Answer

GST

Time limit for refund on export of services

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  1. Facts

    Refund must be filed within two years from the relevant date under Sec 54(1). For export of services, the relevant date is the date of receipt of payment in foreign exchange where payment comes after the invoice, or the invoice date where payment was received in advance.

  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

    If you raised an invoice on 10 March 2024 and received payment on 5 May 2024, the two years run from 5 May 2024, so file by 4 May 2026. The portal does not stop late claims, but the officer will reject them as time barred. Track the relevant date per invoice, not per quarter, because one late invoice can sit inside an otherwise valid claim.

  4. Conclusion

    1. List each export invoice with its payment receipt date
    2. Mark invoices nearing two years
    3. File the claim for older invoices first
    4. Do not mix time barred invoices into a claim

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

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