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The GST refund grounds at a glance
FORM GST RFD-01 separates refund claims by the event that created the refundable amount. The table below shows the practical distinction before the detailed procedures.
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| Refund ground | What created the amount | Typical route | What is being returned | Core evidence or validation risk |
|---|---|---|---|---|
| Exports without payment of tax | Zero-rated goods or services supplied under bond or LUT, leaving ITC unutilised | RFD-01 under Rule 89 | Unutilised ITC, calculated by the Rule 89 formula | Export invoices, shipping or service-realisation evidence, ITC and turnover reconciliation |
| Exports with IGST paid | IGST was paid on an export shipment | Rule 96; the shipping bill can function as the refund application when conditions are met | IGST paid on the export | Export manifest/report, valid return, required authentication and matching shipping-bill data |
| Inverted-duty ITC | Input tax rates exceed the tax rate on the outward supply, causing ITC to accumulate | RFD-01 with the required invoice statement | Eligible accumulated ITC | Annex 1, invoice-level details and proof that input and output rates are correct |
| Excess electronic-cash balance | More tax, interest, penalty, fee or other amount was deposited in the electronic cash ledger than was required | Claim through the relevant return | Cash ledger balance | Ledger and return figures must agree; this is not an unutilised-ITC claim |
| SEZ supplies | Supplies made to an SEZ unit or developer | RFD-01 | Refund associated with the eligible zero-rated supply | Specified-officer endorsement, authorised-operations evidence and, for services, payment evidence |
| Deemed exports | A supply treated as a deemed export under GST rules | RFD-01 | Refund of the eligible tax or related amount | Transaction documents and the evidence required for the particular deemed-export category |
| Orders and transaction corrections | Assessment, provisional-assessment, appeal or other order; tax paid on a supply not provided; place-of-supply correction; or excess tax payment | RFD-01 | The amount established by the order or correction | Order reference or transaction evidence supporting the adjustment |
The same business can use more than one ground over time, but each application should describe one identifiable cause and cover the correct tax period.
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Exports are zero-rated, but the refund mechanism depends on whether IGST was paid when the goods or services left India.
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Exports under bond or LUT without payment of tax
When a zero-rated export is made without payment of tax under a bond or letter of undertaking, the claim concerns ITC that could not be used against output tax. Rule 89 sets a maximum-refund formula:
Maximum refund = (turnover of zero-rated goods + turnover of zero-rated services) × net ITC ÷ adjusted total turnover
The rule defines each component—export turnover, net ITC, adjusted total turnover and the relevant period. Use the definitions for the period covered by the application rather than substituting a management accounting figure. A claim that combines goods and services therefore needs a defensible turnover split and an ITC figure tied to the same period.
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Exports with IGST paid
Rule 96 uses the shipping bill as the refund application only when the export data is ready for electronic processing. The export manifest or report must have been filed, the exporter must have furnished a valid return, any required authentication must be completed, and data mismatches must be corrected. A shipping bill alone is not enough if one of those conditions is missing.
Common reconciliation work includes matching the shipping-bill or bill-of-export number to the invoice reported in the return, checking the exporter and consignee details, and correcting differences between customs and GSTR-1 data. Before relying on this route, check whether an export-duty restriction or another Rule 96 limitation applies to the shipment. Keep the manifest confirmation and corrected return trail with the shipping documents.
Export evidence checklist
- Commercial export invoice linked to the return entry.
- Shipping bill or bill of export for goods.
- Export manifest or report status for the IGST-paid route.
- Bank-realisation certificate or foreign-inward-remittance evidence for services.
- Bond or LUT details where the export was made without payment of tax.
- ITC ledger, purchase invoices and the turnover calculation used for a Rule 89 claim.
- Proof of required authentication and a record of any mismatch correction.
