What is a GST refund?
A GST refund is the return of tax, interest or input tax credit that the law says you should not bear. Most refunds are claimed online in Form GST RFD-01 on gst.gov.in under section 54 of the CGST Act, 2017.
The commonest reasons are exports, supplies to SEZ units, and an inverted duty structure where the tax on your inputs is higher than the tax on your sales. The GST 2.0 rate changes of 22 September 2025, which moved most goods to the 5% and 18% slabs, left some businesses with outputs at 5% and inputs still at 18%. That gap builds up credit you cannot use, and a refund is how you get the cash back.
A refund is paid only on a claim that ties exactly to your returns. Most delays come from statements that do not match GSTR-1, GSTR-3B or GSTR-2B, not from the law itself.
Which GST refunds can you claim?
You can claim a refund in eight common situations. The route and the paperwork differ for each, so the first step is to name the right category.
| Situation | How it is claimed | Main evidence |
|---|---|---|
| Export of goods or services under LUT (no IGST paid) | RFD-01: refund of accumulated input tax credit | Shipping bills or export invoices, FIRC or BRC for services, LUT acknowledgement |
| Export of goods with IGST paid | No RFD-01: the shipping bill is treated as the refund application | Shipping bill, export general manifest, GSTR-1 Table 6A, GSTR-3B |
| Export of services with IGST paid | RFD-01: refund of tax paid | Invoices, FIRC or BRC |
| Supplies to an SEZ unit or developer | RFD-01, with or without payment of tax | Endorsement by the SEZ authorities, invoices |
| Inverted duty structure | RFD-01: refund of accumulated input tax credit | Purchase invoices, GSTR-2B, formula working |
| Excess balance in the electronic cash ledger | RFD-01 | Cash ledger extract |
| Tax paid under the wrong head (for example IGST instead of CGST and SGST) | RFD-01 under section 77 | Invoices and the correct tax payment |
| Deemed exports, or refund arising from an assessment, appeal or other order | RFD-01 by the eligible claimant | Supply documents or the order |
Refund of unutilised input tax credit is allowed only for zero-rated supplies made without payment of tax and for inverted duty (section 54(3)). Credit that is simply lying unused for other reasons is not refundable.
GST refund time limit: two years from the relevant date
You must file within two years of the relevant date under section 54(1). The relevant date is defined separately for each category in Explanation 2 to section 54, and reading the wrong clause is the most common reason a claim is rejected as time-barred.
| Refund category | Relevant date (start of the two years) |
|---|---|
| Export of goods | The date the ship or aircraft leaves India, the goods cross the frontier by land, or they are despatched by post |
| Export of services | The date you receive payment in convertible foreign exchange, or the invoice date where payment came in advance |
| Supplies to an SEZ unit or developer (refund of tax paid) | The due date of the return under section 39 for the period of those supplies |
| Inverted duty structure | The due date of the return under section 39 for the period in which the claim arises |
| Any other case not specifically covered | The date the tax was paid |
A deficiency memo does not stop the clock. If a memo arrives close to the two-year mark, the fresh application must still be inside the limit, which is why we settle the relevant date before anything else.
The 90% provisional GST refund (RFD-04)
For a low-risk claim, the officer sanctions 90% of the amount provisionally in Form RFD-04, within seven days of the acknowledgement. The balance follows after verification in the final order.
Low risk is decided by the system's risk evaluation, not by the officer's choice. Under CBIC Instruction No. 06/2025-GST dated 3 October 2025, applications that the system does not mark as low-risk do not get provisional sanction and go through detailed scrutiny.
Inverted duty claims included from 1 October 2025
Until September 2025, provisional sanction was available for zero-rated supplies (exports and SEZ). From 1 October 2025, Rule 91(2), as amended by Notification No. 13/2025-Central Tax dated 17 September 2025, extends it to inverted duty structure claims as an interim measure. For businesses caught by the GST 2.0 inversion, this is the main reason to file promptly and cleanly.
