Major Updates in Deemed Export Refund Filing Under GST

The GSTN has rolled out important changes in the refund filing process under the category “On account of Refund by Recipient of Deemed Export”. These changes aim to simplify the application process, improve refund accuracy, and allow greater flexibility for taxpayers.

Key Highlights of the Update:

1. No More Chronological Filing

Taxpayers are no longer required to file refund applications in chronological order of tax periods. This means that the “From Period” and “To Period” fields have been removed from the application process under this category. Taxpayers can now file based on invoice data without following a strict monthly order.

2. Return Filing Compliance Mandatory

All returns, including GSTR-1 and GSTR-3B, must be filed up to the date of the refund application. Incomplete return filing will result in rejection or processing delays.

3. Revised Table: ‘Amount Eligible for Refund’

The refund application table under this category has been enhanced to provide better clarity and auto-population of data. Here’s a breakdown of the revised columns:

• Column 1: Balance in ECL at Time of Filing
  Auto-populated values showing available balance under different heads (IGST, CGST, SGST/UTGST) in the Electronic Credit Ledger (ECL).
• Column 2: Net ITC of Deemed Exports
  Auto-calculated based on invoices submitted in Statement 5B, reflecting ITC amount claimed for deemed export supplies.
• Column 3: Refund Amount (As per Invoices)
  Auto-filled total ITC amount claimed from uploaded invoices. This field is downward editable, giving taxpayers some flexibility.
• Column 4: Eligible Refund Amount
  Auto-calculated maximum permissible refund based on available ITC and the debit order guidelines from Circular No. 125/44/2019-GST dated 18.11.2019.
• Column 5: Refund Amount Not Eligible (Due to Insufficient ECL Balance)
  Reflects the shortfall in ITC availability across heads, indicating any part of the claim that cannot be processed due to insufficient credit.

4. Enhanced Refund Claim Functionality

The system has been updated to maximize the refund claim based on uploaded invoices, even if sufficient balance is not available under individual heads in the ECL. The functionality will consider total claimable ITC across all heads and match it with the total available ITC balance, ensuring that taxpayers get the highest possible eligible refund.

Final Thoughts

This move from GSTN is a welcome relief to exporters and deemed export recipients, who often faced procedural bottlenecks due to tax period restrictions. The switch to a more data-driven and invoice-linked approach promises better efficiency and quicker refund processing.

 Notification Reference: GSTN
  08/05/2025