GST Refunds
KORAH AND KORAH, CHARTERED ACCOUNTANTS
What we will discuss?
- Brushing up of the refund provisions
- Requirements for filing a Refund Application
- Practical scenario using a Show-Cause Notice
- (Limiting the scope of our discussion to only Zero-Rated Supplies of Goods / Services / Both!)
S.54 ➞ R.89 ➞97 (CGST ACT)
Starting with S. 49(9) – you have to prove that you have not passed the burden of GST to get refund
Refund of ?
- IGST on Exports
- Unutilized ITC – 0 Rated & Inverted Duty Structure
- Balance in E Cash Ledger
- Excess Payment due to a Mistake
- Others
Refund of tax in case of Zero-Rated Supplies

Time Limits (“Relevant Date”)
Explanation under S. 54(14)
Zero-Rated Supplies on payment of IGST | Zero-Rated Supplies under LUT |
Goods
| Goods & Services
|
Services
|
Amount of Refund Claim

Refund Amount in case of Zero-Rated Supplies under LUT (Net ITC)

Breaking up the Formula

Adjusted Total Turnover

Procedure in Brief (In Rules)
RFD-01
Refund Application + Documentary Evidence
RFD-02
Acknowledgment (ARN) 15 days from Application
Process
60
Days
Deficiency
Memo
RFD-04
Order for Provisional Refund 7 days from ARN
RFD-06
Final Sanction
Order
Payment order
(earlier “advice”)
SCN – Liable for Rejection
Reply to SCN 15days
from SCN
Master Circular 125/44/2019-GST dated 18/11/2019
Application to all refund claims after 26/9/2019
Deficiency Memos
➞RFD-03 also within 15 days
➞Fresh Refund Application
➞2 years from original application
Disbursements
➞Application and Sanction by one authority
➞Disbursed through PFMS to Bank Account
➞Interest @ 6% if not refunded within 60 days
Provisional Refunds
➞90% of amount claimed
➞RFD-06 before RFD-04
Unutilized ITC
➞Upload copy of GSTR 2A
➞Self-certified purchase invoices not in 2A
➞Rule 36(4) – 5% restriction – taken care by FA’21
How does the portal calculate maximum refund amount?
Balance in E Credit Ledger at the end of tax period after filing GSTR 3B or;
As per Formula or;
Balance in E Credit Ledger at the time of refund claim
Zero-Rated Supplies
➞Procedural delay in filing LUT
➞No need proof of realization in case of export of goods
➞Terms and Conditions in LUT
If liable to pay GST, then when?

List of Documents Prescribed
Case 1 : Zero-Rated on payment of IGST
Outside India | To SEZ |
|
|
Case 2 : Zero-Rated Under LUT
Outside India | To SEZ |
|
|
Other Issues faced at the time of Refund Application
- Invoice copies for high value purchases
- Claim of ITC should match with details in GSTR 2A
- Turnover mismatch b/w GSTR 1 & 3B
- Category of refund Vs Invoice Format
- 2 Years from the Relevant Date
- Self-Declarations
- Annexure B – Correct format including column for HSN/SAC
- Correct address in FIRC Copies
- Invoice Vs FIRC Details