When the officer can refuse provisional sanction
Even for a low-risk claim, the officer can record reasons in writing and send the application for detailed examination instead of granting 90%. The instruction asks officers to use this sparingly. A claim with clean reconciliations and no pending mismatches gives the officer no reason to use it.
Export refunds: LUT route or IGST route
Exporters choose between two routes. You export without paying IGST under a Letter of Undertaking and claim back the input credit, or you pay IGST on the export and get that IGST refunded.
Exports under LUT: refund of accumulated ITC
You file an LUT in Form RFD-11 once for each financial year (see our LUT filing service), export without IGST, and claim the unused input credit in RFD-01. The refund is worked out under Rule 89(4): credit multiplied by the share of zero-rated turnover in your total turnover. The turnover figures must tie to your GSTR-3B for the period.
Exports of goods with IGST: the shipping bill is the application
Under Rule 96, the shipping bill is deemed to be your refund application once the carrier files the export manifest and you have filed a valid GSTR-3B. You also complete Aadhaar authentication. The export invoices you report in GSTR-1 (Table 6A) are sent by the GST portal to the customs system (ICEGATE), which checks them against the shipping bill.
If the GSTR-1 data and the shipping bill do not match, the refund is treated as filed only after you correct the mismatch. Most "IGST refund not received" cases we see trace back to an invoice number, value or GSTIN that differs between the two. The refund is credited to the bank account registered with customs, so your AD code registration at the port matters too (see IEC registration).
Exports of services
A service export is refunded through RFD-01, whether under LUT or with IGST paid. Keep the foreign inward remittance evidence (FIRC or bank realisation certificate) for each invoice, because the relevant date and the claim both depend on the date of receipt in convertible foreign exchange.
LUT vs IGST at a glance
| Point | Export under LUT | Export with IGST paid |
|---|---|---|
| Cash tied up | None on the export itself | IGST paid upfront, refunded later |
| How you claim | RFD-01 for accumulated credit | Goods: shipping bill as the application. Services: RFD-01 |
| Annual step | File RFD-11 each financial year | None |
| Where claims usually stall | Turnover working and statements | GSTR-1 Table 6A vs shipping bill mismatch |
Inverted duty structure refund
An inverted duty refund returns input credit that builds up because the tax rate on your inputs is higher than on your outputs. It is claimed in RFD-01 under section 54(3)(ii) using the Rule 89(5) formula.
In plain words, the formula starts from the credit on goods you bought as inputs, takes the share of that credit linked to your inverted-rated turnover, and subtracts the tax you paid on that turnover. Credit on input services and capital goods does not enter the formula. Some notified goods and services are excluded from inverted duty refunds altogether, so we check your items before promising a figure.
The relevant date is the due date of the GSTR-3B for the period, so each month or quarter has its own two-year window. Filing period by period, rather than once a year, keeps each claim inside its limit.
GST refund process, step by step
Every refund moves through a fixed sequence of forms on the GST portal. The table shows what each one means and the time limits the rules set.
| Step | Form | What happens | Time limit |
|---|---|---|---|
| 1 | RFD-01 | You file the application with statements and documents | Within two years of the relevant date |
| 2 | RFD-02 or RFD-03 | The officer acknowledges a complete application, or issues a deficiency memo | Within 15 days of filing |
| 3 | RFD-04 | Provisional sanction of 90% for low-risk export and inverted duty claims | Within 7 days of acknowledgement |
| 4 | RFD-08 and RFD-09 | If the officer proposes to reject any part, a show cause notice; you reply | Reply within 15 days of the notice |
| 5 | RFD-06 | Final order sanctioning, partly sanctioning or rejecting the claim | Within 60 days of a complete application |
| 6 | RFD-05 | Payment order; money is credited to your validated bank account | After sanction |
Our part of the work sits mostly before step 1. We fix the relevant date, reconcile the statements to your returns, prepare the formula working and the documents, and then file. After filing we track each stage and draft any reply.
Deficiency memo (RFD-03) and show cause notice (RFD-08)
A deficiency memo is not a rejection, but it closes your application. You file afresh after correcting the gaps, and the two-year limit keeps running.
Why deficiency memos happen
- Turnover in the refund statement does not match GSTR-3B for the period.
