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Freedom251 › Blog › GST appeals

GST Refund FAQs: Eligibility, Timelines, Interest and Appeals

By Freedom251 Team · · 8 min read

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GST refunds are filed electronically in FORM GST RFD-01, but eligibility, the two-year filing window, processing time and appeal rights depend on the type of refund and its statutory “relevant date.” This guide explains the complete process under the Central Goods and Services Tax Act, 2017 and the GST refund rules.

Who can claim a GST refund?

Section 54(1) of the Central Goods and Services Tax Act, 2017 allows any person claiming refund of tax, interest paid on that tax or another amount paid to the government to apply within two years of the applicable relevant date. The rule is not a blanket two-year period from the date of every invoice: the relevant date changes with the refund category.

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Common eligible categories

  • Zero-rated supplies: exports of goods or services and eligible supplies to a Special Economic Zone (SEZ), subject to the route and evidence required for the claim.
  • Deemed exports: supplies notified as deemed exports when the prescribed recipient and supplier documentation is available.
  • Specified unutilised input tax credit (ITC): credit refundable in the statutory circumstances, including eligible zero-rated supplies and other situations recognised by the refund provisions.
  • Excess tax or other payments: amounts paid in excess, subject to the relevant-date rule and any adjustment against outstanding government dues.
  • Balance in the electronic cash ledger: a refundable balance where the law and the account records support the claim.
  • Refund arising from an order: amounts ordered by an adjudicating authority, Appellate Authority, Appellate Tribunal or court after the order has attained finality.

Refunds under section 54(5) or 54(6) are subject to a ₹1,000 minimum. A claim below that floor is not sanctioned under those provisions.

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How the relevant date works

The explanation to section 54 prescribes different relevant dates for exports, supplies to an SEZ, deemed exports, unutilised ITC, appellate or court orders and other situations. Before filing, identify the category first and calculate two years from the date prescribed for that category. Keep the document that proves the date with the application.

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Refund route Relevant-date approach Typical evidence to organise
Export of goods or services Use the export-specific relevant date in section 54 Export and tax records, shipping or service documents and the supporting statements required by the portal
SEZ supply Use the SEZ-specific relevant date SEZ endorsement or authorised-officer evidence, invoices and supply details
Deemed export Use the deemed-export relevant date Recipient documentation, invoices and proof meeting the notified conditions
Unutilised ITC Use the ITC-category relevant date Electronic credit-ledger data, purchase records, tax invoices and the calculation prescribed for the claim
Excess payment or cash-ledger balance Use the relevant date for that payment situation Challans, returns, ledger extracts and reconciliation showing the excess
Refund based on an order Use the date linked to the final appellate or court order Certified order, proof of finality and a computation of the amount due

The table describes the legal route, not a substitute for checking the exact statutory explanation and current portal requirements for a live claim.

What to prepare before filing

Refund applications are electronic, but the officer can require documentary evidence appropriate to the claim. Reconcile the amount in your return, electronic ledger and books before you start. A practical file should contain:

  • the GSTIN and the correct registration bank account;
  • the relevant-date calculation and proof of that date;
  • invoice-level schedules and a computation showing how the refundable amount was derived;
  • return, payment and ledger records supporting the tax or ITC claimed;
  • export reports and other export evidence for export claims;
  • SEZ endorsement or authorised-recipient evidence for SEZ supplies;
  • recipient documentation for deemed exports;
  • copies of any adjudication, appellate or court order relied on; and
  • an undertaking or declaration wherever the rules require one.

Check that the bank account is active and belongs to the GST registration. A mismatch may stop disbursal even when the refund order is approved.

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How to file FORM GST RFD-01

  1. Choose the correct refund category. On the GST Common Portal, select the category that matches the legal basis of the claim. The category controls the relevant date, statement format and evidence.
  2. Enter the period and amount. Provide the tax period, invoices or documents, eligible turnover or ITC figures and the amount claimed. Reconcile totals with the relevant returns and ledgers.
  3. Upload supporting documents. Attach the evidence applicable to the route, including export, SEZ, deemed-export, order or ledger records. Keep readable copies and the calculation used to reach the claim.
  4. Submit electronically. File FORM GST RFD-01 using the authorised signatory or the permitted electronic verification method. Save the Application Reference Number (ARN) and the submitted form.
  5. Watch for the first officer communication. A prima facie valid application receives an electronic acknowledgement in RFD-02. A deficiency is communicated in RFD-03 instead.
  6. Respond to any deficiency correctly. A deficiency memo is not a request to keep editing the original ARN; follow the portal instruction, correct the defect and submit a fresh, complete application where required.
  7. Monitor sanction and payment. Where the claim is prima facie eligible, provisional sanction may be issued in RFD-04 within a period not exceeding seven days from acknowledgement. Payment advice is issued in RFD-05, and the final sanction order is RFD-06.

CBIC refund rules require the application and evidence to be submitted electronically through the Common Portal. The officer may still seek clarification or additional records under the applicable procedure.

What do RFD-02 through RFD-06 mean?

