baseline for direct exports of goods from India. Product-specific restrictions, destination rules, regulated commodities, special export incentives and sales to merchant exporters can require additional records.
Build one transaction file, not separate piles of documents
For audit, refund and customs questions, the useful unit is the complete transaction file: one contract or purchase order linked to its production batch, stock movement, tax invoice, shipping bill, transport proof, GST reporting and refund or LUT evidence. An index should let a reviewer move from the commercial terms to the physical goods and then to the tax and customs trail without relying on informal explanations.
| File section | What to retain | What it proves |
|---|---|---|
| Commercial agreement | Signed export contract or accepted purchase order, specifications, price schedules, Incoterms or delivery terms where agreed, amendments and approved correspondence | What the parties agreed to ship, at what price, quantity, quality and destination |
| GST books and manufacturing trail | Production records, raw-material and input consumption, stock ledger, inward and outward supplies, ITC records, tax payable and paid, invoice registers, credit/debit notes and relevant vouchers | How inputs became the exported finished goods and how the transaction entered the accounts |
| Export tax invoice | Final invoice, packing details and prescribed export particulars, including the correct GST endorsement | The taxable supply reported to GST and matched to customs |
| Customs and transport | Shipping bill or bill of export, commercial invoice-cum-packing list (or separate documents), bill of lading, airway bill, lorry receipt, railway receipt or postal receipt, as applicable | That the declared goods left India under the corresponding invoice |
| Returns and route evidence | GSTR-1 export data, GSTR-3B or applicable return, IGST-payment evidence or LUT/bond and filing proof, refund statements and customs export confirmation | That the export was reported and the claimed tax treatment is supported |
Keep electronic copies with stable file names and preserve portal acknowledgements, reference numbers and downloaded documents. A spreadsheet or document index can record the contract number, invoice number, shipping-bill number, return period, LUT or refund reference and storage location.
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GST books, inputs, production and stock records
Statutory accounting categories
Section 35 of the Central Goods and Services Tax Act requires registered persons to keep records of production or manufacture, inward and outward supplies, stock, input tax credit availed, and tax payable and paid. The accounts-and-records rules add supporting documents such as invoices, delivery challans, credit and debit notes, vouchers and e-way bills where applicable. Maintain these records even when the immediate transaction is zero-rated; zero-rating does not remove the obligation to prove the underlying supply.
Manufacturing and quantitative linkage
For every export batch, retain a quantitative trail from raw materials and other inputs to finished goods. Monthly production accounts should show the quantities of raw materials or services used, quantities manufactured, and waste or by-products. The stock account should show opening balance, receipts, supplies, losses or write-offs and closing balance. This lets the business explain why the quantity on the export invoice agrees with the production report and the stock ledger.
Where several batches feed one shipment, record the batch or lot references and the allocation method. Where a shipment contains goods from different production periods, preserve the issue notes or warehouse records that explain the aggregation. The rules also require relevant supplier and buyer details, the premises where goods are held, advance accounts and invoice registers. The CBIC accounts and records rules describe preservation of these records and electronic backup capable of restoration after accidental or natural loss.
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Input-tax-credit support
Keep supplier tax invoices and other eligible documents supporting every input-tax-credit entry connected with the goods. Include purchase orders, goods-receipt records, inward registers and payment or adjustment records where they help establish receipt and use. If credit is reversed, reclaimed or apportioned, retain the calculation and accounting entry. A refund reviewer should be able to trace a material purchase from the supplier invoice to the input ledger and then to the exported output or the relevant accumulated-credit computation.
Contract and purchase-order records
What belongs in the agreement file
Retain the signed export contract or accepted purchase order, technical specifications, drawings or quality schedules, agreed price and currency, quantity tolerances, delivery dates, destination, packaging instructions, inspection terms, payment terms and any agreed delivery rule. Keep every amendment, change order and written approval that changes goods, quantities, prices, delivery points or destination. Preserve correspondence that resolves an ambiguity rather than relying on a later oral understanding.
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The reviewed sources do not establish one universal GST-mandated contract checklist for every exporter. These documents are practical commercial evidence, but they do not replace tax invoices, returns or customs documents.
