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GST Compliance – Refund of ITC on Exports (Without IGST)

Refund of ITC on Exports of Goods/Services – Without Payment of Tax (Accumulated ITC)

Edition: September 2025
Disclaimer: This manual is for compliance facilitation. It does not substitute statutory provisions, notifications, or circulars. Taxpayers must verify with the CGST/SGST Acts, Rules, and GSTN updates.


✍️ Preface

Exporters supplying goods or services without payment of IGST under LUT/Bond are eligible to claim refund of the accumulated Input Tax Credit (ITC). Such refunds are filed in Form GST RFD-01. This report explains the law basis, portal filing process, FAQs, and compliance checklist.


⚖️ 1. Law Basis

  • Section 16, IGST Act, 2017 – Zero-rated supplies.

  • Section 54, CGST Act, 2017 – Refund of tax.

  • Rule 89(4), CGST Rules, 2017 – Refund of ITC for zero-rated supplies without payment of IGST.


🛠️ 2. Step-by-Step Process – Filing Refund Application (RFD-01)

  1. Login at www.gst.gov.inServices > Refunds > Application for Refund.

  2. Select refund type: Exports of Goods/Services – without Payment of Tax (accumulated ITC).

  3. Select Tax Period → Click CREATE REFUND APPLICATION.

  4. If NIL refund → Select “Yes” → Declaration → File with DSC/EVC.

  5. For refund claim:

    • Download Offline Utility → Fill Statement 3 with invoice/shipping bill/FIRC/BRC details.

    • Upload JSON file on GST Portal.

    • Validate & Calculate → Errors (if any) corrected via Invalid Document download/re-upload.

    • System auto-computes refund eligibility in Statement 3A.

  6. Enter bank account details → Upload supporting documents (max 10 files, ≤ 5 MB each).

  7. Provide RFD-11 LUT Reference No. if applicable.

  8. Preview refund application (PDF).

  9. Submit → File with DSC/EVC.

  10. ARN generated → Acknowledgement sent via SMS/Email.

  11. Debit entry created in Electronic Credit Ledger (ECL).


📌 3. Key Features

  • Refund can be filed for multiple tax periods (even across FYs) in one application.

  • NIL refund also allowed for one/multiple periods.

  • Statement 3 mandatory → validated with GSTR-1 data.

  • Amendments possible via re-upload of Statement 3.

  • Saved applications retained for 15 days.

  • Validations applied: Refund ≤ Balance in ECL and ≤ Maximum Refund in Statement 3A.

  • Supporting documents: invoices, shipping bills, FIRCs/BRCs, LUT copy.


4. FAQs (with Basis)

Q1. How to claim refund of ITC on exports without IGST?
File RFD-01 with Statement 3 (invoices, shipping bill, BRC/FIRC).

Q2. Can multiple periods be combined?
Yes, across same or different FYs.

Q3. Is NIL refund filing possible?
Yes, NIL refunds can be filed for one/more periods.

Q4. Is uploading Statement 3 mandatory?
Yes, validated with GSTR-1 data.

Q5. What documents required?
Invoices, Shipping Bills, BRC/FIRC (for services), LUT reference.

Q6. What if refund not processed?
ARN generated → Application assigned to Refund Officer → Track via Track Application Status.


5. Compliance Checklist

Step Particulars Status (✔)
1 Login → Refund Application → Select Export (Without IGST)
2 Select Tax Period → Create Refund Application
3 Download & fill Statement 3 → Upload JSON
4 Validate statement → Correct errors (if any)
5 Enter bank account + LUT details
6 Upload supporting docs
7 Preview & File with DSC/EVC
8 ARN generated → Check SMS/Email
9 Track refund status via GST Portal

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