Harun Raaj & AssociatesHarun Raaj & Associates
Indirect Tax Services

GST Export Refund

GST Export Refund

Start — upload documents, pay when ready →Talk to a CAWhatsApp us
SCOPEConfirmed in writing

Regulatory Framework

Refunds relating to export of goods and services are governed by Section 54 of the Central Goods and Services Tax (CGST) Act, 2017, read with Rule 89 of the CGST Rules, 2017.

Zero-rated supply refund route (Section 54(3)): Exporters who supply goods or services without payment of integrated tax, under a Letter of Undertaking (LUT), may claim a refund of the unutilised Input Tax Credit accumulated on inputs and input services used in making the zero-rated supply. The refund application is filed electronically in FORM RFD-01.

Relevant date for exports (Explanation 2 to Section 54): For export of goods, the relevant date is the date on which the ship or aircraft carrying the goods leaves India, or — where goods are exported by land — the date the goods cross the frontier, or the date of dispatch by post. For export of services, the relevant date is the date of receipt of payment in convertible foreign exchange, or, where payment is received in advance of the export, the date of invoice. The two-year limitation period under Section 54(1) runs from this relevant date.

Documentation (Rule 89): The application must be supported by shipping bills or bills of export, the GSTR-2B/ITC statement, and — for service exports — the Bank Realisation Certificate/Foreign Inward Remittance Certificate (BRC/FIRC) evidencing receipt of foreign exchange. Claims exceeding ₹2 lakh require a certificate under Rule 89(2)(m) confirming that the incidence of tax has not been passed on.

Timeline: A provisional refund of 90% of the claimed amount may be sanctioned within 7 days for exporters under Section 54(6); full sanction is otherwise due within 60 days, beyond which interest accrues under Section 56.

Overview

GST export refund is the mechanism by which an exporter recovers the input tax credit that would otherwise block cash in the export business. Under Section 54 of the CGST Act 2017 and Rules 89 and 96 of the CGST Rules, an exporter making zero-rated supplies can claim a refund of unutilised input tax credit — either by exporting with payment of IGST and claiming refund of that IGST (the shipping bill route under Rule 96, where the refund is deemed applied and sanctioned from the shipping bill data), or by exporting under bond or LUT and claiming refund of the accumulated credit under Rule 89. The refund is the exporter's own money coming back.

The refund is the cash cycle of the export business. The credit accumulates because the inputs carry GST while the exports are zero-rated; without the refund, the accumulation sits in the electronic credit ledger and the exporter effectively funds the government with working capital. The refund process is where that capital returns — and it returns faster when the claim is built right the first time.

The cost of a broken refund claim is the blocked cash and the rejection cycle: claims filed with mismatched shipping bills, wrong ledgers or missing invoices are returned or rejected under the deficiency process, and every cycle is more weeks of working capital locked. The claims that sail through are the ones built from the ledger position and the shipping bill data before filing.

This service is for exporters — goods and services, including deemed exports. We map your export supplies to the right refund route under Rule 89 or Rule 96, reconcile the shipping bills and the invoices, prepare and file the refund application, track the sanction and the payment under Section 54, and handle the deficiencies and the appeals when they come.

How It Works

  1. 1

    Refund Route Mapping

    We determine the right route — Rule 96 shipping-bill refund or Rule 89 unutilised credit refund.

    Harun Raaj & Associates does this2-3 days
  2. 2

    Ledger & Invoice Reconciliation

    We reconcile the electronic credit ledger, the invoices and the shipping bill data.

    Harun Raaj & Associates does this1 week
  3. 3

    Application Preparation

    We prepare the refund application under Rule 89 with the prescribed annexures.

    Harun Raaj & Associates does this1 week
  4. 4

    Filing & Sanction Tracking

    We file the claim and track the sanction and payment under Section 54.

    Harun Raaj & Associates does this2-8 weeks
  5. 5

    Deficiency & Appeal Handling

    We respond to deficiencies and pursue appeals if the claim is rejected.

    Harun Raaj & Associates does thisAs required

Frequently Asked Questions

What are the two options for an exporter to avoid GST on exports?
Under Section 16 IGST Act, zero-rated supply (export) can be made: (a) under LUT/Bond (Form RFD-11) — supply without payment of IGST, claim ITC refund on inputs under Section 54(3)(ii); or (b) pay IGST and claim refund of IGST paid on exports (auto-processed via GSTR-1 shipping bill linkage on ICEGATE). Option (a) is preferred for large exporters — avoids cash outflow. Option (b) is simpler for occasional exporters — refund is automatic but takes 2–4 weeks.
What is an LUT and how is it filed?
A Letter of Undertaking under Rule 96A is filed annually on the GST portal (LUT for each financial year, before the first zero-rated supply). Who can file LUT: any registered exporter who has not been prosecuted for any offence under the CGST/IGST Act or any other law where tax evaded exceeds ₹250 lakh. LUT is valid for the entire financial year. If not filed, the exporter must pay IGST on exports and claim a refund — a cash-flow disadvantage.
How is the ITC refund on inputs used for zero-rated exports calculated?
Rule 89(4) formula: Refund = (Turnover of zero-rated supply of goods or services × Net ITC) ÷ Adjusted Total Turnover. Adjusted Total Turnover includes all taxable supplies (including zero-rated) but excludes exempt supplies, nil-rated supplies, and reversal of ITC under Rule 42. 'Net ITC' excludes ITC on inputs used for exempt/nil-rated supplies. GSTR-9C reconciliation of this formula is a common area of dispute.
Why do IGST export refunds get stuck?
Common reasons: (a) GSTR-1 shipping bill details (invoice number, amount, port) do not match ICEGATE customs records — requires GSTR-1 amendment or GSTN-ICEGATE helpdesk intervention; (b) LUT expired or not filed for the relevant period; (c) EGM (Export General Manifest) not filed by the shipping carrier — exporter has no control but can follow up with the shipping line; (d) GSTR-3B filed after the shipping bill date for that period (mismatch in timelines). Resolution requires coordination with the GST portal, ICEGATE, and customs.
What is the time limit and interest on delayed refunds?
Section 54(1): GST refund must be applied within 2 years from the 'relevant date' (for exports: date of export). Missing the 2-year window = permanent forfeiture — no condonation provision. Section 56: 6% interest per annum if the refund is not processed within 60 days of a complete application. Interest accrues automatically — it need not be separately claimed.

Ready to get GST Export Refund?

File a request in under 2 minutes. Our team contacts you within 24 hours.

Start — upload documents, pay when ready →