Why the contract must match the customs declaration
Customs declarations of value, quality and description certify conformity with the export contract entered into with the buyer or consignee. Use the agreement and amendments to support the description and value declared on the shipping bill. If the buyer changes a specification after production, retain the approval and ensure the invoice, packing list, shipping bill and records reflect the final agreed terms. A contract cannot cure an incorrect invoice or missing customs evidence; it is the explanation for the transaction, not a substitute for statutory documents.
Export tax invoice: wording and particulars
Use the export invoice requirements in the CBIC tax-invoice rules. The invoice must carry the endorsement that matches the route:
SUPPLY MEANT FOR EXPORT ON PAYMENT OF IGSTSUPPLY MEANT FOR EXPORT UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF IGST
Retain the final signed or digitally issued invoice and the version transmitted to the buyer, customs broker and carrier. The export invoice rule requires the recipient’s name and address, delivery address, country of destination and the number and date of the application for removal of goods for export in place of the ordinary recipient GSTIN detail specified in the rule. Ensure the invoice number and date are identical wherever they are entered in GSTR-1, the shipping bill and refund statements.
Keep credit notes, debit notes, revised invoices and evidence of how any post-export price adjustment was handled. If a change affects customs value or the refund calculation, preserve the related correspondence and amended declaration.
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Customs and transport documents for goods exports
Ordinary document set
DGFT’s Foreign Trade Policy Chapter 2 identifies the ordinary goods-export set as:
- A transport document: bill of lading, airway bill, lorry receipt, railway receipt or postal receipt, as applicable.
- A commercial invoice-cum-packing list, or separate commercial invoice and packing list.
- A shipping bill, bill of export or postal bill of export.
Keep the issued document, amendments and electronic references. Link the container, package or consignment identifiers to the invoice and packing list so that a reviewer can establish that the transported goods are the invoiced goods.
When more documents are required
The three-item set is not universal. DGFT may require additional documents for restricted goods, policy conditions, no-objection requirements or product-specific compliance, and authorities may ask for further information in an individual case. Check the current product classification, export policy, destination requirements and any licensing or certificate conditions before dispatch. Preserve licences, certificates of origin, inspection or testing certificates, health or safety documents and permissions when the product or destination requires them.
Choose the GST export route and retain its evidence
CBIC describes two broad routes. An exporter may pay IGST on export and seek a refund, or export under a bond or letter of undertaking (LUT) without payment of IGST. Exports under LUT or bond may support a refund of eligible accumulated input tax credit under the applicable rules. The appropriate route depends on current law, eligibility, working-capital position and the transaction facts; neither route is universally preferable.
| Route | Tax treatment at export | Core evidence to retain | Refund mechanism |
|---|---|---|---|
| IGST-paid export | IGST is paid on the export invoice | Invoice with IGST endorsement, shipping bill, export manifest or report confirmation, GSTR-1 export details, the applicable return and payment records | Refund of IGST after the customs and GST data match the statutory conditions |
| LUT or bond | Goods are exported without payment of IGST under the applicable LUT or bond | Valid LUT or bond and filing acknowledgement, endorsed invoices, shipping and transport documents, GSTR-1 and return data, and evidence of the export | Refund of eligible accumulated ITC under the applicable refund rules and portal procedure |
Evidence for an IGST refund
Under the CBIC GST refund rules, retain the shipping bill, corresponding export invoice and evidence that the export manifest or report was filed. Keep proof that the required GSTR-3 or GSTR-3B return condition was met, as applicable to the period and procedure. Rule 96 treats the shipping bill as the refund application when its conditions are met and links GSTR-1 export-invoice data with Customs confirmation that the goods were exported.
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Also retain the statement or electronic record linking each shipping-bill or bill-of-export number and date with the matching export invoice number and date. Investigate mismatches before claiming or following up a refund; a correct physical export does not by itself repair inconsistent invoice data.
