GST Refund Process for Deemed Export Recipients Updated
These changes simplify filing while tightening eligibility. This blog breaks down the revised rules, steps, and legal backing for Indian taxpayers and consultants.
Examples include:
- Supply of goods to Advance Authorisation or EPCG holders
- Supply to EOU (Export Oriented Units)
Recipients (not suppliers) are eligible for claiming refunds of the GST paid.
Key Updates in GST Refund for Deemed Exports
1. New Filing Advisory by GSTN (April 2025)
As per the advisory issued in April 2025 on the GST Portal:
- Table 6 of Form RFD-01 must now reflect:
- Supplier’s GSTIN
- Invoice-wise details
- Shipping bill and export data (even if supply is within India)
2. Supplier Declaration Mandatory
In line with Rule 89(1) of CGST Rules
3. Document Uploads Revised
Mandatory documents include:
- Copy of tax invoice
- Proof of deemed export supply (e.g., EPCG/AA license copy)
Expert Tip: Many applicants face rejections due to incorrect license references or missing undertakings. Always verify the notification under which deemed export benefit is claimed.
Step-by-Step Filing Guide for Deemed Export Refunds
Here’s how to file your refund as a recipient:
| Step | Action | Details |
|---|---|---|
| 1 | Login to GST Portal | Use valid GST credentials |
| 2 | Go to Refunds > Application for Refund | Select Refund on account of deemed exports |
| 3 | Fill Form RFD-01 | Use Table 6 correctly |
| 4 | Upload required docs | Invoices, supplier declaration, license, etc. |
| 5 | Submit ARN | Save and track status via ARN |
Legal Backing for Deemed Export Refunds
- Section 54 of CGST Act, 2017: Governs refund of taxes
- Rule 89(1), 89(4A), and 89(4B) of CGST Rules: Specific to deemed exports
- Notification No. 49/2017 – Central Tax dated 18.10.2017: Declares supplies covered under deemed exports
Recent clarification from CBIC (via circulars) re-emphasises the non-availment of ITC as a precondition.
What Hasn’t Changed?
- Refund must be filed within 2 years from the relevant date.
- Supplies must still be under a valid deemed export notification.
- Dual refund claim (by both supplier and recipient) is not allowed.
Why This Matters for Indian Taxpayers
Incorrect filing or duplicate refund claims may lead to DRC-07 notices or rejection of claims.
For exporters, these refunds are crucial to maintaining liquidity and working capital.
Small missteps – like uploading wrong license copies or availing ITC – can block funds for months.
FAQs
Q1. Can both supplier and recipient claim refund on the same transaction?
No. Only one party can claim. Supplier must issue a declaration if the recipient is claiming.
Q2. What is the time limit for claiming refund?
Refund must be claimed within 2 years from the relevant date (usually date of invoice or payment).
Summary
GST refund filing for deemed export recipients updated: File via RFD-01 with revised Table 6 details, mandatory supplier declaration, and strict non-ITC conditions. Know your steps to avoid rejection.