'GST payable on composition fees and import licensing fees paid to JDGFT'

If the ownership of the goods is with the manufacturer, the beneficial owner will be treated as the merchant exporter

Q. Are we required to pay GST on fees for import licence and composition fees for regularisation of defaults that we pay to JDGFT?

In my opinion, “Yes”, if you are a business entity and the fee is more than Rs 5,000. The import licence fee that you pay is for processing your application that cannot be refunded even if your application is rejected. So, it is a service provided to a business entity. The composition fee is for the service of tolerating an act such as non-fulfilment of export obligation. 

Q. We operate an ICD (not CFS). Many exporters