Evidence for the LUT or bond route
Keep the LUT or bond, its filing acknowledgement and validity details, the invoices issued under it, return data and all documents supporting an accumulated-ITC refund. Because individual claim requirements and portal instructions can change, verify the current rule and filing workflow for the relevant period. Retain the calculation of eligible credit, exclusions and the invoice-level statement submitted with the claim.
Reconcile the file before dispatch and again before filing
Use a two-stage control rather than waiting for a notice or refund failure.
- Freeze the commercial terms: identify the executed contract or purchase order, latest amendment, buyer, destination, agreed quantity, price, currency and delivery terms.
- Match production and stock: record the batch or lot, inputs consumed, output quantity, waste or by-products, stock issue and packing quantities.
- Prepare the invoice: verify the legal name and addresses, country of destination, goods description, quantity, value, invoice number and date, and the correct IGST or LUT/bond endorsement.
- Prepare customs documents: ensure the commercial invoice, packing list and shipping bill carry matching descriptions, quantities, values and invoice references; attach any product-specific permission or certificate.
- Capture transport proof: file the bill of lading, airway bill, lorry receipt, railway receipt or postal receipt and link its consignment identifiers to the shipment.
- Record GST reporting: save the GSTR-1 export entry, the relevant GSTR-3B or other return, tax payment or LUT details and portal acknowledgements.
- Complete the refund file: for IGST-paid exports, save customs export confirmation and manifest evidence; for LUT or bond exports, save the eligible-ITC calculation and refund statement.
- Perform an independent check: compare buyer, description, quantity, value, destination, invoice number/date and shipping-bill number/date across the agreement, invoice, customs record and return data. Document corrections and retain the original and revised versions where changes occurred.
How long to retain GST and export records
Section 36 of the CGST Act states that a registered person must retain books and records until 72 months from the due date of furnishing the annual return for the year to which the records relate. The statutory wording is: “Every registered person required to keep and maintain books of account or other records in accordance with the provisions of sub-section (1) of section 35 shall retain them until the expiry of seventy-two months from the due date of furnishing of annual return for the year pertaining to such accounts and records.”
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If the records relate to an appeal, revision or other proceeding before an authority, tribunal or court, or to an investigation for an offence under Chapter XIX, retain them for one year after final disposal or for the normal 72-month period, whichever is later. Calculate the date using the applicable annual-return due date and the current consolidated law; do not delete a file merely because the shipment is complete.
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Keep records at the registered places of business as required by the rules. For electronic records, maintain backups in a form that can be restored within a reasonable period after accidental or natural loss. Test restoration periodically, restrict editing of final documents and preserve an audit trail for replacements or corrections.
Cases that need a transaction-specific check
Manufacturer selling to a merchant exporter
A manufacturer’s domestic supply to a merchant exporter is not itself an export merely because the merchant later exports the goods. Keep the domestic tax invoice, delivery and payment records for that supply. The merchant exporter’s shipping bill, export invoice and zero-rated treatment belong to the merchant’s export file. Do not use the merchant’s export documents as a substitute for the manufacturer’s GST records.
Regulated goods and special schemes
Goods subject to restrictions, licences, quotas, technical standards, health controls or destination-specific rules may require additional certificates and approvals. Export incentive schemes, bonded manufacturing arrangements and other special procedures can impose their own records and retention conditions. Confirm the current DGFT, Customs, sector regulator and destination requirements before treating the baseline checklist as complete.
Direct goods exports only
This checklist concerns exports of physical goods. Services exports have different place-of-supply, invoice, evidence and refund considerations and should not be folded into this file without a separate review.
Quick Recap
Final pre-closure checklist
- Executed contract or accepted order and every amendment are present.
- Production, input-consumption, waste, stock and dispatch quantities reconcile to the shipment.
- Supplier invoices and ITC support are filed.
- Export invoice carries the correct payment-of-IGST or LUT/bond endorsement and prescribed destination particulars.
- Commercial invoice, packing list, shipping bill and transport document refer to the same goods and invoice.
- Product-specific licences, certificates and no-objection documents are included where required.
- GSTR-1, the relevant return, IGST payment or LUT evidence and refund records are indexed.
- Retention and backup dates are recorded, with a hold applied for any appeal, investigation or other proceeding.
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