What an inverted-duty refund is
An inverted tax structure exists when the GST rate on eligible inputs is higher than the rate on the outward supply. The business pays more tax through purchases than it collects on sales, so ITC accumulates instead of being fully used. FORM GST RFD-01 lists “ITC accumulated due to inverted tax structure” as a distinct ground; it is not an export claim and should not be folded into a general excess-payment explanation.
Rule 89 requires an Annex 1 statement listing invoices received and invoices issued during the tax period. Prepare the statement at invoice level, then test the tax rate on every material input against the output rate used for the corresponding supply. The ITC balance, purchase invoices, sales invoices and return figures should reconcile to the amount requested.
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Inverted-duty preparation steps
- Identify the outward supplies for which the input rate is higher than the output rate.
- Fix the tax period and extract the purchase invoices, eligible ITC and sales invoices for that period.
- Prepare the required Annex 1 invoice statement, including invoices received and issued.
- Recalculate the accumulated ITC and remove entries that do not relate to the stated period or supply.
- Compare the RFD-01 figures with the electronic credit ledger and filed returns before submission.
The principal risk is a rate or invoice mismatch. A spreadsheet total that cannot be traced to individual invoices is unlikely to withstand scrutiny, even when the business genuinely has an inverted structure.
Refund of excess money in the electronic cash ledger
The electronic cash ledger records money deposited in cash for GST payments. If the balance is higher than the amount required, the refund rules allow a claim through the relevant return. This route concerns cash already deposited; it is different from a refund of unutilised ITC in an export or inverted-duty application.
Start with the ledger closing balance for the relevant tax period and identify the deposit or payment that created the surplus. Match the amount to the return through which the claim is made. If the surplus arose from a duplicated challan, an incorrect minor head or a payment made for a liability that never arose, retain the challan and the correction trail so the officer can see why the balance is genuinely refundable.
SEZ supplies and deemed exports
Supplies to an SEZ unit or developer
RFD-01 includes supplies to an SEZ unit or developer as a refund ground. For goods, retain evidence that the goods were admitted for authorised operations and that the specified officer endorsed the supply. For services, retain the endorsement and evidence of payment. The endorsement should identify the supply covered by the invoices in the claim; a generic SEZ certificate that cannot be matched to the invoices creates a reconciliation problem.
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Deemed exports
Deemed exports are listed separately from physical exports. They are domestic supplies treated as deemed exports under the applicable GST provisions, so the file must establish the transaction’s deemed-export status rather than relying on a shipping bill. Attach the invoices, recipient and supplier details, proof of tax payment where relevant, and the prescribed supporting evidence for the particular category.
Refunds based on orders and transaction corrections
Some refunds do not arise from an export or an ITC accumulation at all. RFD-01 covers amounts arising from an assessment, provisional assessment, appeal or other order. Enter the order number and date accurately and attach the order that establishes the refundable amount.
The form also covers tax paid on supplies that were not provided, a correction to the place of supply, and excess tax payment. The evidence depends on the error: a cancelled or unfulfilled supply needs the underlying invoice and cancellation or non-supply record; a place-of-supply correction needs the corrected tax treatment and supporting contract or delivery facts; an excess-payment claim needs the return, challan and reconciliation showing the overpayment.
How to file an RFD-01 application
CBIC’s refund rules state: “Any person … claiming refund of any tax, interest, penalty, fees or any other amount paid by him, may file an application in FORM GST RFD-01 electronically through the Common Portal.” Use the following sequence to prevent a category error.
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- Choose the ground. Select the RFD-01 reason that matches the event: export without payment of tax, inverted-duty ITC, SEZ supply, deemed export, an order, a transaction correction or another listed ground. Do not select an export reason merely because the customer is outside India.
- Fix the tax period. Use the period for which the invoices, ITC, turnover, payment or order applies. Keep separate periods in separate calculations where the form requires it.
- Assemble the category-specific statement. Export claims need shipping, invoice, manifest or remittance data; inverted-duty claims need Annex 1; SEZ claims need endorsement; order claims need the order; cash-ledger claims follow the relevant return route rather than this general application.
