GST Refund for Export of Services Without Payment of Tax: RFD-01 Checklist
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. |
Finin2min Publishing Checklist Before Upload
- Cross-check every legal statement against the official source links below, especially if a notification has changed after this draft date.
- Add one practical example from the target audience — freelancer, SaaS seller, manufacturer, startup or finance team — before publishing.
- Link internally to the GST registration, GST return, GST ITC and GST notice-response pages wherever relevant.
- Avoid quoting a GST rate unless the current GST rate schedule or notification has been verified separately.
- End the article with a clear disclaimer that facts, contracts and portal status can change the final tax position.
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.
- GST Portal export refund user guide
- CGST Rule 89 - Refund application
- CGST Rule 90 - Acknowledgement / deficiency memo
- CGST Section 54 - Refund of tax
- CBIC Circular 125/44/2019-GST - Refund procedure
Frequently Asked Questions
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