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GST Refund on Export of Goods Without Payment of Tax

A comprehensive guide on GST refund on export of goods without payment of tax, covering LUT/bond requirements, documentation, and the refund process.

18 Aug 20264 min read

Export of goods without payment of tax is a zero-rated supply under GST. Exporters can claim a refund of accumulated Input Tax Credit (ITC) on such exports. This comprehensive guide explains the process, documentation, and compliance requirements.

Understanding Zero-Rated Exports

What Is a Zero-Rated Supply?

Exports of goods or services are treated as zero-rated supplies under GST. This means:

  • No GST is payable on the export
  • The exporter can claim a refund of ITC on inputs used for exports

Export Without Payment of Tax

An exporter can export goods without payment of tax by:

  • Furnishing a Letter of Undertaking (LUT)
  • Furnishing a bond

Letter of Undertaking (LUT) vs. Bond

AspectLUTBond
Who Can FurnishRegistered persons with good compliance recordAny registered person
ValidityUsually one financial yearSpecific to the shipment
DocumentationSimpleMore detailed
Bank GuaranteeNot requiredMay be required

Refund Eligibility

Who Is Eligible?

Exporters who have:

  • Exported goods without payment of tax
  • Furnished LUT or bond
  • Accumulated ITC on inputs used for exports
  • Received the export proceeds in foreign exchange

What Can Be Refunded?

Refund of unutilised Input Tax Credit on inputs used for the export of goods.

Documentation Requirements

For Export Refunds

  • Printout of FORM GST RFD-01A and ARN printout
  • GSTR-3B/GSTR-3 printout of the particular month
  • Statement-2 as per Rule 89(2)(c)

Foreign Exchange Proof

  • Foreign Inward Remittance Certificate (FIRC)
  • Bank Realisation Certificate (BRC)

Shipping Bill

  • Shipping Bill (for goods exports)
  • Bill of Lading or Airway Bill

For Claims Exceeding ₹2 Lakhs

  • A Chartered Accountant's certificate to prove no unjust enrichment

Refund Process

Step 1: Export Goods

Export the goods without payment of tax under LUT or bond.

Step 2: File GSTR-1 and GSTR-3B

File GSTR-1 with details of exports (zero-rated supplies) and GSTR-3B.

Step 3: Accumulate ITC

Accumulate ITC on inputs used for exports.

Step 4: File Refund Application

File FORM GST RFD-01 for refund of accumulated ITC.

Step 5: Submit Documentation

Submit all required documents, including:

  • RFD-01A
  • GSTR-3B printout
  • Statement-2
  • FIRC/BRC
  • Shipping Bill

Step 6: Receive Refund

Upon sanction, the refund is credited to the bank account.

Statement-2: Rule 89(2)(c)

Statement-2 is the statement of invoices relating to export of goods or services. It contains:

  • Invoice-wise details of exports
  • Details of ITC claimed
  • Calculation of refund amount

Time Limits

Filing Deadline

Refund claims must be filed within two years from the relevant date.

Processing Time

Interest on delayed refund is payable under Section 56 of the CGST Act.

Unjust Enrichment

What Is Unjust Enrichment?

Unjust enrichment occurs when the burden of tax has been passed on to the customer. In such cases, refund may be denied.

For Exports

For exports, unjust enrichment does not apply as the tax burden is not passed on to a domestic customer.

Common Pitfalls

Pitfall 1: Incomplete Documentation Missing documents lead to deficiency memos and delays.

Pitfall 2: Incorrect Statement-2 Errors in Statement-2 lead to incorrect refund calculation.

Pitfall 3: Missing FIRC/BRC Foreign exchange proof is essential for export refunds.

Pitfall 4: Time-Barred Claims Claims filed after two years are time-barred.

Pitfall 5: LUT Not Furnished LUT must be furnished before export.

Best Practices

Furnish LUT in Advance: Furnish LUT before exporting.

Maintain Documentation: Keep all export documents ready.

File GSTR-1 and GSTR-3B Timely: Timely filing is essential for refund claims.

Reconcile Regularly: Reconcile export invoices with shipping bills.

Track Foreign Exchange: Ensure export proceeds are received within the prescribed time.

Seek Professional Guidance: Export refunds have complexities; professional advice is recommended.

Export of goods without payment of tax under LUT allows exporters to claim refund of accumulated ITC. By maintaining proper documentation and filing within the prescribed time, exporters can claim refunds efficiently.

Need help with export refunds? Our GST experts provide comprehensive advisory and support.

📧 Email: office@anujdesaiassociates.com 📞 Phone: 9619456656 🌐 Website: https://anujdesaiassociates.com 🔗 LinkedIn: linkedin.com/in/ca-anuj-desai-122547230

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