Compliance Pack

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

If you export without paying IGST, the GST you paid on your inputs piles up in your credit ledger.
Deadline: Within 2 years of the relevant date; for services, the later of the invoice date and the date of receipt of payment
Done in Application filed within 5 working days of complete documents; provisional 90 percent refund is due within 7 days of acknowledgement for low-risk claims; final order within 60 days
Prepared by your Savvy, checked by a CA

Valid LUT ARN for the period
Which months do you want to claim
Reconcile export invoices
RFD-01 ARN and RFD-02 acknowledgement

The law and the steps Pay and start · ₹4,999As needed (monthly, quarterly or clubbed periods within a year), + 18% GST

Sample caseTS-GST-REF-01

Refund of ITC on exports without…

Within 2 years of the relevant…

IWhat we need from you8 documents
DQuestions for you6 questions
FForms6 steps
DWhat you getRFD-01 ARN and RFD-02…

Fixed fee₹4,999+ 18% GST

Answer in brief

If you export without paying IGST, the GST you paid on your inputs piles up in your credit ledger. We work out how much of it can be refunded under the Rule 89(4) formula, prepare Statement 3 with your export invoices and remittance proof, file RFD-01 and follow it till the money reaches your bank.

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From the official sources

What the law says, and what trips people up

From the official portal's manuals and FAQs, with the source for each point.

The law

IGST Act 2017, Sec 16(3)(a)
Zero-rated supply under bond or LUT without IGST, with refund of unutilised ITCSource
CGST Act 2017, Sec 54(3) and Rule 89
Refund of unutilised ITC on zero-rated supplies made without payment of tax, applied for in RFD-01 with a statement of invoicesSource
CGST Rules 2017, Rule 89(4)
Refund = (turnover of zero-rated supply × net ITC) ÷ adjusted total turnover; export of goods value capped at 1.5 times domestic value of like goods (Notification 16/2020-CT)Source
CGST Act 2017, Sec 54(1), relevant date for services
Two-year limit; for export of services the relevant date is the later of invoice date and receipt of paymentSource
CGST Rules 2017, Rule 91(2) as amended by Notification 13/2025-CT (from 1 October 2025) and Instruction 06/2025-GST
90 percent provisional refund in RFD-04 within 7 days of acknowledgement on system risk assessment; officer may withhold in high-risk cases with reasonsSource
Notification 14/2025-CT (17 September 2025)
No provisional refund to persons without Aadhaar authentication under Rule 10B, and to suppliers of areca nuts, pan masala, tobacco and essential oilsSource
CBIC Circular 37/11/2018-GST
BRC or FIRC needed for services but not goods; one deficiency memo per application; claims can club periods but not across financial years; lower of invoice and shipping bill value sanctionedSource
CGST Act 2017, Sec 54(7) and Sec 56
Final order within 60 days of a complete application; interest at 6 percent if refund is delayed beyond thatSource
Government fee
No government fee for filing RFD-01. Minimum refund is ₹1,000 per head for credit ledger refunds. Source: https://icaiahmedabad.com/pdf/Study-Presentation/Mihir-Modi_GST-Refund-Practical-Issues_240522.pdf
Late fee or penalty
No late fee, but claims after 2 years from the relevant date are time barred. Interest at 6 percent is payable by the department if the refund is not paid within 60 days. Source: https://caclub.in/refund-of-unutilized-itc-under-gst-process-timelines-and-key-aspects/

On the portal

Login at gst.gov.in > Services > Refunds > Application for Refund
Select 'Refund of unutilized ITC on account of exports without payment of tax' and the period (from and to month within one financial year)
Download Statement 3 template, fill export invoices with FIRC or shipping bill details, upload
Enter turnover of zero-rated supply, adjusted total turnover and net ITC; system computes maximum refund; enter claim by tax head
Upload supporting documents (Annexure B purchase register, FIRC, LUT, reconciliation)
Select validated bank account, sign with DSC or EVC; note the ARN
Services > Refunds > Track Application Status to follow RFD-02, RFD-03, RFD-04, RFD-06

What trips people up

Deficiency memo RFD-03 issued
Only one deficiency memo is allowed per application; file a fresh application with corrections and the original ARN referenceSource
Export invoices raised before LUT
Seek condonation and ex post facto LUT acceptance under Circular 37/11/2018-GST before filingSource
Refund formula does not match return data
Reconcile GSTR-1, GSTR-3B, books and ledger before filing; correct GSTR-1 errors through amendmentSource
Bank account fails PFMS validation
Update the account in registration and re-initiate validationSource
Claim spans two financial years
Split claims by financial yearSource
Provisional refund not given
Check Aadhaar authentication and whether earlier refund matters are pending in appeal or SCN; these block provisional refundSource

People ask

How soon do I get the money?

Low-risk claims get 90 percent provisionally within 7 days of acknowledgement from 1 October 2025; the balance comes with the final order.Source

Do I need BRC or FIRC?

For services yes; for goods, shipping bill and EGM details are used instead.Source

Can I claim three months together?

Yes, periods can be clubbed but not across financial years.Source

What is the time limit for services?

Two years from the later of invoice date and payment receipt.Source

What if the department is late?

Interest at 6 percent is payable if the refund is not paid within 60 days.Source

IDFD

How we solve it: 4 steps

Every line tracked live.

Step 1 of 4 · What we need from you

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Ready0 / 8

Valid LUT ARN for the period
Export invoices for the period
FIRC, BRC or bank remittance advice
Shipping bills and EGM detailsOptional
Purchase register in Annexure B format
GSTR-1, GSTR-3B and 2B for the period
Bank account validated on portal
Aadhaar authentication status

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₹4,999

₹4,999 + ₹899.82 GST = ₹5,898.82

As needed (monthly, quarterly or clubbed periods within a year). Delivered in Application filed within 5 working days of complete documents; provisional 90 percent refund is due within 7 days of acknowledgement for low-risk claims; final order within 60 days. Due: Within 2 years of the relevant date; for services, the later of the invoice date and the date of receipt of payment

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