The GST Council has recommended major changes to India’s refund system, including phased system-based processing, a 10-day acknowledgement deadline, risk-based provisional refunds of up to 90% for certain claims, revised refund data requirements, removal of a turnover cap for zero-rated goods, a combined ₹1,000 threshold, and broader use of eligible input-service and capital-goods ITC. These are recommendations—not amendments in force—until the required Act amendments, rules, notifications or instructions are issued.
What has the GST Council proposed?
The package covers refunds of excess electronic cash-ledger balances, zero-rated supplies and inverted-duty-structure claims. The Council’s official release describes amendments to section 54 of the CGST Act, 2017 and the relevant CGST Rules, 2017, to enable system-based processing and sanctioning in two phases.
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Taxpayers should continue following the operative Act, Rules, forms and departmental instructions until implementation is formally notified. The figures below are proposed policy parameters, not measured improvements in processing time or guaranteed payment outcomes.
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Phase 1: automated screening and provisional sanction
- Excess cash-ledger balances: Full refunds would be sanctioned automatically by the system without officer intervention.
- Acknowledgement deadline: The period for issuing an acknowledgement or deficiency memo would fall from 15 days to 10 days. If neither is issued within 10 days, the claim would be deemed acknowledged under the proposal.
- Zero-rated and inverted-duty claims: The system could provisionally sanction 90% of the claimed amount after risk identification and evaluation. This is a proposed, risk-based process—not an automatic entitlement to 90% for every applicant.
Phase 2: automated acknowledgement and final sanction for zero-rated claims
After system verification, acknowledgement would be generated automatically. For acknowledged zero-rated claims, the full refund would then be sanctioned automatically after adjustment of any pending dues, subject to system risk assessment. The official description of full-refund automation in Phase 2 applies to zero-rated claims; it should not be extended to inverted-duty claims without a separate notification.
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| Claim category | Proposed processing | Officer role in the proposed workflow |
|---|---|---|
| Excess electronic cash-ledger balance | Full system-based sanction in Phase 1 | No officer intervention for the automated sanction |
| Zero-rated supply | 90% provisional sanction in Phase 1; full automated sanction proposed in Phase 2 after verification and adjustment of dues | Reduced involvement, subject to risk controls and notified exceptions |
| Inverted duty structure | 90% provisional sanction proposed in Phase 1 | Do not assume Phase 2 full automation; the official recommendation does not state it |
Changes to GST refund applications and calculations
More system-readable FORM GST RFD-01 data
The Council recommended redesigning FORM GST RFD-01 to capture information in a system-readable format. For specified refund claims involving zero-rated supplies and inverted duty structure, scanned-document uploads would be dispensed with. This changes the proposed submission format; it does not remove the need to retain records or satisfy eligibility and verification requirements.
Removal of the zero-rated goods turnover cap
The proposal would remove the limit in rule 89(4)(C) that restricts the zero-rated goods turnover used in the refund formula to 1.5 times the value of like goods supplied domestically. Until the rule is amended, taxpayers should not recalculate claims on the assumption that the cap has already disappeared.
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One combined ₹1,000 minimum threshold
The Council recommended clarifying that the ₹1,000 minimum refund threshold applies to the total amount claimed across CGST, SGST or UTGST and IGST taken together, rather than treating each component as a separate threshold. The clarification concerns eligibility for processing; it is not a promise that an otherwise ineligible claim will be paid.
When input services and capital goods may count for ITC refunds
Input services in inverted-duty refunds
Eligible input-service ITC availed on or after 1 November 2026 is proposed to be included in “Net ITC” for inverted-duty refund calculations. The proposal does not make a business eligible merely because its input services carry a higher GST rate than its outward supplies. The inverted structure must still be established by comparing the applicable rates on inputs and output supplies, and the proposal does not expand the class of taxpayers eligible under section 54(3).
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Capital goods in zero-rated and inverted-duty refunds
Eligible capital-goods ITC availed on or after 1 April 2027 is proposed to be included, to the extent attributable to the relevant period, in refund calculations for zero-rated supplies and inverted duty structure.
