GST
Turnover figures questioned in an ITC refund
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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.
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
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.
Conclusion
- Recompute the formula with period-wise return data
- Reconcile turnover with GSTR-1 and GSTR-3B
- Explain any difference in the RFD-09
- Accept the corrected figure if the officer is right
A Savvy can do this for you
Reply to refund deficiency memo RFD-03 and notice RFD-08
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