Indian suppliers of qualifying exported services can generally seek a GST refund through one of two zero-rated supply routes: export without paying integrated tax under a bond or Letter of Undertaking (LUT), then claim eligible unutilized input tax credit (ITC); or pay integrated tax on the export and claim a refund of that tax. The application is filed electronically in FORM GST RFD-01. Which route applies—and whether the service qualifies as an export—depends on the current law and the transaction’s facts.
First confirm that the service qualifies as an export
A service provided to someone outside India is not automatically an export for GST purposes. The Integrated Goods and Services Tax Act defines export of services through conditions that must be assessed against the transaction, including the supplier, recipient, place of supply, payment and any establishment relationship. Check the current statutory definition and the facts of the particular supply before choosing a refund route. The IGST Act provides the statutory framework for zero-rated supplies.
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GST registration is needed to claim a refund for zero-rated exports, according to CBIC’s FAQs. Because eligibility and procedural conditions can depend on current rules and the claimant’s circumstances, confirm them before filing.
Choose between the two refund routes
The IGST Act provides two broad routes for zero-rated supplies. The right choice is not universal: consider the cash-flow effect, available eligible ITC, evidence readiness and the conditions that apply to your claim.
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| Route | What you do | What the refund claim is for |
|---|---|---|
| Export without payment of integrated tax | Export under a bond or LUT, subject to the applicable requirements. | Eligible unutilized ITC attributable to zero-rated supplies, subject to the rules and exclusions. |
| Export on payment of integrated tax | Pay integrated tax on the export, subject to the applicable conditions. | Refund of the integrated tax paid. |
CBIC Circular No. 135/05/2020 identifies separate refund categories for export of services with payment of tax and refund of unutilized ITC for exports without payment of tax. See the circular and the IGST Act. The sources establish the distinction between routes, not which route will be preferable for a particular exporter.
Prepare the records for an export-of-services claim
For a refund claim relating to export of services, the refund rules call for a statement containing the invoice numbers and dates, together with the relevant Bank Realization Certificates (BRCs) or Foreign Inward Remittance Certificates (FIRCs), as applicable. Reconcile those records before filing so the invoices and remittance evidence correspond to the claim. The requirements appear in CBIC’s refund rules.
- Export-service invoices, with invoice numbers and dates.
- Relevant BRC or FIRC details and supporting evidence, as applicable.
- Records needed to substantiate the selected route and calculate the amount claimed under the current rules.
For the no-payment route, CBIC’s FAQs refer to following the LUT or bond process. Check the current requirements for your circumstances; the retrieved official material does not establish every current portal attachment or declaration.
File the refund application
- Confirm eligibility and route. Check the current export-of-services definition against the transaction, then decide whether the claim is for eligible unutilized ITC after export without payment of tax or for integrated tax paid on export.
- Complete the relevant LUT or bond process if exporting without payment. Confirm the applicable current requirements in CBIC’s FAQs and rules.
- Reconcile invoices and remittance evidence. Match invoice numbers and dates to the relevant BRC or FIRC details required for an export-of-services claim.
- Submit FORM GST RFD-01 electronically through the common portal. Select the refund category matching the chosen route. The electronic application and categories are described in the refund rules and CBIC Circular No. 135/05/2020.
- Follow the live portal prompts. Check its current attachment, declaration and status requirements for the category you select; the available official material here does not establish a complete click-by-click workflow.
Calculate an unutilized-ITC claim with the current rule
For zero-rated supplies made without payment of tax under bond or LUT, the refund rules set a formula for the maximum refund of unutilized ITC. In broad terms, it relates zero-rated supply turnover and net ITC to adjusted total turnover. The operative rule defines these terms and includes qualifications, so do not calculate a claim from that summary alone. Use the current text of CBIC’s refund rules, the figures for the relevant period and the exclusions applicable to the claimant.
Use goods-export guidance carefully
The GST Portal’s GSTR-1 guide discusses export reporting and says shipping-bill details may be supplied later by amendment when unavailable at filing. That instruction concerns goods exports; shipping bills are not standard evidence for an export-of-services refund checklist. For services, the refund rules instead specify invoice details and relevant BRC or FIRC information.
An older CBIC PDF labels the application FORM GST RFD-01A and lists export-service refund categories. Treat it as historical context rather than proof of the current filing interface: the current refund-rules page identifies electronic filing of FORM GST RFD-01. See the historical RFD-01A rules and form PDF and the current refund rules.
Check deadlines and current requirements before filing
The official material cited here does not establish a single limitation period that can safely be applied to every refund category and fact pattern, nor does it set out every current portal step. Confirm the deadline and procedural requirements for the exact claim under current law and the live GST Portal before submitting.
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