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GST Refund Services
GST Refund is the statutory right of a registered taxpayer under Section 54 of the CGST Act, 2017 read with Rules 89 to 96A of the CGST Rules to recover unutilised input tax credit and tax paid to the Government in a range of specific situations — exports of goods and services under LUT, exports on payment of IGST, supplies to SEZ units and developers, inverted duty structure, deemed exports, excess balance in the electronic cash ledger, refund of tax paid in excess or under the wrong head, and refund on finalisation of provisional assessment. Refunds are one of the most working-capital-sensitive compliances under GST — delays and rejections can directly strangle cash flow for exporters and manufacturers.
The refund framework is procedural and unforgiving. Applications are filed online in Form GST RFD-01, supported by detailed statements (Statement 1A, 2, 3, 4, 5A, etc.) that vary by refund type, and are subject to a strict two-year limitation from the "relevant date" under Section 54(1). The officer can issue deficiency memos in Form RFD-03, provisional refund orders in Form RFD-04, final sanction / rejection in Form RFD-06, payment orders in Form RFD-05, and show cause notices in Form RFD-08 — with the taxpayer responding through Form RFD-09. Each stage has defined timelines, and any slip at the documentation, reconciliation, or legal-language stage can cost the refund entirely.
We offer end-to-end GST Refund Services — from identifying eligible refund categories, preparing refund computations and statements, reconciling data with GSTR-1, GSTR-3B, GSTR-2B, and ICEGATE / shipping bills, filing RFD-01 on the GST portal, responding to deficiency memos and show cause notices, following up with the jurisdictional officer, and pursuing recovery of interest on delayed refunds under Section 56 — so every rupee of legitimate refund is recovered quickly, cleanly, and with a complete documentary defence.
2 Years
Limitation from relevant date
RFD-01
Primary refund application
60 Days
Refund processing timeline
6% p.a.
Interest on delayed refunds
Laws & Frameworks We Work Under
CGST Act – Sec 54 to 58
CGST Rules – Rule 89 to 96A
IGST Act – Sec 16 (Zero-rated)
Form RFD-01 / 03 / 06
Form RFD-04 / 05
Form RFD-08 / 09
Section 56 – Interest
Rule 96 / 96A (Exports)
Major Categories of GST Refunds We Handle
Exports – LUT
Unutilised ITC on Exports Under LUT
Refund of accumulated input tax credit on zero-rated exports of goods or services made without payment of IGST under LUT.
- Exports under Section 16 IGST
- Services exports to overseas
- Goods exports under LUT
- Refund of unutilised ITC
- Net ITC formula in Rule 89(4)
- Statement 2 / 3 / 3A
Exports – IGST
IGST Paid on Exports
Refund of IGST paid on export of goods — processed automatically through shipping bills and ICEGATE integration.
- Shipping bill = refund application
- ICEGATE & GSTN integration
- Auto-credit to bank
- Rule 96 alignment
- BRC / FIRC matching
- EGM & SB mismatch handling
SEZ
Supplies to SEZ
Refund of unutilised ITC or IGST paid on supplies of goods / services to SEZ units or developers.
- Endorsed invoice / tax paid proof
- LUT-based zero-rated supply
- SEZ officer endorsement
- Statement 4 / 5A
- SEZ developer vs unit
- Timing & limitation mapping
Inverted
Inverted Duty Structure
Refund of unutilised ITC where GST on inputs is higher than GST on output supplies.
- Rule 89(5) formula
- Max refund computation
- Impact on capital goods
- Notified ineligible categories
- Statement 1 / 1A
- Industry-specific nuances
Deemed Export
Deemed Exports
Refund of tax on specified supplies treated as deemed exports — to EOU, advance authorisation holders, etc.
- Supplier / recipient refund
- Undertaking & declarations
- Notification-based categories
- EOU / AA / EPCG linkage
- Statement 5B
- Documentary evidence pack
Cash & Excess
Excess Cash Ledger / Tax Paid
Refund of excess balance in the electronic cash ledger or tax paid under the wrong head.
- Excess cash ledger refund
- Tax paid in wrong head
- IGST / CGST / SGST / cess
- Tax paid more than due
- Provisional assessment refund
- Direct online processing
Stages of a GST Refund Application
RFD-01
Refund Application
Online refund application filed by the taxpayer on the GST portal with prescribed statements.
Filed
Online
RFD-02
Acknowledgement
System-generated acknowledgement issued once the officer finds the application prima facie complete.
Ack
15 Days
RFD-03
Deficiency Memo
Memo raising deficiencies in the application — taxpayer must re-file after addressing each point.
