If a GST refund claim appears under your business GSTIN without your authority, do not assume that the claim was paid or that your business is automatically liable. First validate the communication, then search the GST portal for registrations and refund records linked to your PAN, preserve every document, report any unauthorized registration through the GST portal’s PAN-misuse facility, and respond promptly to any formal notice or demand.
The correct remedy depends on what you can verify: a suspicious message, an unauthorized GST registration, a refund application, a sanctioned refund, an actual bank payment, or a demand order are different situations with different deadlines.
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Start by verifying the message, not by replying to it
Fraudsters can imitate government notices and include phone numbers, email addresses or links that divert you to an unofficial service. Before opening an attachment, sharing credentials or sending money, validate the identifier through the Directorate General of Intelligence (DGGI) public-services page: https://dggi.cbic.gov.in/dggi-ui/services.
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- Do not use a hyperlink, QR code or telephone number supplied in an unverified message to reach the department.
- Save the original email, letter, attachment, envelope and message headers. Record when and how you received them.
- If the identifier cannot be validated, treat the message as unverified while you independently check your GST portal account and contact the appropriate officer through official channels.
Validation confirms whether a communication identifier exists; it does not, by itself, prove that a refund application is genuine, fraudulent or paid.
Identify which of the four situations you are facing
Use the portal records, the verified communication and your bank statements to classify the problem before choosing a response. The following distinctions prevent a premature admission or a missed deadline.
| What you can verify | What it means at this stage | Immediate focus |
|---|---|---|
| Only a suspicious email, call or letter | No official claim has yet been established. | Validate the DIN, eOffice Issue Number or GSTN RFN; preserve the message and inspect your portal account. |
| An unfamiliar GST registration appears when your business PAN is searched | A registration may have been obtained or linked without your consent or knowledge. | Capture the registration details and file the GST portal PAN-misuse complaint after completing the portal’s identity verification. |
| A refund application, acknowledgement or sanction is visible | A claim exists in the tax record, but its status and relationship to your business remain to be established. | Save the application or ARN information, filings and notices; ask the competent jurisdictional officer to examine the mismatch. |
| A refund payment appears in a bank account or a formal demand order is served | The matter has moved beyond a possible application and may involve recovery or adjudication. | Reconcile the payment or order with the portal record immediately and obtain case-specific professional advice; an appeal deadline may apply. |
Neither a PAN match nor an unfamiliar GSTIN proves that your business made the claim. The decisive facts are the registration record, the refund application, any sanction or payment entry, the tax period and the evidence linking an individual to the filing.
Search every GST registration linked to the business PAN
GST Portal guidance describes a Search by PAN function for finding registrations associated with a PAN and a complaint route for suspected misuse. Use the GST Portal/GSTN instructions at https://tutorial.gst.gov.in/downloads/news/misuseofPANdocument.pdf.
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- Open the official GST portal independently rather than through the suspicious message.
- Use the portal’s Search by PAN functionality with the business PAN and the requested state or other identifying details.
- List every GSTIN returned. Compare legal name, principal place of business, registration date, status and jurisdiction with your own records.
- For an entry you do not recognise, take dated screenshots or download the available registration details. Do not edit the files; retain the original metadata where possible.
- Follow the portal guidance for reporting misuse of PAN. Complete the prescribed identity verification and submit the complaint online.
- Save the acknowledgement reference number (ARN) generated by the complaint facility. The portal guidance says complaints are assigned to jurisdictional officers and that the ARN can be used to track progress.
Describe the facts narrowly: explain that the registration or activity is not authorised by the business, identify the GSTIN and PAN involved, and attach the records requested by the portal. Avoid accusing a named person unless you have documentary evidence. A complaint starts an official review; it is not a finding that a refund was sanctioned or paid.
Trace the refund from application to payment
A refund allegation can refer to several different events. Inspect the relevant GST portal sections and your accounting and bank records to establish which event, if any, occurred.
Check the application record
Look for the refund application number or ARN, filing date, tax period, category of refund and the GSTIN used. Compare the claimant’s bank-account details and uploaded documents with authorised signatories, your books and your internal approval trail. If an ARN is present, preserve the complete status history rather than only the latest screen.
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Save every notice, request for clarification, deficiency communication, order and acknowledgement associated with the application. Note the issuing office, document identifier and date of communication. A pending application, a rejected application and a sanctioned refund have different consequences; do not describe an application as a payment until the bank entry is confirmed.
Check the bank account independently
Reconcile the period covered by the application against all business bank accounts, including accounts used for tax payments or refunds. A credit that looks like a refund should be matched to the government payment reference and the amount in the portal record. If no corresponding credit exists, record that fact and provide the statement to the competent jurisdictional officer.
