GST Refund Claims

The CGST Act recognises refund in several scenarios:

• Export of goods or services on payment of IGST — refund of the IGST paid.
• Export of goods or services under LUT (without IGST payment) — refund of accumulated ITC.
• SEZ supplies — same two routes (with-IGST or under-LUT).
• Inverted duty structure — where input GST rate exceeds output GST rate (e.g., textiles, fertilisers, certain processed food). Refund of accumulated ITC.
• Excess balance in cash ledger — surplus deposits that haven’t been utilised against tax payable.
• Refund of tax paid on intra-state supply later held to be inter-state (or vice versa).
• Provisional refund — 90% of zero-rated supply refund within 7 days of acknowledgement.

The relevant references:

• Section 54 of the CGST Act — refund framework, time limit (2 years from relevant date).
• Rule 89, 90, 91, 92, 93, 94, 95, 96 of the CGST Rules — procedural rules for each refund category.
• Form RFD-01 (online application), RFD-02 (acknowledgement), RFD-04 (provisional), RFD-06 (final).
• Notification 49/2017-CT and subsequent amendments — LUT, bond, conditions.
• CBIC Master Circular 125/44/2019-GST — consolidated procedural guidance.

• GSTIN, period for which refund is claimed.
• For exports of services: FIRC / BRC issued by AD bank.
• For exports of goods: shipping bills, EGM, export invoices.
• For SEZ supplies: SEZ endorsement on invoice.
• Statement-3 / Statement-1A / Statement-2 (as applicable).
• GSTR-1, GSTR-3B, GSTR-2B for the period.
• For inverted duty: HSN-wise output and input rate analysis.
• LUT acknowledgement (for under-LUT exports).

What is the time limit for filing a refund claim?

Two years from the relevant date (Section 54). Relevant date varies by refund type — date of FIRC for service exports, date of shipping bill for goods exports.

Can refund be claimed if the LUT was not filed for the year?

Without LUT, exports must be made on IGST payment, and the IGST paid is the refund (different mechanics). Without LUT and without IGST payment, the export is non-compliant and the refund route closes.

Does the refund attract interest if delayed?

Yes. If refund is not paid within 60 days of complete filing, interest under Section 56 at 6% applies. We track this and claim interest separately if denied.

What’s the GST 2.0 impact on inverted-duty refund?

Several sectors moved from 5% / 12% / 18% / 28% to 5% / 18% / 40% from 22 September 2025. Some inverted positions disappeared, new ones emerged. We re-run the assessment annually and at each rate-change event.