GST Refund Filing Changes: Export, SEZ & Deemed Exports

Introduction

The Goods and Services Tax Network (GSTN) introduced key updates to the GST refund filing process on May 8, 2025. These revisions are designed to simplify and streamline the procedure, especially for businesses involved in exports, supplies to SEZ units, and deemed exports. This article outlines the details of these changes and their impact on GST taxpayers

Categories Affected by the Revised GST Refund Filing Process

The Goods and Services Tax Network (GSTN) has introduced changes to the refund filing process, specifically impacting the following categories:

Export of Services with Payment of Tax
Supplies Made to SEZ Units/SEZ Developers with Payment of Tax
Refund Applications by Suppliers of Deemed Exports
Refund Applications by Recipients of Deemed Exports

These updates are intended to simplify the filing procedure, improve efficiency, and make it easier for taxpayers to track their refund status

Key Changes in Refund Filing Procedure (Applicable to Specific Categories)

1. Elimination of ‘From’ and ‘To’ Tax Period Requirement

Previously, refund applications required taxpayers to specify a tax period range. With the new update, this requirement has been removed for the affected categories. Taxpayers can now directly choose the relevant refund category and proceed with the application—no need to enter specific tax periods.

2. Mandatory Return Filing Before Refund Application

Taxpayers must ensure that all applicable returns (e.g., GSTR-1, GSTR-3B) are filed up to the date of the refund application. This is necessary for the system to validate and process refund claims accurately.

3. Shift to Invoice-Based Filing

The process has transitioned from tax period-based to invoice-based filing. Taxpayers now upload eligible invoices directly to claim refunds. The following statement formats apply to each category:

Statement 2: For Export of Services with Payment of Tax
Statement 4: For SEZ Supplies with Payment of Tax
Statement 5B: For Supplier Refund Claims in Deemed Exports

4. Invoice Locking Post Submission

Once invoices are uploaded as part of a refund application, they are locked and cannot be modified. This ensures data integrity during the refund process. Invoices will only be unlocked if the refund application is withdrawn or if a deficiency memo is issued

Detailed Update: Refund by Recipient of Deemed Exports

The Goods and Services Tax Network (GSTN) has introduced several key changes to streamline the refund filing process for recipients of deemed exports. Below are the major updates applicable to this category:

1. Removal of Chronological Filing Requirement

Taxpayers are no longer required to file refund applications in the chronological order of tax periods. The earlier mandate to specify a “From Period” and “To Period” when filing a refund claim has been eliminated, offering greater flexibility.

2. Pre-Condition: Filing of All Returns

Before submitting a refund application, taxpayers must ensure that all relevant GST returns (such as GSTR-1 and GSTR-3B) due up to the date of application are filed. This is necessary for the system to process and validate refund claims accurately.

3. Introduction of Revised “Amount Eligible for Refund” Table

A newly structured table titled “Amount Eligible for Refund” has been introduced within the application to provide a transparent calculation of the refund amount based on uploaded invoices. The table includes the following columns:

Column 1: Balance in ECL – Auto-populates the available balance in the Electronic Credit Ledger at the time of application.
Column 2: Net ITC of Deemed Exports – Reflects the Input Tax Credit (ITC) claimed from invoices uploaded in Statement 5B.
Column 3: Refund Amount as per Uploaded Invoices – Displays the total ITC amount from uploaded invoices. This field is editable.
Column 4: Eligible Refund Amount – Automatically calculated as the maximum refundable ITC, based on the prescribed debit hierarchy from the applicable circular.
Column 5: Refund Amount Not Eligible – Shows the difference between the claimed ITC and the ITC available in the Electronic Credit Ledger.

4. Enhanced Functionality for Maximizing Refund Claims

GSTN has upgraded the system to allow higher refund claims. Taxpayers can now claim the total eligible refund amount based on invoices uploaded, even if the available balance under specific heads (e.g., CGST, SGST, IGST) in the Electronic Credit Ledger is insufficient. The system automatically evaluates the total ITC and distributes debits optimally to maximize the refundable amount

Key Takeaways for GST Taxpayers

Invoice-Based Refund Filing
Refund claims are now processed based on individual invoices rather than tax periods, streamlining the application process.
No Tax Period Selection Required
The mandatory selection of ‘From’ and ‘To’ tax periods has been removed for specified refund categories.
Mandatory Filing of Returns
All applicable GST returns (e.g., GSTR-1, GSTR-3B) must be filed up to the date of refund application to proceed with the claim.
Invoice Locking Mechanism
Once invoices are uploaded with a refund application, they are locked and cannot be modified or reused—unless the application is withdrawn or a deficiency memo is issued.
Updated Refund Calculation Tables
Revised tables in the refund application provide a transparent, detailed view of eligible refund amounts, based on uploaded invoices and ledger balances

Simplify GST Refund Filing with IndiaFilings

Navigating GST refund procedures can be complex—but with IndiaFilings, you don’t have to do it alone. Our expert team stays updated with the latest GST regulations to ensure accurate, timely, and hassle-free refund claims. Whether you’re applying for refunds on exports, SEZ supplies, or deemed exports, we handle the documentation and compliance—so you can focus on your business while we maximize your refund

About the Author

Rohit

Rohit is an experienced legal writer who excels at translating complex legal concepts into clear, actionable insights. His work equips entrepreneurs with the knowledge they need to confidently navigate legal requirements and successfully launch, manage, and grow their businesses

June 17, 2025