The official material does not establish one universal method to freeze a claim or reverse a payment in every case. Ask the jurisdictional officer handling the registration or refund to record the discrepancy and advise what procedural step is available for that specific file.
Report the mismatch and preserve a complete evidence file
Use a single, chronological case folder so that an officer or adviser can see what happened without reconstructing it from scattered messages. The following is a prudent record-preservation checklist; it is not a substitute for any document formally requested by the department.
- Original suspicious communications, attachments, headers, call details and the result of DGGI identifier verification.
- Search-by-PAN results, each unfamiliar GSTIN’s registration details and screenshots showing the date and time captured.
- The PAN-misuse complaint, submitted attachments, generated ARN and later portal status updates.
- GST returns, invoices, e-invoice or e-way-bill records and accounting ledgers for the relevant tax period.
- Refund application or ARN details, supporting schedules, deficiency memos, notices, orders and correspondence.
- Bank statements and payment references demonstrating whether a refund was received, by which account and on what date.
- A short internal chronology identifying authorised signatories, portal users, tax practitioners and any suspected credential compromise.
Keep read-only copies and a working copy separately. Do not delete portal messages after downloading them, and do not alter a document’s date or content to make the sequence appear cleaner.
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If a formal demand order arrives, treat the appeal clock as urgent
A demand order is different from an informal allegation or a pending refund application. The GST Portal FAQ on appeals against demand orders says an appeal is generally due within three months from communication of the order, with possible condonation for up to one further month when sufficient cause is shown. Read the current FAQ at https://tutorial.gst.gov.in/userguide/appeal/appeal_faq.htm.
- Record the exact date and legally recognised mode of communication, not merely the date you happened to open the document.
- Identify the order number, issuing authority, tax period, amount demanded, interest and penalty components.
- Ask a GST practitioner or tax lawyer to check whether the document is an appealable order, whether any pre-deposit or filing form applies and how limitation is calculated for your facts.
- Prepare evidence showing that the registration, portal credentials, filing or bank account was not authorised by the business, while also addressing any genuine transactions in the period.
- File within the ordinary three-month period whenever possible. If that period has passed, document the reason immediately because the FAQ describes only a possible additional month for sufficient cause.
Do not wait for the PAN-misuse complaint to finish before obtaining advice on an appeal. The complaint and the appeal are separate processes, and an appeal deadline can expire while a registration investigation is pending.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Understand the legal period before relying on a section number
CBIC’s published text of section 74 concerns tax that was not paid, was short paid or was erroneously refunded where fraud, wilful misstatement or suppression to evade tax is alleged. The page labels the section for periods up to financial year 2023-24: https://taxinformation.cbic.gov.in/content-page/explore-act/1000348/1000001.
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That qualification matters. The section applicable to a later tax period, the limitation period, the required notice and the available settlement or appeal route must be checked against the law in force for that period. Do not assume that section 74 applies merely because a notice uses the words “fraud” or “erroneous refund.” A professional should map the allegation to the tax period, the evidence and the current statutory provision.
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Rule 89 provides the GST rules framework for refund applications; the CBIC text is available at https://taxinformation.cbic.gov.in/content-page/explore-rules/1000484/1000001. The rule framework can help you identify the application information to retrieve, but it does not decide whether your particular GSTIN was misused or whether money was paid.
Common mistakes that make an impersonation problem harder
- Paying a caller to “close” the case: verify the official communication and use the portal or department contact route instead.
- Replying through an unverified link: this can disclose passwords, one-time codes or identity documents. Navigate to the official services independently.
- Deleting suspicious messages: the message may contain the identifier needed for verification and evidence of impersonation.
- Assuming a PAN match equals liability: establish who obtained the registration, who filed, what was sanctioned and whether a payment occurred.
- Waiting for an investigation before addressing a demand: a demand-order appeal has its own limitation period.
- Making an absolute statement in a notice response without checking records: distinguish what you know, what the portal shows and what remains unverified.
When to obtain professional representation
Consider immediate advice from a GST practitioner or tax lawyer when a demand, investigation summons, large claimed amount, bank credit, credential compromise or multiple-state registrations are involved. Give the adviser the complete chronology and unedited records. Ask specifically which officer has jurisdiction, which tax period and statutory provision govern, whether a reply or appeal is due, and how to protect the business while the PAN-misuse complaint is reviewed.
Professional advice is also useful when the business did authorise a tax agent but the agent’s actions are disputed. The question may then involve agency records, portal access logs, engagement terms and the accuracy of returns, not simply an unknown registration.
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A strong response is factual and traceable: it identifies the verified communication (or explains that it could not be verified), lists the GSTIN and refund ARN, states the tax period, separates application from sanction and payment, attaches the relevant records, cites the PAN-misuse complaint ARN and asks the competent officer for the next procedural step. It does not concede fraud, liability or receipt of money before those facts are established.
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