Answer

GST

Time limit for refund on export of goods

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  1. Facts

    For export of goods, Sec 54 sets the relevant date as the date the ship or aircraft carrying the goods leaves India, or the date goods pass the frontier for land exports. The claim must be filed within two years of that date.

  2. Provisions and law

    • Sec 54(1), CGST Act 2017Refund to be claimed within two years from the relevant date
    • Rule 89, CGST Rules 2017Application for refund in RFD-01 with the prescribed statements
  3. Analysis

    Goods shipped on 15 June 2024 must be in a claim filed by 14 June 2026. Exporters who batch claims once a year can lose the earliest months, so many file monthly or quarterly. Check the export date in the shipping bill and EGM data, not the invoice date.

  4. Conclusion

    1. Pick up the export date from each shipping bill
    2. List shipments nearing two years
    3. File claims at least quarterly
    4. Keep the shipping bill and EGM details with the claim

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Refund of ITC on exports without payment of tax, RFD-01

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