- Invoices claimed are missing from GSTR-2B, or the statement lists invoices of another period.
- Export invoices lack shipping bill or foreign-exchange evidence.
- The wrong refund category is chosen, or a required undertaking or certificate is missing.
We run these checks before filing. They are the same checks the officer runs, so doing them first saves a full cycle.
Replying to RFD-08
A show cause notice in RFD-08 means the officer intends to reject all or part of the claim. The reply in RFD-09 is due within 15 days. We draft it point by point with the supporting documents; if the final order still goes against you, it can be appealed (see GST notice reply).
Interest on a delayed GST refund
If a sanctioned refund is not paid within 60 days of receiving your complete application, section 56 of the CGST Act entitles you to interest for the delay. The notified rate is 6% a year, and 9% a year where the refund arises from an appellate or court order that has become final.
Interest runs from the day after the 60 days end until the refund is paid. It is payable only on an application that was complete, which is another reason to avoid a deficiency memo.
How to check GST refund status
You can track a refund on the GST portal after logging in: go to Services › Refunds › Track Application Status, and search by the financial year or the ARN (Application Reference Number) you received on filing.
The status shows the stage in form terms: RFD-02 or RFD-03 after filing, RFD-04 or RFD-06 at sanction, and RFD-05 at payment. Once a payment order is issued, the Public Financial Management System (PFMS) tracker shows whether your bank account validated and whether the money has been sent. A refund held at PFMS usually means a bank account detail does not match; we check that before filing.
CA certificate for a GST refund: when it is needed
You need a certificate from a chartered accountant or cost accountant under Rule 89(2)(m) when the refund claimed exceeds ₹2 lakh. It confirms that the tax has not been passed on to anyone else.
The certificate is not required for exports, for refunds of unutilised input credit (including inverted duty) or for tax paid under the wrong head (section 54(8)). Below ₹2 lakh, a self-declaration under Rule 89(2)(l) is used instead, again with the same exceptions. Where a certificate is needed, our CA issues it as part of the engagement.
Documents we need for a GST refund
- GSTR-1, GSTR-3B and GSTR-2B for the claim period
- The refund statements that apply to your category, with invoice-wise detail
- Shipping bills and export invoices, for goods exports
- FIRC or bank realisation evidence, for services exports
- LUT acknowledgement for the financial year, for exports without IGST
- Purchase invoices supporting the input credit claimed
- Your working of the Rule 89(4) or Rule 89(5) formula, if you have one (we prepare it otherwise)
- For SEZ supplies, the SEZ endorsement on the invoices
- Bank account details matching the account on your GST registration
Our GST refund fee
Regikart files a GST refund from ₹4,999. The fee covers fixing the relevant date, reconciliation, the refund statements and formula working, filing RFD-01 and tracking the claim to sanction.
| Item | Amount |
|---|---|
| Professional fee: GST refund application | From ₹4,999 |
| Government fee: RFD-01 or IGST export refund | No government fee |
Professional fees exclude GST at 18%. Government fees, where they apply, are paid at actuals to the department and are shown separately. Fees verified on 21 September 2026.
We quote a fixed fee after seeing the category, the number of periods and the invoice volume. The fee is not a percentage of your refund.
Why Regikart for GST refunds
- Reconciliation before filing. Statements are tied to GSTR-1, GSTR-3B and GSTR-2B before RFD-01 goes in, because that is where deficiency memos come from.
- Relevant date first. Every claim starts with the limitation check, period by period.
- One firm for the whole chain. LUT filing, monthly GST return filing, refunds and replies to notices sit with the same CA team.
- Named reviewer. Refund work is reviewed by CA Deepak Jaiswal.
- Three offices. Kolkata (head office), Delhi and Bengaluru, working online with clients across India. 250+ clients.
Not registered yet, or registering a new place of business for exports? Start with GST registration.
Related: GSTR-9C, which reconciles the turnover you declared, zero-rated supplies included, with your audited accounts once aggregate turnover crosses ₹5 crore, and CMA data if your bank is setting or renewing a working capital limit.