In India, Goods and Services Tax (GST) is an exasperating activity, especially when it comes to the process of availing refunds. As an exporter or a startup that has surplus ITC or a taxpayer who has an inverted duty structure, it is important to know how the GST refund works to ensure you are not caught short of payment and are also compliant.
A GST refund refers to the return of excess tax paid by a taxpayer to the government. These may be as a result of various reasons as follows:
In the CGST Act, the regulation of the refund is by:
Section 54: Deals with the procedure and conditions of claiming GST refunds, such as time limit (usually within a Period of 2 years) and categories such as exports, inverted duty structure, and overpayments.
Section 55: Concerns itself with refunds to the specialised agencies, e.g., the United Nations, the embassies, and the multilateral financial institutions, which can make claims to tax refunds on taxation of the inward supplies.
Section 56: Gives potential issues regarding the interest to be paid by the government in case the refund has not been received within 60 days or has been delayed since receipt of a complete application.
The provisions provided in section 54 of the Central Goods and Services Tax (CGST) Act, 2017, deal with the refund of the tax paid under GST. It establishes different terms and processes of refund claim, the date applicable in determining the time of filing the refund claim, the type of taxes that are refundable, and the documents that should be submitted together with the application for a refund claim.
Under section 54 of the CGST Act, along with Rule 89 of the CGST Act 2017, businesses can claim the GST Refund of accumulated ITC in the following cases:
Not every taxpayer is eligible; many of them are under the GST regulations. A claim for refund may arise on account of the following situations:
(a) Export of goods or services
(b) Supplies to SEZ units and developers
(c) Supply of goods regarded as Deemed Exports
(d) Refund of taxes on purchases by UN or embassies under Section 55 of the CGST Act, 2017
(f) Refund of the accumulated Input Tax Credit on account of the inverted rate structure
(i) Tax paid in excess/by mistake
(k) Refund of tax paid in the wrong head under Section 77 of the CGST Act, 2017 & Section 19 of the IGST Act, 2017
Thus, practically every situation is covered. The GST law requires that every claim for refund be filed within 2 years from the relevant date
Your refund category will also change depending on the nature of your business and the kind of transaction that you are making.
These are the various categories of refunds under the GST regime as given below:
GST refund on inverted dut
Under the existence of Input tax and output tax, the accumulation of Input Tax Credit (ITC) occurs when the tax rate on the input (purchases) is higher than that of taxes on output supplies. This becomes what is called the inverted duty structure. Under Section 54(3) of the CGST Act, a taxpayer is allowed to get a refund of the unused ITC in these instances.
The application for refund should be made by filing the application for refund form, GST RFD-01, following the filing of relevant GSTR-1 and GSTR-3B returns of the tax period. The supporting records, such as statement of invoices, inward and outward supply particulars, declarations as per Rule 89(5), are required. There are also prescribed conditions that should be satisfied by the taxpayer, that are mentioned in Rule 89(2)(h) and Rule 89(5).
Note: ITC refund cannot be made in regard to input services or capital goods during the inverted duty structure.
The portal manages this process centrally with the GST portal, and the primary document to be submitted is RFD-01.
Step-by-Step Process:
1. Pre-application: Matching GSTR-3B and GSTR-1
2. Submit RFD‑01 online
3. Get ARN (Application Reference Number)
4.RFD‑02: Acknowledgment
5.RFD‑03: If deficiencies are found
6.RFD‑06: Final refund sanction order
Invoices and debit/credit notes related to the refund claim
A GST officer issues a GST Refund Deficiency Memo (Form RFD-03) in case all conditions of a given refund application, as submitted in Form RFD-01, are deficient or incorrect. If a refund claim in Form RFD-01 is found deficient, the GST officer issues Form RFD-03 within 15 days under Rule 90(3). This memo takes the initial application as invalid and mandates that the taxpayer correct the mistakes and make another RFD-01 with a different ARN, which has to be within 2 years as initially set.
In case your refund request is incomplete:
In the circumstances where there is a claim to refund of taxes paid on export of goods or services, other than the refund of accumulated Input Tax Credit (ITC), up to a total provision of the refund claim, 90 per cent shall be provisionally sanctioned to the applicant within 7 days of the acknowledgment of the claim. This provision guarantees liquidity on a timely basis among the exporters with checks of compliance in the form of final scrutiny.
For GST refund RFD-06, the following points are to be considered:
i) Sum on refund/interest: Actual amount claimed by the applicant.
ii) Refund Sanctioned on Provisional Basis (Order No date): Enter details of any amount already refunded provisionally.
iii) Amount inadmissible to refund: Mention the amount not eligible for refund with reasons (multiple reasons allowed).
iv) Gross to pay (1-2-3): Difference of amounts in points (i), (ii), and (iii).
v) Refund adjusted against outstanding demand: If any demand exists, it’s adjusted against the refund (mention Demand Order No., date, Act, and period).
vi) Net Amount to be paid: Final sanctioned refund amount as per the order
There is an acknowledgment that comes under the scheme RFD-02, which is there on the common portal to the applicants. The application of self-assessment of the refund can be applied on the form GST RFD-01 of the common portal, whose acknowledgment will be auto-populated on the common portal.
The acknowledgment is auto-populated and includes:
Some GST refund scenarios require additional understanding:
Exporters who supply goods or services without payment of IGST under LUT are eligible to claim a refund of unutilized ITC. After filing GSTR-1 and GSTR-3B, the refund must be claimed through Form RFD-01. Ensure that invoices, shipping bills, EGM, and BRC/FIRC (for services) are correctly matched to avoid delays.
Exporters often face GST refund delays due to portal issues, document errors, or a lack of expert guidance. MyGSTRefund solves this with automated matching of invoices, shipping bills, and bank details, real-time ARN tracking, Refund calculator , ready RFD-09 responses, and tailored support for LUT, SEZ, and inverted duty refunds, ensuring faster, error-free claims.
GST Refund Helpline (MyGSTRefund): +91 92891 92891
Check: www.mygstrefund.com
1. What is the time limit for taking a refund?
The time limit for the individual claiming a refund is required to apply before the expiry of two years from the “relevant date” as given in the Explanation to section 54 of the CGST/TSGST Act.
2. Can I track the status of the Refund Pre-Application Form after its submission?
Unfortunately , there is no tracking functionality available after the Refund Pre-Application Form is submitted on the GST Portal.
3. Is it possible to trace a refund by ARN?
Yes, it can be checked using the status checker of the GST portal or MyGSTRefund
dashboard.
4. What if my refund is under ₹1,000?
No refund shall be granted if the amount is less than Rs 1000/-. [Sec. 54 (14) of the CGST/TSGST Act].