Deficiency
Re-file
RFD-04
Provisional Sanction
Provisional refund order sanctioning typically 90% of the claim for eligible exporters / zero-rated cases.
90%
Provisional
RFD-05
Payment Order
Payment advice through which the sanctioned refund is credited to the taxpayer's bank account.
PFMS
Bank Credit
RFD-06
Final Sanction / Rejection
Final order sanctioning or rejecting the refund application — forms the basis for appeal.
Final
Appealable
RFD-08
Show Cause Notice
Show cause notice issued by the officer proposing rejection of all or part of the refund claim.
SCN
Reply
RFD-09
Reply to SCN
Detailed, reasoned reply to RFD-08 with supporting documents to protect the refund claim.
Defence
Evidence
Our GST Refund Services
Eligibility Diagnostic
Identifying eligible refund categories — exports, SEZ, inverted, deemed exports, excess cash ledger, etc.
LUT Filing
Annual LUT (Letter of Undertaking) in Form RFD-11 so that exports can be made without IGST.
Refund Computation
Net ITC and refund computation under Rule 89(4) / 89(5) for LUT exports and inverted structure.
RFD-01 Filing
End-to-end preparation and filing of RFD-01 with correct statements (1A / 2 / 3 / 4 / 5A / 5B).
Shipping Bill IGST Refund
Support on Rule 96 IGST refund on exports through ICEGATE — resolving SB / EGM mismatches.
Deficiency Memo Response
Responding to RFD-03 memos with complete, re-filable applications and supporting evidence.
SCN & RFD-09 Defence
Drafting RFD-09 replies to RFD-08 SCNs with legal arguments, case law, and documentary support.
Interest on Delay & Appeals
Claiming interest under Section 56 on delayed refunds and appeal against wrongful rejection orders.
When You Need GST Refund Support
Regular Exporter
You export goods or services regularly and accumulate large unutilised ITC each month.
SEZ Supplier
You supply goods or services to SEZ units / developers and need refund of unutilised ITC or IGST.
Inverted Duty Business
Your inputs attract higher GST than your output supplies, leading to perpetual ITC accumulation.
EOU / AA / EPCG Supplier
You supply to EOU, advance authorisation, or EPCG license holders as deemed exports.
IGST Refund Stuck
Your Rule 96 IGST refund is blocked due to SB / EGM / GSTR-1 / 3B mismatches.
Excess Cash Ledger
Excess balance accumulated in electronic cash ledger or tax paid under the wrong head.
Refund Rejected
Refund application rejected via RFD-06 or SCN in RFD-08 needs a strong appeal or reply.
Interest on Delayed Refund
Refund was sanctioned beyond 60 days and interest under Section 56 is due but unclaimed.
Documents Needed for a GST Refund Claim
Transaction Data
- Sales / export invoices
- Shipping bills & EGM
- BRC / FIRC / IRM
- LUT / bond acknowledgement
- SEZ endorsed invoices
- E-way bills & transport proof
- Contracts with customers
ITC & Returns Data
- Purchase register
- GSTR-1 / 3B / 2B of period
- GSTR-9 / 9C (if available)
- ITC register & reversal log
- Net ITC / inverted computations
- Electronic cash / credit ledger
- DRC-03 / refund adjustments
Supporting & Legal
- CA / CMA certificate (as applicable)
- Declaration of no unjust enrichment
- Bank account details for refund
- Authorisation letter / POA
- PAN & KYC of authorised signatory
- Previous RFD orders, if any
- Prior appeal / writ orders
Our End-to-End GST Refund Approach
1
Eligibility Scan
Identifying eligible refund pools — LUT, IGST, SEZ, inverted, deemed exports, excess cash.
2
Reconciliation
Tying GSTR-1, GSTR-3B, GSTR-2B, ICEGATE, BRC / FIRC, and books for every refund period.
3
Computation & Filing
Preparing refund computations, statements, and filing RFD-01 on the GST portal.
4
Officer Follow-Up
Handling RFD-03 deficiency memos, RFD-08 SCNs, and personal hearings with the officer.
5
Refund & Interest
Tracking RFD-04 / 05 / 06 orders, bank credit, and claiming interest on any delay under Sec 56.
Why Choose Us for GST Refunds
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Deep expertise across refund types
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Strong LUT & export experience
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ICEGATE & SB mismatch expertise
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Robust Rule 89(4) / 89(5) workings
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SCN / RFD-08 defence capability
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Interest on delayed refunds
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Multi-GSTIN refund coordination
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Cash-flow focused delivery
FAQs on GST Refund Services
What are the main situations in which a GST refund can be claimed?