The proposed allocation spreads capital-goods ITC over 60 months: one-sixtieth is attributed to each month beginning with the month in which the credit is availed. Only eligible credit attributable to the claim period is counted. Blocked or otherwise inadmissible ITC is excluded, and required reversals must be deducted.
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| ITC category | Refund type covered by proposal | Proposed availability date | Calculation treatment |
|---|---|---|---|
| Input services | Inverted-duty refunds | ITC availed on or after 1 November 2026 | Included in Net ITC if otherwise eligible; does not by itself establish an inverted structure |
| Capital goods | Zero-rated and inverted-duty refunds | ITC availed on or after 1 April 2027 | One-sixtieth per month over 60 months, limited to eligible credit attributable to the relevant period |
Interest on appeal pre-deposits
The Council recommended making section 115 a standalone provision specifying the interest rate for refunds of amounts paid as appeal pre-deposits. It also proposed a circular clarifying issues relating to that rate. The material available for this proposal does not establish a new operative rate, so taxpayers should not apply a replacement percentage until the law or an official instruction states one.
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Repair common Windows errors and clear accumulated junk for a smoother, more stable PC - no reinstall needed.Free scan · no reinstallHow these proposals differ from today’s refund procedure
Under the currently published CBIC Refund Rules, applications are filed electronically through FORM GST RFD-01 and remain subject to scrutiny, acknowledgement or deficiency communication, provisional refund where the statutory conditions are met, final orders and an opportunity to respond before rejection. The rules state that an officer issues a provisional refund order within seven days of acknowledgement when the relevant conditions are satisfied.
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- Large capacity: This tax document organizer has 13 pockets, each holding about 40 sheets of paper, it can be flexibly expanded and shrunk as the number of files increases, holding a total of about 500 sheets of paper, ideal for organizing and protecting important documents, paperwork, bills, tax records, receipts, invoices and more
- Pre Printed Labels and Customizable labels: these pre printed label stickers have common tax categories, such as Medical Expenses, Employment Income, Rental Income, and more, we also included alphabet labels and customizable labels for your personal uses, please note that the customizable labels do not come with adhesive
- Broad uses: this expandable file folder organizer is proper for organizing various financial and tax related documents, with strippable labels and divider labels for sorting, making your tax preparation more systematic and managed, ideal for annual tax returns, document storage and filing, professional tax services, and tax agencies
That existing seven-day officer-led provision is different from the proposed automated 90% sanction for qualifying zero-rated and inverted-duty claims. Until amendments and implementation instructions take effect, businesses should preserve supporting evidence, reconcile returns and ledgers, and follow the live portal workflow.
Quick Recap
What businesses should do now
- Check legal status before changing claims: Look for the enacted section 54 amendment, amended rules, notifications and CBIC instructions before using any proposed date, threshold or formula change.
- Separate claim types: Identify whether each application concerns excess cash balance, zero-rated supply or inverted duty structure, because the proposed automation differs by category.
- Prepare structured data: Maintain invoice, export or supply evidence, return data, electronic ledgers, payment records and ITC reconciliations in a format that can populate the revised RFD-01 if implemented.
- Track ITC dates: Keep separate records of input-service ITC availed on or after 1 November 2026 and capital-goods ITC availed on or after 1 April 2027.
- Apply eligibility filters: Exclude blocked or inadmissible credit and account for reversals before calculating any prospective claim.
- Monitor the portal and notices: Automated processing would still be risk-based and could involve verification, adjustment of dues or a deficiency communication.
What is not yet established
- The recommendations do not themselves amend the CGST Act or Rules.
- The published figures are proposed parameters, not evidence that refunds will actually be processed within 10 days or that taxpayers will receive money faster.
- There is no established new interest rate for appeal pre-deposit refunds in the material described here.
- Phase 2 full automated sanction is stated for zero-rated claims, not generally for inverted-duty claims.
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