Boutique Law Firm, started in 2015 Advisory, Health-Checks

➢ Boutique Law Firm, started in 2015

➢ Advisory, Health-Checks and Litigation support services in entire spectrum of Indirect Taxes,

International Trade, Legal Metrology and other Allied laws

➢ Team of 50 members with 5 Partners having experience in leading Accounting and Law firms

➢ Client base includes leading Indian corporates and MNCs across industry verticals

REFUNDS AND TDS UNDER GST

Key Accolades

About NITYA Tax Associates

TABLE OF CONTENTS

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REFUNDS

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A SNAPSHOT ON REFUNDS !!

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▪ Cashflow to exporter.

▪ Refunds are policy matters of government

o Nexus with exports

o Remittance of taxes back to taxpayer where it is collected without authority of law

▪ General refund types

o Input stage refund

o Output stage refund

o Notified situations

▪ Doors of Courts can be knocked where special situations for refund is not explicitly covered

under the Act.

▪ Given to a person who has actually borne the incidence of taxes

▪ Comes with procedures (Documentation + Verification + Limitation period)

LEGAL BACKGROUND

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LEGAL PROVISION

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Section 54 of CGST Act

▪ Any person claiming refund may file application….

▪ No refund of unutilized ITC in cases, other than:

o Zero rate supplies

✓ Physical exports

✓ Supplies to SEZ Units / Developers

o Inverted Duty Structure

GENESIS OF REFUND

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Constitution of India

▪ Article 265 -

No tax shall be levied or collected except by the authority of

law

Any amount collected in excess of tax shall be refund.

o Excess rate charged / clerical errors etc.

▪ Section 54 -

Substantial only for refund under inverted duty structure and

deemed exports refund

REFUND TYPES

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Output Stage Refund

Input Stage Refund

(Accumulated ITC)

Others

Inputs / Input

services used in

zero-rated supplies

Inverted duty

structure

IGST paid on

zero rated

supplies

Deemed

exports

Tax payment

under wrong

heads

Excess

payment of tax

Assessment /

Appeal / Any

other order

Other reasons

PROCEDURE

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Refund claim to be filed

within 2 years from ‘relevant date’

▪ Goods exported by sea or air -

Date on which such Ship / Aircraft leaves India

▪ Export of services -

Date of receipt of payment OR date of issuance of

invoice (in case of advance)

▪ ITC on inverted duty -

Due date for furnishing return for the period in which

refund is claimed

▪ Other cases -

Date of payment of tax

Note – Courts have construed time-limit to be a

substantial law and rejected claims which were filed

after due date

Notification No. 24/2021 - Central Tax dated June 1, 2021

▪ Any proceeding / issuance of order, intimation etc. by any

Authority or any appeal, reply, report, return, statement

etc. by Taxpayer

▪ Last date falling between April 15, 2021, to June 29,

2021

▪ Revised due date is June 30, 2021

PROCEDURE

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SC order dated April 27, 2021

▪ Whether extended time limit of SC order will apply on

new application?

▪ What if deficiency memo has been issued after March

14, 2021?

▪ What if application has been filed before March 14,

2021, and no deficiency memo is issued? Interest

implications?










refund is claimed

▪ Other cases -




after due date

PROCEDURE

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Filing of refund claim

(RFD-01)

Generation of ARN

4 supporting docs

(max 5 MB each)

Deficiency Memo

(RFD-03)

(to be issued within 15 days)

Acknowledgement

(RFD-02)

(within 7 days)

Provisional Order

(RFD-04)

Final Order

(RFD-06)

(within 45 days)

(within 60 days)Disbursement

Fresh application

to be filed










refund is claimed

▪ Other cases -




after due date

DEFICIENCY MEMO

May 2020

Files Refund

Application

June 2020

Issues

‘Deficiency

Memo’

Period of Refund - September 2018

Files Fresh Refund

Application

July 2020December

2020

Refund

Sanctioned

Interest Calculation -

From October 2020

&

Not from August 2020!

