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Documents common to export-of-services refund claims
- FORM GST RFD-01: Refund applications are generally filed electronically through the common portal. See the current CBIC refund rules.
- Export invoice schedule: List invoice numbers and dates, and match them to the refund statement and remittance evidence. Rule 89 provides for invoice and relevant BRC/FIRC details for export-of-services refund claims.
- Export invoices: Check that each invoice includes the applicable export endorsement and required recipient, delivery and destination-country information. The endorsement differs depending on whether IGST was paid.
- BRC/FIRC evidence: Retain the relevant Bank Realisation Certificate (BRC), Foreign Inward Remittance Certificate (FIRC) or applicable remittance evidence. Reconcile it with invoice references and payment receipts.
How the supporting documents differ by refund route
The key distinction is whether the export was made on payment of IGST or without payment of IGST. The statement set and refund basis differ accordingly.
| Claim route | Refund basis | Statements and supporting papers listed by CBIC | Additional route-specific evidence |
|---|---|---|---|
| Export on payment of IGST | Refund of IGST paid on export | Statement 2; invoices relating to inputs, input services and capital goods; BRC/FIRC for export of services; and an undertaking or declaration. | Export invoices with the payment-of-IGST endorsement. |
| Export without payment of IGST under LUT or bond | Refund of accumulated ITC | Statements 3 and 3A; invoices relating to inputs and input services; BRC/FIRC for export of services; and an undertaking or declaration. | The applicable LUT or bond, and export invoices with the no-payment endorsement. |
These document lists come from CBIC Circular 37/11/2018-GST. It refers to the then-used FORM RFD-01A, so treat that form label as historical procedural wording: check the current portal’s RFD-01 workflow and attachment list when preparing a claim.
Invoice endorsements
The invoice rule specifies these route-specific phrases:
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- For export on payment of IGST: “SUPPLY MEANT FOR EXPORT ON PAYMENT OF IGST”.
- For export without payment of IGST: “SUPPLY MEANT FOR EXPORT UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF IGST”.
Refer to the CBIC invoice rules for the prescribed invoice particulars.
When an LUT or bond is needed
For export of services without payment of integrated tax, CBIC says the exporter is required to submit an LUT or bond. The LUT/bond route is therefore not interchangeable with a claim based on IGST paid at export. See the CBIC sectoral FAQ.
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Check the transaction and reconcile the file before filing
A document bundle by itself does not prove that a transaction qualifies as an export of services. Check the relevant statutory conditions for the transaction, including the parties and recipient, place of supply, and consideration and payment facts. A CBIC clarification addresses one export-of-services condition, but it is not a complete transaction-specific eligibility checklist; obtain advice for facts that are unclear.
- Match invoice numbers, dates and values across the invoices, refund statements and BRC/FIRC evidence.
- Account for any credit or debit note adjustments in the claim.
- Use the statement set and refund basis that correspond to the actual route: IGST paid or accumulated ITC after export without payment of tax.
- Confirm that the invoice endorsement and any LUT or bond match that route.
What Circular 37 means for additional documents
Circular 37 says officers should not call for documents beyond its category-specific lists unless the information is not available electronically. Because the circular dates from 2018 and uses RFD-01A terminology, read it as processing guidance rather than a substitute for the current portal workflow. Check the portal’s live requirements before submitting.
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