GST Refund Process: Export, Inverted Duty, Excess Cash Ledger

When you can claim a GST refund

GST refunds are available in these scenarios under Section 54:

1. Export of goods/services — Either with payment of IGST (refund of IGST paid) OR without payment of IGST under LUT (refund of unutilised ITC)
2. Inverted duty structure — When input GST rate is higher than output GST rate (e.g., textile manufacturers with 12% input GST but 5% output)
3. Excess balance in cash ledger — Money paid to GSTN but not utilised against any liability
4. SEZ supplies — Supplies to SEZ units treated as exports
5. Deemed exports — Specific categories like supplies to EOUs
6. Refund of tax paid by mistake — Tax paid in wrong head (e.g., IGST instead of CGST+SGST)
7. Tax paid on cancelled supplies — Hotel booking cancellations etc.

Time limit — 2 years

Refund claim must be filed within 2 years from the 'relevant date':

• Exports: 2 years from end of FY in which export was made
• Inverted duty: 2 years from end of FY in which input tax credit accumulated
• Excess cash: 2 years from date of payment
• Cancelled supplies: 2 years from cancellation date

Claims beyond 2 years are time-barred. Cannot be filed.

Step-by-step refund filing (RFD-01)

1. Login to gst.gov.in → Services → Refunds → Application for Refund
2. Select refund type (export with LUT, inverted duty, excess cash, etc.)
3. Select tax period(s) for which refund is claimed
4. System auto-calculates eligible refund amount based on returns filed
5. Upload supporting documents:
   • Shipping bills (for exports)
   • Bank realisation certificate (BRC) / FIRC
   • Tax invoices
   • Inward supply invoices (for ITC refund)
   • Bank account details
6. Generate ARN (Application Reference Number)
7. System sends acknowledgment
8. Pre-audit by tax officer (5-7 days)
9. If approved, 90% provisional refund disbursed (Section 54(6))
10. Final order within 60 days of complete application

Bottlenecks and how to avoid

• BRC not received — Bank's e-BRC system delays. Push your bank for fast BRC release.
• Shipping bill mismatch — Customs data must match GST returns. Reconcile before filing refund.
• ITC reversal — Pre-2022 ITC for invoices not in GSTR-2B must be reversed before refund claim.
• Document missing — Officer issues deficiency memo (RFD-03). Respond within 15 days.
• Different state outflows — If exports happen from different ports/states, claim separately per GSTIN.

Interest on delayed refunds

If GST department delays refund beyond 60 days of complete application:

• Interest at 6% p.a. (Section 56) for first 24 days delay
• Then 9% p.a. for further delay beyond that
• Officer who delays may also face departmental action

Track your refund status on portal and follow up via grievance redressal if delayed.