
Exporters have several options for tax recovery and export incentives. GST refund for exporters, Duty Drawback, and RoSCTL have different legal regimes and are subject to different eligibility criteria. It is essential for exporters to understand the operation of each mechanism as well as how they work together to determine the opportunities offered for their export products.
Each mechanism recovers a genuinely different cost component, and understanding this separation is the first step to claiming all three correctly.
The introduction of GST 2.0 rate rationalisation on 22nd September 2025 brought about a significant change in the workings of taxes on the textile industry, and all the exporters' refund claims considered after that date are being calculated in this new structure.
This last row matters more than it looks; it's the reason the inverted duty structure in textiles under GST hasn't fully disappeared even after the rate correction.
Until September 2025, the classic inversion used to be applied throughout the fibre to yarn to fabric to garments segment, with rates not matching at almost every step of the process.
GST rates for specified textile products were rationalised from September 2025. The applicable rate should be checked product-wise against the relevant HSN and notification.
Where eligible inputs attract a higher GST rate than the corresponding outward supplies, an inverted duty structure may arise. Refund eligibility must be determined with reference to Section 54(3), Rule 89(5), the relevant HSNs and applicable conditions.
Eligible unutilised ITC arising from an inverted duty structure may be refundable under Section 54(3) read with Rule 89(5), subject to the applicable conditions and exclusions.
Like any export, textile shipments qualify as zero-rated supply under Section 16 of the IGST Act, regardless of the domestic GST rate that would otherwise apply.
Exporters file a Letter of Undertaking (LUT) for textile export through Form GST RFD-11 exactly as any other exporter, valid for the financial year.
RoSCTL (Rebate of State and Central Taxes and Levies), operational since 7 March 2019, exists specifically to refund the taxes GST never touches at all: VAT on captive fuel, electricity duty, mandi tax on raw cotton, and similar embedded state and central levies.
Eligible RoSCTL benefits are issued electronically as duty credit scrips/e-scrips in accordance with the applicable scheme and customs procedures.
RoSCTL coverage is prescribed for eligible products falling within the tariff items/categories covered by the prevailing RoSCTL scheme. Eligibility should be checked against the applicable tariff classification and notification.
Standalone fabric exports should be checked against the prevailing RoDTEP schedule and applicable tariff-item conditions; they should not automatically be described as RoDTEP-eligible
Yes, on the same export, there may be two components of tax: one by Duty Drawback (customs duty on inputs) and the other by GST refund (unutilised ITC), which are different, and the exporter must ensure that the same tax/duty component is not claimed twice and that all applicable restrictions and conditions are satisfied.
Duty Drawback for exporters of textiles is subject to the notified schedule of rates of drawback known as “All Industry Rate” (AIR), which varies by HS code, like the other Drawback schemes.
Check the latest rules and regulations before publishing the specific two-month period of Customs or Drawback.
An exporter of garments exports apparel valued at ₹50,00,000 (FOB) under Chapter 62 with values exceeding ₹2,500 per garment, which falls in the 18% domestic GST slab, but the export of apparel remains zero-rated.
Exporters should separately evaluate GST refund, Duty Drawback and applicable export incentives to identify the benefits available for their specific exports.
ICEGATE shipping bill GST refund tracking is where most textile exporters first notice a claim has stalled, usually traced back to a shipping bill-to-GSTR-1 mismatch, an unlinked AD Code, or a bank validation failure at the PFMS stage.
Checking both the GST portal's refund status and ICEGATE's own tracking module, rather than just one, catches issues faster.
Exporters can also use a GST Refund Report Card to review potential refund-related issues.
Do not publish this without a specific legal opinion/source. The GST treatment of transfer/sale of duty credit instruments should be separately examined.
GST refund, Duty Drawback and RoSCTL should be treated separately by the textile exporters, with independent eligibility requirements and processes. In order to claim a benefit, product classification, the applicable notifications, shipping-bill declarations, eligible ITC, and the nature of the export transaction all ought to be considered.
For exporters, a GST-wise reconciliation of shipping bills and applicable export incentives with GST data can help in the identification of the claims and minimize the chances of any documentation or classification-related problems.
1. Is it necessary to obtain separate registrations at DGFT and GST portal for an exporter to avail RoSCTL and GST refund?
No, both are different processes; only having an IEC and GSTIN is required. No separate registration is required for filing of RoSCTL in the shipping bill via ICEGATE, or for filing a GST refund in the GST portal via Form RFD-01.
2. Can a product with a made-up of over ₹2,500 be offered at 6.05% RoSCTL, even if it is subject to 18% domestic GST?
Yes, RoSCTL eligibility is based on HS chapter classification (Chapter 63 for made-ups) and not the GST slab the product attracts if sold in India, and complete export is considered zero-rated too.
3. What would be the consequences of a textile exporter applying for RoDTEP but not RoSCTL for a garment shipment?
As RoSCTL and RoDTEP are not interchangeable, a RoDTEP claim in error for those HS chapters that also require RoSCTL may normally have to be corrected with the department.
4. Is there a minimum export value required to claim RoSCTL on a shipment?
There is no minimum FOB value specified for its eligibility as a RoSCTL claim; however, for very low-value shipments, some documentation issues may apply, as in most other export incentive claims.
5. Can accumulated RoSCTL e-scrips be used to pay GST liability, or only customs duty?
RoSCTL e-scrips are specifically designed for customs duty payment or transfer/sale to another importer, and are not usable for settling GST liability, which follows its own separate payment and refund mechanisms.