Section 54 of the CGST Act allows a taxpayer to claim refund in a range of specific situations — unutilised ITC on export of goods or services under LUT without payment of IGST; IGST paid on export of goods (processed automatically through shipping bills under Rule 96); supplies to SEZ units or developers; accumulated ITC due to an inverted duty structure; deemed exports (e.g. supplies to EOUs or advance authorisation holders); excess balance in the electronic cash ledger; tax paid under the wrong head; tax paid on supplies that did not take place; and refund arising from finalisation of provisional assessment or appellate orders. Each category has its own statements, limitation, and documentary requirements.
What is the time limit to apply for a GST refund?
Section 54(1) prescribes a two-year limitation period, calculated from the "relevant date" as defined in the Explanation to Section 54. The relevant date varies by refund type — for example, date of export (shipment) for exports of goods; date of payment / receipt of convertible foreign exchange for services; date of tax payment for excess tax; date of adjustment order for provisional assessment. Missing this two-year window can extinguish the refund claim, subject only to exceptional relief under writ jurisdiction. Our practice is to maintain a live refund pipeline and file well ahead of the limitation date.
What is the difference between LUT and IGST routes of exporting?
Under the LUT route, an exporter files a Letter of Undertaking in Form RFD-11 at the beginning of every financial year and exports goods or services without paying IGST — later claiming refund of the accumulated input tax credit under Rule 89(4). Under the IGST route, the exporter pays IGST on exports upfront and claims refund of the IGST paid — for goods exports, the shipping bill itself is treated as the refund application under Rule 96 and the refund is credited automatically via ICEGATE. LUT is typically preferred for cash-flow reasons, while the IGST route can be useful where ITC accumulation is limited.
What is the inverted duty structure refund?
Under Section 54(3)(ii) of the CGST Act read with Rule 89(5), where the rate of GST on inputs is higher than the rate on output supplies — known as an inverted duty structure — the registered person can claim refund of the unutilised ITC that accumulates as a result. The refund is computed using the formula in Rule 89(5), and credit on input services and capital goods is generally not eligible for inclusion in the refund pool. Sectors like textiles, fertilisers, some pharmaceuticals, and renewable energy frequently operate in inverted structures and depend heavily on this refund.
How long does a GST refund take to process?
The statutory timeline under Section 54(7) is 60 days from the date of receipt of a complete refund application. Within this window, provisional sanction of up to 90% can be granted under Rule 91 (through Form RFD-04), typically within 7 days of acknowledgement for eligible zero-rated cases. Final sanction or rejection is passed in Form RFD-06, followed by actual bank credit through Form RFD-05. If the timeline is not met, interest under Section 56 becomes payable. In practice, a well-prepared refund with clean reconciliation is often sanctioned much faster than a poorly documented one.
Is interest paid if refund is delayed?
Yes. Section 56 of the CGST Act provides for interest on delayed refunds — 6% per annum where the refund is not sanctioned within 60 days from the date of application, and 9% per annum in specific cases of refunds arising from appellate / court orders that are not paid within 60 days of the order. In our engagements, we actively track the refund clock and separately pursue interest claims where the department has crossed the statutory timeline — ensuring the taxpayer does not lose the time value of money.
What happens if a GST refund application is rejected?
A refund rejection order in Form GST RFD-06 is an appealable order under Section 107 of the CGST Act. The taxpayer can file a first appeal in Form GST APL-01 within three months (extendable by one month) from the date of service of the order, along with the prescribed pre-deposit. Before rejection, the officer is required to issue an SCN in Form GST RFD-08, to which the taxpayer responds in Form GST RFD-09. A well-drafted RFD-09 often results in the SCN being dropped — so the quality of the reply at this stage is just as important as the appeal later.
Do we need a CA certificate for GST refund?
A CA / CMA certificate certifying the "unjust enrichment" aspect — confirming that the burden of tax has not been passed on to another person — is required in certain refund categories and where the refund amount exceeds the prescribed threshold (currently ₹2 lakh, subject to notifications). Exports are generally presumed to satisfy the unjust enrichment test through a separate declaration. We advise at the outset whether a CA / CMA certificate is needed, and either issue it ourselves (for engagements where that is appropriate) or coordinate with the client's auditors, ensuring the certificate fully supports the refund filing.
Turn Accumulated ITC & Excess Tax Into Real Working Capital
Partner with our specialists for end-to-end GST Refund Services — LUT, IGST, SEZ, inverted duty, deemed exports, cash ledger, and refund appeals — all under one roof.
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