GSTR-9 Table 5: Supplies on Which Tax Is Not Payable

GSTR explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.

There is a fact behind this table that explains its whole reporting history: there is no nil rate schedule for goods at all, and only three services are nil-rated. That is why the form let exempt and nil-rated be reported together for six years — and why non-GST supply could never be merged with them.

Table 5 captures "details of outward supplies made during the financial year on which tax is not payable": 5A exports without payment of tax, 5B SEZ supplies without payment of tax, 5C supplies on which the recipient pays under reverse charge, 5C1 supplies on which the e-commerce operator pays under section 9(5) — inserted by Notification No. 12/2024-CT dated 10.07.2024 — 5D exempted, 5E nil rated, 5F non-GST supply (includes 'no supply'), and 5G the sub-total.

Why the reporting options were what they were

For FY 2017-18 to 2020-21, registered persons could "either separately report their supplies as exempted, nil rated, and non-GST supply or report consolidated information for all these three heads in the exempted row only."

For FY 2021-22 and 2022-23, the option narrowed: "either separately report their supplies as exempted supply and nil rated supply or report consolidated information for these two heads in the exempted row only. However, Non-GST Supplies are to be mandatorily reported in Table 5F."

The legal reason for merging the first two:

"Section 2(47) defines exempt supply as the supply of any goods or services or both which attract nil rate of tax or which may be wholly exempt from tax under section 11, or under section 6 of the IGST Act, and includes non-taxable supply. This definition entails that exempt supply is a wide term and includes nil rated supply and non-taxable supply. There is no clear distinction between exempted and nil-rated supply in law because the lawmakers have not defined nil-rated supply."

And the practical reason:

"Notification No. 01/2017-CT(Rate) contains 6 Schedules with different rates of taxes, and there is no Schedule levying tax nil rate on goods. However, in case of service, only three services related to the lease of land and agriculture etc. are notified at 'nil' rate."

The three nil-rated services:

So Table 5E is, for most taxpayers, empty. Anything a business calls "nil rated" is almost certainly exempt under section 11, and belongs in 5D.

Why non-GST could never be merged

"Non-GST supply is not defined anywhere in the GST law. However, non-taxable supply is defined under section 2(78)… which means the supply of goods or services or both which is not leviable to tax under the CGST Act or the IGST Act. It can be concluded that non-GST supplies are used interchangeably with non-taxable supplies."

And it still affects credit: "Although these supplies are reported as non-taxable supplies, the value of such supplies shall also be considered for the reversal of input tax credit in terms of section 17(2) read with rules 42 and 43."

With two carve-outs from section 17(3). An Explanation inserted by the CGST (Amendment) Act, 2018 from 01.02.2019 provides that "'value of exempt supply' shall not include the value of activities or transactions specified in Schedule III, except those specified in paragraph 5", and the Finance Act, 2023, effective 01.10.2023, added a further exception for "such activities or transactions as may be prescribed in respect of clause (a) of paragraph 8."

Details come from Table 8 of GSTR-1.

5C and the reversal that follows it

Table 5C covers "supplies on which tax is to be paid by the recipient on reverse charge basis" — notified under Notifications No. 04/2017-CT(R), 04/2017-IT(R), 13/2017-CT(R) and 10/2017-IT(R). "a person who is making the supply of goods or services on which tax is to be paid by the recipient shall not collect tax from him." From Table 4B of GSTR-1.

And the Guide flags a trap that costs credit:

"as per section 17(3), the value of exempt supply includes supplies on which a recipient is liable to pay tax on a reverse charge basis. Although… shown separately under Table 5C… and not as exempt supply in Table 5D, the turnover declared in this particular table should be considered for reversal under section 17(2) read with rules 42 and 43."

So Table 5C is presentationally outside the exempt rows but substantively inside them for rule 42. A GTA or a licensor of copyright with large RCM outward turnover must reverse common credit on it, even though nothing in Table 5D reflects that turnover.