Form Purpose What you should do
RFD-01 Electronic refund application Submit the category, computation and evidence before the two-year limit
RFD-02 Acknowledgement Record the acknowledgement date and ARN; this date matters for processing and interest
RFD-03 Deficiency memo Correct the identified defect and follow the fresh-filing instruction
RFD-04 Provisional sanction, where applicable Check the sanctioned amount and await payment processing
RFD-05 Payment advice Confirm the bank account and monitor disbursal
RFD-06 Final sanction order Review the amount sanctioned, rejected or adjusted and the reasons recorded

How long does a GST refund take?

The statute provides a 60-day benchmark for payment of a refund ordered under section 54(5), measured from receipt of the application. It does not guarantee that every claim will be paid in 60 days: a deficiency, verification, missing evidence, bank-validation failure or a lawful adjustment can extend the practical timeline.

Provisional sanction, where available, may be issued within no more than seven days from acknowledgement. The remaining balance still requires final examination and an RFD-06 order.

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Bank validation can add a separate hold

The Public Financial Management System (PFMS) validates bank details after filing and again after the payment order. Track the application on the GST Portal and the validation or disbursal status on PFMS. If validation fails, correct the bank details in the GST registration, update the refund application as directed and monitor it again; an approved order cannot be credited to an account that PFMS cannot validate.

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Can you claim interest for a delayed refund?

Yes, when a payable refund covered by section 56 is not paid within 60 days from receipt of the application. The ordinary statutory ceiling is up to 6%. The ceiling is up to 9% when the refund results from an order of an adjudicating authority, Appellate Authority, Appellate Tribunal or court that has attained finality.

CBIC Circular 79/53/2018 clarifies the calculation: the 60-day period starts from the ARN receipt date, interest runs from the day after that period and continues until the refund is credited to the claimant’s bank account. The ceiling is not necessarily the rate payable in every case. Use the rate notified and applicable to the relevant period, including any later amendment, when making a live calculation.

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Keep the ARN, RFD-06, payment advice, PFMS credit date and bank statement. Those records establish when the application was received and when the money actually reached the account.

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What happens if the application is deficient or rejected?

Deficiency memo

When the officer finds a deficiency, RFD-03 communicates it electronically. Under the refund rules, the amount debited for the claim is re-credited to the electronic credit ledger. Correct the defect and file as required rather than assuming the original application continues unchanged.

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Partial or complete rejection

An RFD-06 order may sanction part of the claim and reject the rest. A rejected amount is re-credited through PMT-03 after the rejection becomes final or after the claimant gives the required undertaking not to appeal. Read the reasons and identify whether the issue is evidence, calculation, eligibility, limitation or an adjustment.

Adjustment or withholding

Section 54 permits adjustment of a refund against outstanding dues. In specified pending-proceeding circumstances, the Commissioner may withhold payment when there is an assessed risk to revenue because of malfeasance or fraud, but the claimant must receive an opportunity of hearing. Such a withholding is different from a routine processing delay and should be addressed through the order and the available legal remedy.

How to appeal a rejected GST refund

  1. Record the communication date. The general limitation period starts when the decision or order is communicated.
  2. File APL-01 online within three months. Section 107(1) provides three months to appeal to the Appellate Authority.
  3. Explain any delay immediately. Up to one additional month may be condoned when sufficient cause prevented timely filing. Do not assume a longer delay can be accepted.
  4. Attach the order and grounds. State which findings, calculations or legal provisions are disputed and attach the evidence supporting the refund.
  5. Supply a copy if the order is not uploaded. The GST Portal FAQ says a self-certified copy must be provided within seven days for the final acknowledgement process in APL-02.

Pre-deposit in a demand appeal

For a demand appeal, the GST Portal FAQ states that at least 10% of the disputed tax must be paid as pre-deposit before filing. Admitted dues also have to be dealt with. Once the appeal is admitted, the remaining disputed amount is flagged as non-recoverable under the portal process. The exact amount, form fields and payment requirements depend on the order and the statutory provision, so check the current portal instructions for the particular case.

Choosing the right refund route

When more than one explanation seems possible, use this order of checks:

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  1. Identify whether the transaction is an export or SEZ supply, deemed export, unutilised ITC claim, excess payment, cash-ledger balance or order-based refund.
  2. Calculate the category-specific relevant date and confirm that two years have not elapsed.
  3. Match the evidence burden to that route instead of attaching a generic invoice bundle.
  4. Confirm that the electronic form sequence, bank account and PFMS status are complete.
  5. Preserve the ARN and communication dates in case the 60-day interest period or an appeal deadline becomes relevant.

Practical checklist before you press submit

  • Is the claim at least ₹1,000 where the section 54(5) or 54(6) floor applies?
  • Have you identified the correct relevant date rather than simply using the invoice date?
  • Do the return, invoice, ledger and bank figures reconcile?
  • Are export, SEZ, deemed-export or order documents attached where applicable?
  • Is the registration bank account correct and capable of PFMS validation?
  • Have you saved the ARN, acknowledgement and every officer communication?
  • If rejected, have you diarised the three-month APL-01 deadline and assessed any required pre-deposit?

Rates, forms, notifications and portal screens can change. For a complex export or SEZ claim, a fraud-related withholding, or an appeal involving significant tax, obtain advice from a qualified GST professional and verify the live instructions on the GST Portal before filing.

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