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Indian exporters generally have two GST refund routes: export without paying IGST and claim eligible unutilised input tax credit, or pay IGST on the export and seek a refund of that tax, subject to the rules and eligibility for the transaction. The route determines the records and process to check when a refund is delayed. For applicable refund claims, CBIC’s rules use FORM GST RFD-01; the IGST refund route for exported goods follows a distinct customs-and-return data flow. A submitted application alone does not establish that every required document or data match is in place.
First identify which export refund you are claiming
Exports are generally treated as zero-rated supplies under India’s GST framework. “Zero-rated” is not simply another word for “exempt”: the two export routes below have different tax and refund mechanics. The GST Portal and CBIC explain the broad alternatives, but eligibility and applicable rules depend on the transaction and current law. They should not be treated as an unconditional choice for every exporter or shipment. See the GST Portal’s GSTR-1 guide and CBIC Circular No. 125/44/2019-GST.
| Point to compare | Export without payment of IGST | Export with payment of IGST |
|---|---|---|
| Tax paid on export | No IGST is paid under this route, subject to applicable bond or LUT requirements. | IGST is paid, subject to the rules and eligibility that apply. |
| Refund sought | Eligible unutilised input tax credit (ITC). | IGST paid on the export. |
| Process emphasis | Bond/LUT compliance, eligible credit, refund application and supporting evidence. | Export, GST return and customs data flow; consistency of export records is important. |
| What to investigate first if delayed | Application status and evidence, the credit calculation, export reporting and LUT or bond compliance. | Whether export details in the return and customs records match and are available to the refund process. |
This is a process-level comparison, not advice that a particular exporter qualifies for either route. Confirm the current requirements for the transaction before filing or changing the route.
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Under this route, the exporter does not pay IGST on the export, subject to the applicable bond or Letter of Undertaking (LUT) requirements, and may claim a refund of eligible unutilised ITC. The refund is not a refund of the export’s full invoice value or of every credit balance: the amount depends on the rules and the eligible credit for the claim. CBIC’s refund rules set out the calculation for refunds of ITC on zero-rated supplies made without payment of tax, along with application and evidence requirements.
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An LUT is a Letter of Undertaking. The GST Portal provides a guide for furnishing one, and CBIC’s rules describe bond/LUT procedures and export-proceeds conditions. The cited PDF is a version of the CGST Rules updated to 13 September 2018, so it is not a safe basis for assuming that a detailed deadline or requirement remains unchanged. Check the current amended rule for the relevant export and period. The portal’s LUT filing guide and the 2018 rules PDF are useful for understanding the route, with that date limitation in mind.
Route 2: export with payment of IGST
Under this route, IGST is paid on the export and a refund of the tax paid may be sought, subject to applicable rules. The refund flow for IGST paid on exported goods is distinct from the ordinary RFD-01 process: export, return and customs information are relevant to the flow. Do not assume that every exporter seeking a refund should file RFD-01. Instead, identify the route actually used and investigate the corresponding records.
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Prepare records before filing
For goods, the export invoice, shipping bill and GST return reporting need to describe the same export consistently. CBIC’s refund rules condition the relevant export-of-goods refund application on delivery of the export manifest or export report. If shipping-bill details were not available when GSTR-1 was filed, the GST Portal says they can be added later through the amendment section of a subsequent GSTR-1. That is a way to update missing details; it is not a reason to leave an identified discrepancy unresolved.
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Keep a claim-period reconciliation that lets you trace each relevant invoice and shipment across the GST return and customs records. Before filing, check that the values and identifiers used in those records correspond, and that the applicable return information has been filed. For an ITC refund, also be able to support the credit claimed and the calculation under the applicable rules. For an IGST-paid export, focus on whether the data required for the customs-and-return flow has been reported and can be matched.
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- Export records: retain the export invoice and, for goods, the related shipping-bill information and evidence relevant to the claim.
- Return reporting: check the export entries in GSTR-1 and whether relevant amendments or later-period information have been filed.
- Tax route: record whether the export was made with IGST payment or under the no-payment route, and retain the applicable tax and LUT/bond records.
- Claim support: assemble the evidence required for the particular refund category, rather than assuming one document set covers every claim.
File through the route that applies
CBIC’s refund rules provide for electronic FORM GST RFD-01 applications for refund claims other than the specifically excluded export IGST refund route. The rules describe supporting evidence by refund category, so the documents needed depend on what is being claimed. Filing RFD-01 is a step in the process, not proof that the claim is complete, supported or ready for sanction.
- Classify the claim. Confirm whether it is a claim for eligible unutilised ITC on exports made without payment of tax, or a refund of IGST paid on exported goods. Check the current rule and eligibility for the transaction.
- Complete the reporting and evidence checks. Reconcile invoice and export details with the relevant return and customs records. For the no-payment route, confirm the applicable LUT or bond compliance and prepare support for the ITC and refund calculation.
- Use the corresponding filing flow. File RFD-01 for an applicable claim covered by that form, with the supporting evidence for its category. For the export IGST refund route for goods, follow the distinct customs-and-return data flow rather than treating RFD-01 as the universal application.
- Keep the filing trail. Retain the application or return information, the records submitted, and any subsequent clarification or deficiency communication so you can check the status and respond against the actual issue.
The official CBIC refund-rules page is the source for the RFD-01 framework and category-specific evidence requirements. Requirements can change, so confirm the current rules and portal workflow for the claim period.
