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GST Refund Services — Export, IGST, ITC & Inverted Duty Structure | N D Savla & Associates

GST Refund Services — Export Refunds, Inverted Duty Structure, IGST Refund & Excess ITC Recovery

Export Refund · IGST Refund · Inverted Duty Structure · ITC Refund · RFD-01  |  Mumbai | Exporters | SEZ Suppliers | Zero-Rated Supplies

GST Refund Services in Mumbai

A GST refund arises when a registered taxpayer has paid GST — through IGST paid on exports, ITC accumulated against zero-rated supplies made under LUT, or ITC that has built up because of an inverted duty structure — and is entitled to recover that payment from the government. GST refund claims are filed on the GST portal at gst.gov.in, and when approved, the refund amount is credited directly to the taxpayer's bank account. For export-oriented businesses, a well-managed GST refund programme is a critical component of working capital management: IGST paid on exports or ITC accumulated on inputs used for exports is money that belongs to the exporter and must be recovered promptly. Delays in GST refund processing can tie up crores of rupees in blocked working capital, forcing businesses to resort to costly short-term borrowings.

N D Savla & Associates, Chartered Accountants in Mumbai, provides end-to-end GST refund services: identifying eligible GST refund categories, computing the refund amount, filing Form RFD-01 with all required documentation, following up with the department, responding to deficiency memos (RFD-03), and where necessary, pursuing escalation to the Commissioner and beyond when GST refund claims are wrongly rejected. This page covers the complete range of GST refund categories under the CGST Act, 2017. For the specific deep-dive on inverted duty structure GST refund, see our Inverted Duty Structure GST Refund guide. For the GST export LUT, see our GST LUT Form guide.


Categories of GST Refund Under the CGST Act, 2017

GST Refund CategoryWho Can ClaimForm and Mechanism
IGST paid on export of goodsExporters who have exported goods and paid IGST on the export supply (as opposed to exporting under LUT/bond)No separate RFD-01 required; IGST refund is processed automatically based on GSTR-1 and shipping bill data reconciliation on the ICEGATE-GSTN system
ITC accumulated on zero-rated supplies (goods/services exported under LUT)Exporters who have filed LUT and exported without paying IGST but have ITC on inputs used for exportForm RFD-01 under the category "Refund on account of zero-rated supplies" with Statement 3 of eligible ITC
GST refund due to inverted duty structure (Section 54(3))Registered persons where the GST rate on inputs is higher than the GST rate on output suppliesForm RFD-01; computation using Rule 89(5) formula; Statement 1 for goods-based claims
Excess GST paid by mistakeAny registered taxpayer who has paid excess CGST, SGST, or IGST (by error in the return or by double payment)Form RFD-01 for excess tax paid; supported by payment challans and return details showing the excess
GST paid on supplies to SEZ units or developersSuppliers who have supplied goods or services to an SEZ unit or SEZ developer and paid GST on such supply (which should be zero-rated)Form RFD-01; certificate from SEZ officer confirming receipt
Tax paid on advance but supply not madeTaxpayers who paid GST on advance received but the supply was not made and the advance was refunded to the customerForm RFD-01; documentary evidence of advance reversal
Pre-deposit refund after order in appealTaxpayer who paid a pre-deposit for appeal and the appeal was decided in their favour (whole or partial)Form RFD-01 after the appellate order is received

IGST Refund on Export of Goods — Automatic vs Manual

Automatic IGST Refund Processing

For exporters who export goods under a shipping bill and have paid IGST on the export supply, the IGST refund is designed to be automatic: GSTN matches the IGST paid details declared in GSTR-1 with the shipping bill details filed at the port (through ICEGATE). When the match is successful, the system automatically processes the IGST refund and credits it to the exporter's bank account registered with customs (PFMS-linked account). No separate Form RFD-01 filing is required. This is the cleanest and fastest form of GST refund for goods exporters.

When the IGST Refund Gets Stuck — Manual Intervention Required

  • GSTR-1 and shipping bill mismatch: if the GSTIN, invoice number, invoice date, taxable value, or IGST amount in the GSTR-1 does not exactly match the shipping bill, the automated system cannot process the refund. The exporter must amend GSTR-1 or file a manual refund claim
  • SB005 and SB006 errors: shipping bill errors that block IGST refund processing — the exporter must contact the customs port officer to get the shipping bill corrected
  • Bank account not registered with PFMS: the bank account for IGST refund credit must be registered on the GST portal and validated through PFMS. Validation failures block credit
  • LUT not filed before export: if the exporter exports under LUT but the LUT was not filed before the date of export, the export may not qualify for zero-rated treatment, blocking the IGST refund

