Answer

GST

Turnover figures questioned in an ITC refund

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  1. Facts

    ITC refund on exports under LUT uses a formula: turnover of zero-rated supplies times net ITC divided by adjusted total turnover. Officers check these figures against returns. Errors here commonly lead to RFD-08.

  2. Provisions and law

    • Rule 89(4), CGST Rules 2017Formula for refund of ITC on zero-rated supplies without payment of tax
    • Rule 92(3), CGST Rules 2017Before rejecting a refund wholly or partly, a notice in RFD-08 is issued and the applicant replies in RFD-09 within 15 days
  3. Analysis

    Example: zero-rated turnover Rs 50 lakh, adjusted total turnover Rs 80 lakh, net ITC Rs 8 lakh. Maximum refund is 50 / 80 x 8 = Rs 5 lakh. If the officer included exempt supplies differently or took turnover of a different period, show a reconciliation with GSTR-1 and GSTR-3B for the same period. Turnover of goods exports may also be capped by rule.

  4. Conclusion

    1. Recompute the formula with period-wise return data
    2. Reconcile turnover with GSTR-1 and GSTR-3B
    3. Explain any difference in the RFD-09
    4. Accept the corrected figure if the officer is right

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