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How to investigate a delayed refund
Start with the route, claim period and current portal status—not with an assumed processing deadline. A deficiency or clarification notice may point to a specific missing document or inconsistency. If the status does not explain the delay, work outward from the claim: verify filing, reconcile the export records, then check whether the issue is one the relevant CBIC guidance addresses.
- Confirm the claim type and period. Establish whether the refund is for unutilised ITC under the no-payment route or IGST paid on exported goods. Make sure you are checking the filing and export records for the correct period and shipment or invoice set.
- Read the status and communications. Check the refund status through the relevant GST or customs workflow and look for any deficiency, clarification or other notice. Note what the authority has asked for and the claim it concerns; do not treat an unexplained delay as proof of rejection or as proof that a particular document is missing.
- Reconcile invoice and shipping-bill data. Compare the relevant export invoice and shipping-bill information in the GST return with the customs records. Look for missing shipping-bill details, inconsistent identifiers or values, and return entries that do not correspond to the shipment.
- Check return information and amendments. Confirm that the applicable GSTR-1 information has been filed. If shipping-bill details were unavailable at original filing, the GST Portal’s GSTR-1 guidance allows them to be added through the amendment section of a subsequent GSTR-1. Review the later-period reporting where relevant to the discrepancy.
- Check the tax-route requirements. For a no-payment claim, verify the LUT or bond position and the ITC calculation and evidence. For an IGST-paid export, check that the export and return data needed for the distinct customs-linked refund flow are consistent.
- Compare GSTR-1 and GSTR-3B where relevant. CBIC Circular No. 37/11/2018-GST discusses discrepancies between GSTR-3B and GSTR-1 and situations where information in a later-period GSTR-1 may be relevant. Compare the returns for the periods at issue and see whether the facts fit the circular’s guidance; it is not a guarantee that a claim will be sanctioned.
- Respond to the identified problem. Submit or correct the relevant information through the applicable process and respond to a notice using the evidence it requests. Keep a copy of the correction or response and check the status again; a data correction does not by itself establish that every other condition is satisfied.
A practical mismatch checklist
| What you find | What to check | What the cited guidance supports |
|---|---|---|
| Shipping-bill details are absent from the original GSTR-1 | Whether the shipping-bill number and date were available when that return was filed, and whether the export can be matched to customs records. | The GST Portal says those details can be added in the amendment section of a subsequent GSTR-1 when they were unavailable at original filing. See the GSTR-1 guide. |
| GSTR-1 and GSTR-3B do not agree | The periods and figures involved, and whether later-period GSTR-1 information is relevant to the particular discrepancy. | Circular No. 37/11/2018-GST discusses these discrepancies and later-period information in the situations it covers; it does not promise sanction in every case. |
| A no-payment export claim has an LUT or bond concern | Whether the required LUT or bond was in place and what current rule applies to the export and period. | The circular discusses possible condonation of delayed LUT filing in appropriate circumstances. That relief is not automatic; assess the case under the applicable rule and guidance. The GST Portal’s LUT guide explains the portal process. |
| A notice identifies missing support or a deficiency | The claim category and the particular evidence or explanation requested. | CBIC’s refund rules set out evidence requirements by refund category. A generic document set cannot be assumed to satisfy every claim. |
There is no single guaranteed processing time for every route
The sources cited here do not establish one current, guaranteed end-to-end processing time for every exporter refund type. CBIC’s sectoral FAQ contains timing descriptions, but those descriptions may be historical and should not be treated as a current service guarantee without checking the applicable rule or official service standard. The CBIC Sectoral FAQs are therefore not a sound basis for promising an individual exporter when funds will arrive.
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Separate an estimated or quoted timeline from the statutory interest provision. A delay, by itself, does not establish that a particular claim qualifies for interest. First establish that the claim falls within the relevant statutory conditions and determine the applicable notified rate.
When statutory interest may apply
Section 54 of the Central Goods and Services Tax Act provides that qualifying refunds not paid within 60 days of receipt of the application can attract interest at a rate notified by the Government. For the general provision, the statutory ceiling is 6%. Certain refunds arising from an order that has attained finality have a statutory ceiling of 9%. These figures are legal limits, not average processing times, guaranteed payment dates or automatically owed rates for every delayed export refund. Eligibility and the actual notified rate must be checked against the claim’s facts and applicable notification. See CGST Act, section 54.
If you believe the conditions may be met, establish when the relevant application was received, which provision governs the refund, whether the refund is qualifying and what rate is notified for the applicable case. Do not calculate or promise an interest amount solely from the fact that 60 days have passed.
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A well-organised file makes it easier to distinguish a filing issue from an export-data mismatch or a question about eligibility. Keep records in a way that ties each claim to its route and period, rather than relying on a single refund reference without the underlying export trail.
Quick Recap
- The export invoice and, for goods, shipping-bill details and the related customs export evidence relevant to the claim.
- The GSTR-1 information for the relevant period, including any later-period amendment that added shipping-bill details or other relevant export information.
- The tax-route record: evidence of IGST payment for the paid route, or the relevant LUT/bond records for the no-payment route.
- For an ITC refund, the credit records and calculation supporting the amount claimed under the applicable refund rules.
- The RFD-01 application and supporting documents where that filing route applies, or records relating to the customs-and-return flow for an export IGST refund.
- Portal status information and copies of any deficiency, clarification or other notice, together with the response or correction submitted.
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