GST Refund Filing Updates: Changes for Export, SEZ & Deemed Export Categories

The Goods and Services Tax Network (GSTN) has recently made significant updates to the GST refund filing process as of May 8, 2025. These changes aim to simplify and streamline the refund process for businesses, particularly in specific categories such as exports, supplies to SEZ units, and deemed exports. Find more information about these changes and what it means to GST taxpayers in this article.

Categories Affected by the New Refund Filing Process

The GSTN has made changes to the refund filing process for the following categories:

• Export of Services with Payment of Tax
• Supplies Made to SEZ Units/SEZ Developers with Payment of Tax
• Refund by Supplier of Deemed Export
• Refund by the Recipient of Deemed Export

The changes made to these categories, as they simplify the filing process, making it more efficient and easier to track refunds. Let’s dive into the changes.

Key Changes in Refund Filing Procedure (For Specified Categories)

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

Previously, taxpayers had to specify the tax period (From and To) when filing a refund application. With the latest update, this requirement has been removed for the affected refund categories. Taxpayers can now directly proceed with selecting their refund category and initiate the refund application without needing to select specific tax periods.

2. Mandatory Return Filing Prior to Refund Application

Before applying for a refund, taxpayers must ensure that all returns (such as GSTR-1, GSTR-3B, etc.) due up to the date of the refund application are filed. This ensures that all necessary information is available for accurate processing of refunds.

3. Transition to Invoice-Based Filing

The refund filing process has shifted from being tax period-based to invoice-based filing. This means that taxpayers can now upload eligible invoices directly and claim refunds accordingly. The following statements apply to specific categories:

• Statement 2: For Export of Services with Payment of Tax
• Statement 4: For SEZ Supplies with Payment of Tax
• Statement 5B: For Supplier’s Application in Deemed Exports

4. Locking of Invoices After Upload

Once invoices are uploaded as part of a refund application, they are locked and cannot be amended. This ensures that there is no further modification of data after the refund application is submitted. If the refund application is withdrawn or a deficiency memo is issued, only then will the invoices be unlocked for future claims.

Below, we have attached the official attachment released by the GST advisory regarding these changes.

Detailed Update for “Refund by Recipient of Deemed Export”

Below, we have given the list of changes in the GST refund filing process for the ‘refund by recipient of Deemed export’ category.

1. Chronological Filing Requirement Removed

Under the category of refund by the recipient of deemed export, there is no longer a need to file refund applications in chronological order of the tax periods. This eliminates the previous requirement to select “From Period” and “To Period” when applying for a refund.

2. Pre-requisite: All Returns Must Be Filed

As with other refund categories, taxpayers must ensure that all returns (GSTR-1, GSTR-3B, etc.) due up until the date of filing the refund application are submitted.

3. Revised “Amount Eligible for Refund” Table

The refund application includes a revised table called “Amount Eligible for Refund,” which provides a clear breakdown of the refund amounts based on uploaded invoices. The columns in this table are as follows:

• Col. 1: Balance in ECL – This column auto-populates the balance available in the Electronic Credit Ledger (ECL) at the time of filing the refund application.
• Col. 2: Net ITC of Deemed Exports – This auto-populates the amount of Input Tax Credit (ITC) claimed based on invoices uploaded in Statement 5B.
• Col. 3: Refund Amount as per Uploaded Invoices – This shows the total ITC claimed from uploaded invoices and is editable.
• Col. 4: Eligible Refund Amount – The maximum ITC available for refund, auto-calculated based on the debit order specified in the circular.
• Col. 5: Refund Amount Not Eligible – This shows any difference between the claimed ITC and the ITC available in the ECL.

4. Functionality Enhancement to Maximize Refund Claims

GSTN has also improved the refund filing functionality. Taxpayers can now claim a larger refund amount based on the uploaded invoices, regardless of the balance available under each specific head in the Electronic Credit Ledger. The system compares the total ITC claim with the available balance to maximize the refund.

Find below the GST official announcement regarding these specific GST refund filing procedure change,

Key Takeaways for GST Taxpayers

• Invoice-Based Filing: Refunds can now be claimed based on invoices, not tax periods, simplifying the process.
• No Tax Period Selection: The requirement to select a specific tax period ('From' and 'To') has been removed for certain refund categories.
• File All Returns: Ensure that all due returns (GSTR-1, GSTR-3B, etc.) are filed before submitting a refund application.
• Invoice Locking: Once uploaded, invoices are locked for future amendments and cannot be used in other refund applications unless the refund is withdrawn or a deficiency memo is issued.
• Revised Refund Calculation: The new refund application tables reflect detailed calculations for eligible refunds, ensuring transparency.

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FAQs

1. What are the latest changes in the GST refund filing process?

The GSTN has removed the need to select 'From' and 'To' tax periods and introduced invoice-based filing for categories like exports, SEZ supplies, and deemed exports.

2. Which refund categories are affected by the recent GST update?

The changes apply to Export of Services with Tax, Supplies to SEZ units with Tax, and Deemed Export refunds (by supplier and recipient).

3. Is it mandatory to file all returns before applying for a refund?

Yes, taxpayers must file all returns such as GSTR-1 and GSTR-3B before submitting a refund application.

4. Can uploaded invoices be modified after submission?

No, once invoices are uploaded for a refund application, they are locked and cannot be amended unless the application is withdrawn or a deficiency memo is issued.

5. What’s new in the refund filing for recipients of deemed exports?

Chronological filing is no longer required, and a revised “Amount Eligible for Refund” table provides a detailed breakdown of ITC and refund eligibility.

DINESH P Expert

Updated on: June 2nd, 2025