ITC Accumulated on Zero-Rated Supplies — LUT Route GST Refund

Exporters who export goods or services under LUT do not pay IGST on the export. Instead, they claim a GST refund of the ITC accumulated on inputs used to make the export supply. The claim is filed in Form RFD-01 on the GST portal. The eligible refund amount is computed using the formula prescribed under Rule 89(4):

Refund of ITC (LUT Route) = (Export Turnover in State / Adjusted Total Turnover) × Net ITC
  • Export Turnover: the value of export supplies in the state during the tax period
  • Adjusted Total Turnover: total turnover in the state during the tax period (excluding certain supplies)
  • Net ITC: total ITC availed during the tax period on inputs and input services used for the supply of goods or services (excluding ITC on capital goods)

GST Refund for Service Exporters — Specific Considerations

Service exporters — IT companies, consulting firms, architects, legal services providers, BPO/KPO companies — typically export services under LUT and accumulate ITC on their inputs (office rent, professional services, software subscriptions, hardware, stationery, etc.) at 18% GST. The output GST collected on export services is nil (zero-rated under LUT). The entire input ITC accumulates and must be recovered through periodic GST refund claims. For large service exporters, the monthly GST refund recovery can be a significant source of working capital. Key issues for service exporters claiming GST refund:

  • Foreign currency receipt evidence: for export of services to qualify as zero-rated under Section 2(6) of the IGST Act, the service must be supplied to a recipient outside India AND the payment must be received in convertible foreign currency (or Indian rupees where permitted). Bank realisation certificates (BRCs) or FIRC must be produced to support the claim
  • CA certificate: for service export GST refund claims above specified amounts, a CA certificate in prescribed format (Annexure 2 to the circular) confirming the amount of ITC availed and that the refund has not been claimed elsewhere must be furnished along with RFD-01

GST Refund Process — From RFD-01 to Bank Credit

  1. File Form RFD-01 — on gst.gov.in under Services ? Refunds. Select the correct category of GST refund and tax period; upload supporting statements and documents
  2. ARN generation — after submission, an Application Reference Number (ARN) is generated to track status on the portal
  3. Provisional GST refund (RFD-04) — for GST refund claims other than ITC refunds, the proper officer must grant a provisional refund of 90% of the claimed amount within 7 days of acknowledgement (if the claim is complete)
  4. Final GST refund (RFD-06) — after verification of all documents, the proper officer issues the final refund order within 60 days of receipt of the complete application; the refund is then credited to the registered bank account
  5. Deficiency memo (RFD-03) — if the proper officer finds any deficiency, they issue RFD-03 requesting additional information; the taxpayer must respond to resume processing
  6. Rejection (RFD-06 with rejection) — if the officer rejects the claim, a speaking order with reasons must be issued; the taxpayer can appeal before the Appellate Authority under Section 107
?? Important: If a GST refund is not processed within 60 days of receipt of the application, interest at 6% per annum becomes payable by the government under Section 56 of the CGST Act. If the delay is on account of reasons attributable to the registered person (incorrect application, missing documents), interest does not accrue for that period.

Frequently Asked Questions — GST Refund Services

How long does the GST refund process take?
The CGST Act specifies a 60-day timeline for the proper officer to process a GST refund application from the date of complete application receipt. In practice, processing times vary: straightforward IGST refund on exports is typically 2–4 weeks; ITC refund on zero-rated supplies (LUT route) typically 4–8 weeks; inverted duty structure GST refund can take 6–12 weeks due to additional scrutiny. If the department issues a deficiency memo, the timeline resets from the date of resubmission. N D Savla & Associates follows up actively with the GST refund team to ensure timely processing.
Can we claim a GST refund for both IGST paid and ITC accumulated?
Yes, but not for the same supply. An exporter can claim either IGST refund (for exports where IGST was paid) OR ITC refund (for exports under LUT where no IGST was paid but ITC has accumulated on inputs). An exporter cannot claim both for the same export transaction. The choice between the two routes affects which GST refund mechanism is used.
We were denied a GST refund. What can we do?
A GST refund rejection can be appealed before the Appellate Authority (Commissioner Appeals) under Section 107 of the CGST Act within 3 months of the date of the rejection order. A pre-deposit of 10% of the disputed refund amount (which is itself refundable if the appeal succeeds) is required. See our GST Appeal Services guide for the appeal process.

Have a GST Refund Pending?

Whether it's an export IGST refund, LUT-route ITC refund, or an inverted duty structure claim, we handle the full process from filing to bank credit.

?? +91 9821 83 26 83  |  ?? WhatsApp: +91 9819 000 511  |  ? nainitsavla@savlagroup.in

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