Table 5C1 is the supplier's mirror of Table 4G1 — "Supplies on which tax is to be paid by e-commerce operators as per section 9(5) ", from Tables 14(b) and 14A(b) of GSTR-1. Section 9(5) →

5A and 5B: zero-rated without payment

Zero-rated supply under section 2(23) read with section 16 of the IGST Act means exports and supplies to an SEZ developer or unit, with two routes — under bond or LUT claiming refund of ITC, or on payment of IGST claiming refund of the tax. 5A and 5B take the first route only; the second goes to Tables 4C and 4D.

The LUT rules that decide eligibility:

Who may furnish an LUT. Notification No. 37/2017-CT dated 04.10.2017 extended it to all exporters except those "prosecuted for any offence… and the amount of tax evaded in such cases exceeds ₹250 lakhs", and those who fail to pay tax and interest under rule 96A(1) — for whom "the facility of export without payment shall be withdrawn and will be restored after payment."

Validity. Circular No. 08/08/2017-GST dated 04.10.2017: the LUT "shall be valid for the whole financial year in which it is tendered." But where goods are not exported in time and the tax is not paid "within 15 days after expiry of three months" — or, for services, "15 days after the expiry of one year" without receipt in convertible foreign exchange — "the facility of export under LUT would be deemed to have been withdrawn", restored on subsequent payment. In the interval, exports must be "either on payment of the applicable integrated tax or under bond with a bank guarantee."

Late LUT is condonable. Circular No. 37/11/2018-GST dated 15.03.2018: "the substantive benefits of zero-rating may not be denied where it has been established that exports… have been made. The delay in furnishing LUT in such cases may be condoned and facilities for export under LUT may be allowed on ex-post facto basis. Accordingly, such supplies shall also be reported in Table 5A or 5B."

SEZ supplies need an endorsement. Circular No. 48/22/2018-GST dated 14.06.2018: supplies to an SEZ are zero-rated and refundable "only if such supplies have been received by the SEZ developer or SEZ unit for authorized operations. An endorsement to this effect shall have to be issued by the specified officer of the Zone."

From Table 6A of GSTR-1 for 5A, and Table 6B for 5B.

Key takeaways

• Table 5 covers exports and SEZ supplies without payment of tax, recipient-RCM supplies, section 9(5) supplies, exempt, nil-rated and non-GST supplies.
• Exempt and nil-rated could be merged because section 2(47) makes exempt supply the wider term and nil-rated is undefined.
• There is no nil rate schedule for goods, and only three nil-rated services — two under heading 9972 and one under 9986.
• Non-GST supply was always reported separately, and its value still triggers rule 42/43 reversal.
• Section 17(3) excludes Schedule III items other than paragraph 5, and, from 01.10.2023, prescribed paragraph 8(a) transactions.
• Table 5C turnover must be counted for rule 42/43 reversal even though it sits outside Table 5D.
• Table 5C1 is the supplier's mirror of the operator's Table 4G1.
• The LUT is valid for the financial year; it is deemed withdrawn on failure to pay under rule 96A(1), and restored on payment.
• A late LUT may be condoned ex post facto where exports are established — Circular No. 37/11/2018; SEZ supplies need the specified officer's endorsement.

Read next

• GSTR-9 Table 5N: Total Turnover, and What It Excludes
• GSTR-9 Table 4: Outward Supplies on Which Tax Is Payable
• GSTR-9 Table 7: ITC Reversed and Ineligible ITC

Disclaimer: Positions stated as on 5 September 2026, based on sections 2(23) and 16 of the IGST Act, 2017, sections 2(47), 2(78), 11 and 17 of the CGST Act, 2017, rule 96A of the CGST Rules, 2017, Notifications No. 01/2017 and 11/2017-Central Tax (Rate), 37/2017 and 12/2024-Central Tax, and Circulars No. 08/08/2017-GST, 37/11/2018-GST and 48/22/2018-GST, as reproduced in the ICAI Technical Guide on GST Annual Return (Form GSTR-9).