- Reconcile the electronic records. Match the claim with the filed return, electronic credit or cash ledger, customs data where applicable, and the invoices listed in the attachment.
- Upload evidence and submit electronically. Preserve the acknowledgement and the submitted statement. An officer may issue FORM GST RFD-02 after scrutiny or FORM GST RFD-03 if the application is deficient.
- Respond to a deficiency precisely. Correct the stated mismatch or missing document, then resubmit the claim in the manner required for the deficiency communication. Do not silently change the refund ground or tax period.
Documents and certificates: what changes by claim type
| Claim | Documents to organise before filing | Checks that commonly decide acceptance |
|---|---|---|
| Export goods, no IGST | Invoices, shipping bills or bills of export, bond/LUT details, ITC records and Rule 89 turnover calculation | Invoice-to-shipping match, correct period, eligible net ITC and adjusted-total-turnover calculation |
| Export services, no IGST | Invoices, contract or service records, bank-realisation certificates or foreign-inward-remittance evidence, ITC and turnover records | Remittance linked to invoices and service turnover included in the formula |
| Export goods, IGST paid | Shipping bill, invoice, export manifest/report confirmation and return data | Manifest filed, valid return, required authentication and corrected customs/return mismatches |
| Inverted duty | Annex 1, purchase and sales invoices, ITC ledger and rate analysis | Input rate higher than output rate and every amount traceable to invoices |
| SEZ supply | Invoices, authorised-operations admission evidence, specified-officer endorsement and service-payment evidence where applicable | Endorsement identifies the claimed supplies |
| Order or correction | Relevant order, original and corrected invoices, returns, challans and transaction records | Claim equals the amount established by the order or correction |
The ₹2 lakh certificate threshold
For specified refund claims above ₹2 lakh, review whether a certificate from a chartered accountant or cost accountant is required to establish that the incidence of tax was not passed on. The rules contain statutory exceptions, so the threshold is not a universal requirement for every application. Check the exception that applies to the chosen refund ground and retain the certificate, or the reason it is not required, with the file.
Frequent rejection and delay points
- Wrong ground: An excess cash balance is filed as an ITC refund, or an order-based correction is filed as an export.
- Shipping-bill mismatch: The number or invoice value differs between customs data and GSTR-1.
- Missing manifest: An IGST-paid export is otherwise complete but the export manifest or report has not been filed.
- Invalid return: The return required for Rule 96 processing was not furnished correctly.
- Authentication incomplete: Required Aadhaar authentication or another prescribed authentication step remains pending.
- Untraceable ITC: The claim total cannot be tied to purchase invoices, the credit ledger and the stated period.
- Unsupported SEZ status: The endorsement does not show authorised operations or cannot be matched to the invoices.
- Order omitted: An order-based amount is claimed without the order reference or with a figure different from the order.
- Certificate overlooked: A claim above ₹2 lakh is submitted without checking the non-passing-on certificate requirement and its exceptions.
A practical decision test before submission
Ask four questions in order: What event created the amount; is the amount cash or unutilised ITC; does the claim belong in the relevant return or in RFD-01; and which document independently proves the event? If the answers are “excess deposit,” “cash,” “relevant return” and “cash-ledger reconciliation,” it is not an export or inverted-duty RFD-01 claim. If the answer is “zero-rated export,” decide next whether IGST was paid. If the answer is “input rates higher than output rates,” prepare the inverted-duty Annex 1 rather than an export statement. This classification prevents most downstream mismatches.
The Bottom Line
GST refund success depends less on choosing a broad “refund” option than on matching the cause, route and evidence: Rule 89 for unutilised export ITC, Rule 96 for qualifying IGST-paid exports, Annex 1 for inverted duty, the relevant return for excess cash, and RFD-01 for SEZ, deemed-export, order and correction claims.
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