For GST input tax credit (ITC), keep the prescribed source document for every credit—typically the supplier’s tax invoice or debit note, a bill of entry for import IGST, or the applicable Input Service Distributor (ISD) document—together with accounts that show how the credit was recorded and claimed. For a refund, the evidence depends on the reason for the claim: exports, supplies to an SEZ, deemed exports, an order or appeal, inverted duty, and other categories each have different documents.
Use this as a central-rule checklist under India’s CGST framework. State or Union Territory provisions, notifications, amendments and GST Portal instructions can change the exact filing set, so verify the requirements for your registration and the refund period before submitting FORM GST RFD-01.
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Start with the document that creates the ITC
An ITC file should let an auditor move from the return claim back to the underlying supply without guessing. The primary evidence is the prescribed document for that transaction:
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- Supplier tax invoice: retain the complete invoice issued under the GST invoice rules, including the supplier and recipient GSTINs, invoice number and date, description, taxable value, tax rate and amount, place of supply where relevant, and other particulars required for that transaction.
- Supplier debit note: keep the debit note and the invoice or supply record to which it relates. The debit note must be traceable to the additional tax being claimed.
- Bill of entry or other prescribed customs document: retain the document supporting IGST paid on imported goods. Keep the import entry, assessment details and payment evidence together.
- ISD document: for credit distributed by an Input Service Distributor, retain the ISD invoice, ISD credit note or other prescribed ISD document, along with the calculation showing how the credit was allocated.
These are the documents that establish the statutory basis for the credit. They do not replace the eligibility conditions in the CGST Act and rules, such as receiving the supply, using it for business and making any required reversals. A valid-looking invoice can still relate to ineligible credit.
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Keep the accounting trail behind every credit
The CGST records rules require accounts of tax payable, tax paid and ITC claimed, as well as registers of tax invoices and debit notes issued and received. Preserve an unbroken link between the source document, your accounting entry, the ITC ledger and the return in which the credit was reported.
Businesses commonly maintain the following supporting records. These are practical substantiation records rather than a single additional set prescribed for every ITC claim:
- Purchase orders, contracts or engagement letters showing what was agreed.
- Goods-received notes, delivery challans, transport records or warehouse receipts for goods.
- Service completion reports, timesheets, acceptance records or other evidence that a service was received.
- Payment records, bank references and correspondence that explain unusual adjustments, advances or credit notes.
- Expense coding, cost-centre details and business-purpose notes showing why the purchase relates to taxable business activity.
- A document index that maps each invoice or import entry to the general-ledger voucher, ITC working paper and relevant return period.
Retain the original electronic file where the invoice was issued electronically, and preserve legible scans of paper documents. Do not rely on a spreadsheet alone: the spreadsheet should point to the underlying invoice, note or customs record.
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GSTR-2A and GSTR-2B are reconciliation tools. GSTR-2B contains supplier-reported invoice and debit-note information and import-of-goods information received from ICEGATE. Match those statements to your purchase register and investigate differences before claiming or retaining credit.
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Portal appearance is not a conclusive eligibility test. The GST Portal cautions that some legal restrictions are not fully shown as unavailable in the statement. You must self-assess the transaction and omit or reverse credit when the law requires it, even if an entry appears in GSTR-2B. Conversely, certain imports, including some courier imports, may not appear in the stated import data; the bill of entry remains the important evidence.
A practical monthly reconciliation file
- Download the relevant GSTR-2B and preserve the file with the period name and download date.
- Match each reported invoice or debit note to the supplier invoice in your purchase register and accounting system.
- List invoices that are missing, duplicated, amended or reported in a different tax period.
- Check tax amount, place of supply, reverse-charge treatment, blocked-credit categories and any credit already reversed.
- For imports, reconcile the bill of entry and ICEGATE data to the import register; retain the customs documents even when portal data is absent.
- Document the decision for each difference: claim, defer, reverse, or seek correction from the supplier.
Refund documents depend on the claim basis
Rule 89 of the CGST Rules sets the application and documentary-evidence framework. Refund applications are generally filed electronically in FORM GST RFD-01, but there is no universal “refund bundle.” Identify the event that created the refund first, then assemble the evidence for that category.
| Refund basis | Core documents to retain | Additional evidence or filing detail |
|---|---|---|
| Refund arising from an order or appeal | The order or appeal reference and a copy of the relevant order, or the payment reference specified by the rule for that case | Keep the calculation showing how the order amount becomes the amount requested in RFD-01. |
| Export of goods | Shipping bill or bill of export and the related export-invoice particulars | Retain transport and customs records and ensure the export manifest or report has been delivered as required before filing. |
| Export of services | Service-invoice particulars for the exported services | Retain the relevant Bank Realization Certificate (BRC) or Foreign Inward Remittance Certificate (FIRC) information and supporting remittance records. |
| Supply of goods to an SEZ | Tax-invoice particulars for the supply | Keep the specified officer’s endorsement confirming receipt or the required SEZ evidence for the supply. |
| Supply of services to an SEZ | Service-invoice particulars | Retain evidence that the service was received for authorised operations, the authorised-operations details and proof that the SEZ recipient paid the supplier. |
| Deemed exports | Invoice particulars for the deemed-export supply | Keep any other evidence notified for the particular deemed-export category and transaction. |
| Specified inverted-duty refund of unutilized ITC | Annex 1 statement to RFD-01 listing invoice numbers and dates for invoices received and invoices issued during the claim period | Reconcile the statement to purchase and sales registers and to the eligible credit calculation. |
The table describes central-rule examples. A notification, state or Union Territory instruction, or a later portal change can add requirements for a particular period. Check the live RFD-01 workflow and the jurisdictional instructions immediately before filing.
