GST & Indirect Tax

GST Refund for Export of Services Without Payment of Tax: RFD-01 Checklist

Finin2min GST Desk·June 2026·8 min readEXPORT REFUND

Reviewed by CA Nikhil Gupta · Last reviewed 19 June 2026

Exporting services without charging IGST under LUT can create accumulated input tax credit. That credit is valuable only if the refund file is clean: export invoices, LUT, returns, ITC, remittance proof and refund period must all speak the same language.

Export of Services: Five Conditions to Test

A service is not automatically an export just because the customer is outside India. Under the IGST framework, export of services requires five checks: supplier located in India, recipient located outside India, place of supply outside India, payment received in convertible foreign exchange or permitted Indian rupees, and supplier and recipient not merely being establishments of a distinct person. Miss any one of these checks and the GST position can change completely.

For the connected rule or filing step, see GST Refund Route and RFD-01 Checklist.

Condition	What to verify	Common evidence
Supplier in India	Your registered place/fixed establishment is in India	GST registration, invoice profile, business address.
Recipient outside India	Customer is located outside India	Contract, purchase order, billing details.
Place of supply outside India	Section 13 result should point outside India	Service classification memo, client scope, evidence of performance.
Payment condition	Foreign exchange / permitted INR receipt	FIRC/BRC, bank advice, remittance note.
Not same establishment	Supplier and recipient are not merely establishments of same person	Group structure, branch/subsidiary analysis.

Refund Workflow Under GST: What the Portal and Law Expect

Most GST refund claims are filed electronically in Form GST RFD-01 through the GST portal. Rule 89 governs the refund application, Rule 90 covers acknowledgement and deficiency memo mechanics, and Section 54 contains the core refund framework including the 60-day order timeline for complete applications. For export refunds without payment of tax, the GST portal guide also requires choosing the appropriate refund category and furnishing export details through the utility/online workflow.

Stage	Form / record	Control point
Before filing	Return filing and ledger reconciliation	Applicable returns should be filed; ledgers and turnover working should match books.
Application	GST RFD-01	Choose correct refund category and period; upload required statements.
Acknowledgement	GST RFD-02	If application is complete, acknowledgement is generated and statutory timelines start.
Deficiency	GST RFD-03	If deficiency memo is issued, a fresh application normally has to be filed.
Order / sanction / rejection	RFD order trail and ledger impact	Track sanctioned amount, rejection reasons and re-credit where applicable.

Documents to Prepare Before RFD-01

LUT acknowledgement for the relevant financial year.
Export invoices with correct zero-rated/LUT wording.
Statement of invoices and export turnover for the refund period.
FIRC/BRC/bank remittance evidence or equivalent proof.
GSTR-1 and GSTR-3B reconciliation for outward supplies and ITC.
Purchase invoices and GSTR-2B support for ITC claimed.
Calculation of net ITC, adjusted turnover and refund amount as applicable.

Common Reasons Export-Service Refunds Get Stuck

Issue	Why it hurts	Prevention
Returns not filed	Portal may block or officer may question claim	File applicable returns before refund application.
Invoice mismatch	Export turnover in books, GSTR-1 and refund statement differs	Reconcile invoice-wise before RFD-01.
Weak remittance proof	Export-of-services condition not proven	Maintain bank advice/FIRC/BRC file.
Wrong refund period	Refund cannot be casually spread across financial years	Follow period rules and chronological filing discipline.
ITC not supported	Credits not traceable to valid invoices/GSTR-2B	Prepare vendor-wise ITC working.

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Planning a GST export refund?Build a refund working paper before filing RFD-01, not after receiving a query.

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Official References Used

This article uses official GST law, GST portal guides and CBIC circulars only. Verify rates, forms and procedural changes before publishing because GST notifications and portal flows can change.

Export-service refund — limitation and evidence controls

Refund eligibility starts with zero-rated/export status; LUT alone is not enough. For export of services, test all section 2(6) IGST conditions and the zero-rated-supply route, then compute eligible unutilised ITC under Rule 89.

Control	Why it matters
Relevant date	Section 54 generally allows two years from the relevant date. For export services, the relevant date depends on whether payment was received after completion of service or in advance before invoice.
Receipt condition	Payment must be received in convertible foreign exchange or in INR where permitted by RBI, subject to the export-of-services framework.
Distinct-person test	A foreign branch/establishment relationship can defeat “export of services” even when money comes from abroad.
ITC traceability	Refund is not “all ITC in the ledger”; preserve invoice eligibility, GSTR-2B/books linkage and Rule 89 computation.
Post-refund realisation	Zero-rated law contains consequences for non-realisation in specified export situations; maintain remittance follow-up after sanction.

Relevant-date example: service completed 15 May and foreign remittance received 20 July: the export-service relevant-date rule points to receipt of payment. If payment was received in advance before invoice, the invoice date is the statutory reference point.

Primary checks: CGST Act section 54; IGST zero-rated supply; Circular 125/44/2019-GST.

Frequently Asked Questions

How is export-service ITC refund filed? ▼

The GST portal guide points taxpayers to Services > Refunds > Application for Refund and the export-without-payment refund category, with details uploaded for the relevant tax period.

Can refund be claimed if returns are pending? ▼

The official portal guide notes that applicable returns due before the refund application should be filed; otherwise an error may be shown for relevant taxpayer types.

Is LUT enough to claim refund? ▼

No. LUT is only one requirement. Export conditions, ITC eligibility, return reporting and documentary proof must also be satisfied.

Source and review trail

Use the current official instrument, portal or regulator publication before acting. This panel separates the category authority from page-specific references.

Primary category: GST & Indirect Tax
Official starting point: www.gst.gov.in

Page source links

Primary sources & related provisions

Statutory provisions referenced in this guide: