ICAI Firm Regn. No. 010699SMon–Sat, 9:00 AM – 7:00 PM
Goods & Services Tax

GST Refund Services in India

A GST refund claim arises where more tax has effectively been paid than is due — most commonly for exporters, businesses with an inverted duty structure, or where excess balance sits unused in the electronic cash ledger. It's claimed in Form RFD-01 within a strict two-year window, and RITS & Associates prepares and files refund claims for clients across India and overseas, including the reconciliation work that supports a clean, fast-tracked application.

Updated September 2026ICAI FRN 010699S6-minute read

The main categories of GST refund

  • Export of goods or services without payment of tax — under a Letter of Undertaking, the unutilised input tax credit attributable to the export is refunded.
  • Export with payment of IGST — the IGST paid on the export is refunded, often processed through the shipping bill itself for goods.
  • Inverted duty structure — where tax on inputs is higher than tax on the output supply, leading to accumulated, otherwise unusable input tax credit.
  • Excess balance in the electronic cash ledger — money deposited but not needed to discharge liability can be claimed back.
  • Excess payment of tax — including tax paid under the wrong head (say, IGST instead of CGST/SGST) under Section 77.
  • Deemed exports and supplies to SEZ units — specific categories treated as exports for refund purposes even though the goods don't physically leave India.
  • Refund following a favourable appellate order — where an earlier demand is set aside or reduced on appeal.

Time limits by refund type

The two-year clock starts from a different "relevant date" for each category
Refund typeRelevant date
Export of goodsDate the goods leave India (date of departure of the ship or aircraft)
Export of servicesDate of receipt of payment in convertible foreign exchange (or as otherwise prescribed)
Inverted duty structureEnd of the financial year in which the claim arises
Excess balance in electronic cash ledgerNo time limit in the same sense — can generally be claimed at any time
Tax paid under the wrong headDate the tax is paid under the correct head
Refund following an appellate orderDate of communication of the order

This two-year limit is treated strictly — courts have consistently upheld it, and there is no statutory provision to condone a claim filed even a day late. Identifying the correct relevant date for your specific claim, and not leaving the application until close to the deadline, matters more here than in most other GST filings.

Documents typically required

  • GSTR-1 and GSTR-3B for the relevant period, and GSTR-2B supporting the input tax credit claimed.
  • For export refunds: shipping bills, bank realisation certificates or foreign inward remittance certificates evidencing receipt of export proceeds.
  • For inverted duty claims: a statement of inward and outward supplies for the period, computed under Rule 89(5).
  • A statement of the electronic cash and credit ledgers for the relevant period.
  • A declaration confirming the applicant hasn't passed on the incidence of the tax to another person (to satisfy the unjust enrichment test), where applicable.
  • A certificate from a Chartered Accountant or Cost Accountant, where the claim exceeds the prescribed threshold and the self-declaration alone isn't sufficient.

The refund process, step by step

  1. Eligibility and relevant-date check

    The specific refund category is confirmed, and the relevant date for the two-year limit is fixed before anything else — getting this wrong at the outset risks the whole claim.

  2. Computation under the applicable rule

    The refund amount is computed using the formula prescribed for that category — Rule 89(4) for zero-rated supplies without payment of tax, Rule 89(5) for inverted duty structure claims, and so on.

  3. Filing Form RFD-01

    The application is filed online with supporting statements and declarations, and an acknowledgement in Form RFD-02 is issued once the application is complete.

  4. Provisional refund, where applicable

    For eligible zero-rated and inverted-duty claims assessed as low-risk by the system, 90% is sanctioned provisionally within 7 days, in Form RFD-04, without waiting for full scrutiny.

  5. Departmental scrutiny

    The balance amount, or the full amount for claims not eligible for provisional refund, goes through scrutiny. A deficiency memo (RFD-03) may be issued if something is missing, which restarts the processing clock once resubmitted.

  6. Final sanction or rejection

    A final order is issued in Form RFD-06, sanctioning the refund or explaining a rejection — a show-cause notice is issued first if the officer proposes to reject or reduce the claim.

Processing timelines

Key timelines
StageTimeline
Acknowledgement of a complete application (RFD-02)Within 15 days
Provisional refund for eligible, low-risk claims (RFD-04)Within 7 days of acknowledgement
Final order (RFD-06)Within 60 days of a complete application
Interest for delay beyond 60 days6% per annum; 9% where the refund follows an appellate or court order

Practical notes from our engagements

  • The relevant date computed incorrectly. Since the two-year limit has no exceptions, getting the relevant date wrong — particularly for service exports, where it depends on when payment is actually received rather than when the service is provided — is the single riskiest mistake on a refund claim.
  • Provisional refund no longer automatic. Since October 2025, the 90% provisional refund is granted based on a system risk evaluation, not automatically for every eligible claim — a clean, well-matched GSTR-1/3B/2B position materially improves the chance of being treated as low-risk.
  • Shipping bill and invoice details not matching exactly. For export refunds, a mismatch between the invoice value on the shipping bill and the GST invoice is one of the most common reasons for a deficiency memo.
  • Inverted duty computation done on the wrong basis. Rule 89(5) includes only input tax credit on inputs (goods), not on input services or capital goods — a computation that includes those overstates the claim and gets flagged during scrutiny.
  • Deficiency memo response delayed. Once an RFD-03 deficiency memo is issued, the 60-day processing clock restarts only from resubmission — treating it as low priority simply extends how long the refund takes.

How we handle a refund claim

We confirm the refund category and the relevant date before starting any computation, since that single decision governs whether the claim can be filed at all. The application is prepared with GSTR-1, GSTR-3B and GSTR-2B already reconciled, so the claim presents as low-risk and matched from the outset rather than requiring clarification partway through processing.

Frequently asked questions

What is the time limit for claiming a GST refund?

Two years from the 'relevant date', which varies by refund category — for exports, the date the goods leave India; for inverted duty claims, the end of the financial year. There's no provision to condone a claim filed after this.

Is the 90% provisional refund automatic?

Not anymore. Since 1 October 2025, provisional refund is granted based on a system-generated risk evaluation for eligible zero-rated and inverted-duty claims — low-risk applications are fast-tracked, but it isn't guaranteed for every claim.

How long does a GST refund take to process?

Up to 60 days from a complete application for the final order, with interest at 6% per annum payable if the department exceeds that. A deficiency memo, if issued, restarts the clock from resubmission.

Can I claim a refund of excess balance in my electronic cash ledger at any time?

Yes, this category doesn't carry the same relevant-date constraint as export or inverted-duty claims — excess cash ledger balance can generally be claimed whenever the business wants it back.

What is an inverted duty structure refund?

It applies where the tax rate on inputs is higher than on the output supply, leading to input tax credit that accumulates and can't otherwise be used — the excess is claimed as a refund under Rule 89(5).

Does the inverted duty refund include credit on services and capital goods?

No — Rule 89(5) computes the refund based only on input tax credit on inputs (goods), excluding input services and capital goods.

What happens if my refund application has a deficiency?

The department issues a deficiency memo in Form RFD-03, and you need to correct and resubmit — the 60-day processing period then runs from the resubmission date, not the original filing.

Can a refund claim be rejected without a hearing?

No — where the officer proposes to reject or reduce a claim, a show-cause notice is issued first, giving the applicant an opportunity to respond before a final order.

Is a Chartered Accountant's certificate always required for a refund claim?

Only above a prescribed claim value — below that, a self-declaration on the unjust enrichment point is generally sufficient.

Not sure which service fits?

Describe your situation in a sentence or two. A partner will tell you what it involves, what we'll need from you and the timeline — before any work begins.

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