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Extra records for unutilized-ITC refund applications
CBIC Circular 125/44/2019 gives specific upload guidance for unutilized ITC claims. For claims handled under that guidance, retain and upload the relevant GSTR-2A and an invoice-level Annexure-B statement. The statement should support the eligible credit and the computation of the refund.
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The circular says applicants should provide self-certified copies of claimed invoices that are eligible but do not appear in GSTR-2A. It also says officers should not insist on copies of invoices whose details are available in the relevant uploaded GSTR-2A. This is 2019 circular guidance, so confirm whether later directions or the current portal require a different format or additional upload.
Build the Annexure-B support file
- Assign each invoice a unique line in the statement, with invoice number, date, supplier GSTIN, taxable value and tax amounts.
- Mark whether the invoice appears in GSTR-2A and retain the corresponding downloaded statement.
- For an eligible invoice missing from GSTR-2A, attach the self-certified invoice copy and evidence of receipt and payment where relevant.
- Reconcile the statement totals to the electronic credit ledger, books and the amount entered in RFD-01.
Unjust-enrichment declarations and certificates
Where the unjust-enrichment provisions apply, Rule 89 uses a threshold for the supporting declaration or certificate. For a claim up to ₹2 lakh, the rule specifies a declaration in the prescribed form. For a claim above ₹2 lakh, it specifies a certificate from a chartered accountant or cost accountant. The rule contains exceptions, so do not apply the ₹2 lakh threshold mechanically to every refund category.
Keep the working paper that explains why the claim is outside an exception or why the required declaration or certificate applies. Preserve the certificate, engagement records and calculation with the refund file rather than uploading only the final amount.
What to retain after filing
Save the submitted RFD-01, ARN, acknowledgements, deficiency memos, notices, replies, orders and sanction or rejection communications. Keep the exact versions of statements and annexures uploaded, not just editable files that may change later. If an officer requests an invoice or reconciliation, your response should reproduce the same line item and calculation used in the application.
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Use a claim-period folder structure
- Create a folder for the GSTIN, financial year, tax period and refund basis.
- Store the signed or submitted application and ARN at the top level.
- Store source documents in separate subfolders for invoices, debit notes, bills of entry, export or SEZ evidence, certificates and portal statements.
- Keep a read-only final copy of each uploaded spreadsheet or PDF, with a version date.
- Record who prepared, reviewed and approved the claim and the date each reconciliation was completed.
How long must GST records be kept?
Section 36 of the Central Goods and Services Tax Act, 2017 states: “Every registered person required to keep and maintain books of account or other records in accordance with the provisions of sub-section (1) of section 35 shall retain them until the expiry of seventy-two months from the due date of furnishing of annual return for the year pertaining to such accounts and records:”
In practical terms, the ordinary clock is 72 months from the due date for the annual return for the year to which the records relate. It is not simply six years from the invoice date. Calculate the deadline separately for each financial year and keep evidence of the annual-return due date used.
If an appeal, revision, other proceeding or covered offence investigation concerns the records, retain them until one year after final disposal or until the ordinary period ends, whichever is later. A pending dispute can therefore extend the storage period beyond the normal 72-month calculation.
Common document-control failures and fixes
Claiming from a portal line without checking eligibility
Failure: treating a GSTR-2B entry as automatic entitlement. Fix: perform the legal eligibility review and record reversals or exclusions, while retaining the invoice and reconciliation evidence.
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Keeping only a purchase-register export
Failure: the register has numbers but no invoice image, debit note or import document. Fix: link every line to the source file and preserve the document particulars required by the invoice or customs rules.
Using one checklist for every refund
Failure: attaching export documents to an inverted-duty claim, or omitting an SEZ endorsement because the invoice is present. Fix: classify the refund basis first and use the matching evidence in the Rule 89 table.
Ignoring amendments and later portal instructions
Failure: relying on an old circular or an earlier upload screen. Fix: verify current GST Portal prompts, notifications and jurisdictional instructions for the period being claimed.
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Failure: deleting files at 72 months while an appeal, investigation or other covered proceeding remains open. Fix: place a legal hold on the affected records and calculate the later disposal date after final resolution.
Quick Recap
A concise pre-filing checklist
- Identify the ITC or refund legal basis and the exact claim period.
- Confirm that each ITC line has the prescribed invoice, debit note, bill of entry or ISD document.
- Reconcile books, electronic credit ledger, GSTR-2A or GSTR-2B and import data.
- Document eligibility decisions, reversals and unresolved supplier differences.
- For refunds, assemble the category-specific order, export, SEZ, deemed-export, payment, certificate or declaration evidence.
- For unutilized-ITC claims, prepare the required annexure and invoice-level support, including copies for eligible invoices missing from GSTR-2A where applicable.
- Check unjust-enrichment requirements and the ₹2 lakh threshold together with the rule’s exceptions.
- Save the final application, ARN, uploads and later correspondence in a read-only claim folder.
- Set the retention deadline from the relevant annual-return due date and extend it for any proceeding or investigation.
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