Jeopardizes limitation

period & accrual of

interest from original

date of fling

Issues

‘Deficiency

Memo’

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Ruling Decision

Jian International

(Del HC)

Insitel Services

(Del HC)

Time limit of 2 years does not

include time period from filing

refund claim till communication

of deficiencies for filing fresh

refund applications

Shri Gayatri Cashews

(Mad HC)

Garden Silk Mills

(Guj HC)

INTEREST

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Delayed refund!Ruling Decision

Apar Industries

(Bom. HC)

Saraf Natural Stones

(Guj. HC)

Amit Cotton Industries

(Guj. HC)

Willowood Chemicals

(Guj. HC)

PRACTICAL ISSUES

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Output Stage Refund

Input Stage Refund

(Accumulated ITC)

Others

Inputs / Input

services used in

zero-rated supplies

Inverted duty

structure

IGST paid on

zero rated

supplies

Deemed

exports

Tax payment

under wrong

heads

Excess

payment of tax

Assessment /

Appeal / Any

other order

Other reasons

Input Stage Refund

(Accumulated ITC)

Without payment of tax

i.e., Inputs / Input services

used in zero-rated supplies

On payment of tax

i.e., IGST paid on zero rated

supplies

Computation of refund of unutilized ITC

(only for inputs and input services) -

Lower of:

▪ Maximum refund amount as per

prescribed formula in CGST Rules

▪ Balance in credit ledger at end of tax

period for which refund is filed.

▪ Balance in credit ledger at time of filing

refund application

REFUND TYPES

Output Stage Refund

ISSUES

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KEY ISSUES

Refund to SEZ Rule 89(4)

Mismatch with SB

Rule 96B

ITC not appearing in GSTR-2A

Rule 89(4)(B)

Rule 96(10)

LIMIT ON VALUE OF EXPORTED GOODS – RULE 89(4)

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Refund of unutilized ITC available

Net ITC

Turnover of Zero-Rated

Supply of Goods

Turnover of Zero-Rated

Supply of Goods

Adjusted Total Turnover

Value of zero-rated

supply of goods made

during relevant period

without payment of tax

Value of exported goods to

not exceed 1.5 times of

value of goods sold

domestically

▪ Arbitrary provision

▪ Limits scope of export

▪ Ultra-vires

▪ Ambiguous terminology – Like goods /

similarly placed supplier

REFUND CURTAILED TO FOB VALUE OF EXPORTED GOODS

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▪ Clarified that zero-rated supply effected under GST. Hence,

value to be transaction value under Section 15 of CGST Act

▪ Refund to be granted on invoice value or Shipping Bill value,

whichever is lower

▪ Difference may be because of terms of sale, exchange rate etc.

Example

Particulars Amount (Rs.)

Turnover 500

Net ITC 200

Invoice Value150

(Goods value 100 + Freight 50)

FOB value basis SB 100

Refund Granted (150 / 500) * 200 = 60

Refund on FOB value (100 / 500) * 200 = 40

Excess Refund = Rs. 20

Circular No. - 125/44/2019 - GST

ILLUSTRATION (Turnover Rs. 500 & Net ITC Rs. 200)

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Output Stage Refund


Invoice Value150

[(Goods value 100 + Freight 50)


Refund Granted 27

Refund on FOB value 100 * 18% = 18

Excess Refund = Rs. 9

Inverted Duty Refund


Invoice Value150

[(Goods value 100 + Freight 50)


Refund Granted [(150 / 500) * 200] - 7.5 = 52.5

Refund on FOB value [(100 / 500) * 200] - 5 = 35

Excess Refund = Rs. 17.5

18% GST 27 5% GST 7.5

▪ To be inserted

▪ Refund formula uses the term ‘value’ denoting value arrived under Section 15 of

CGST Act

▪ Transaction value includes incidental expenses charged at the time or before

delivery

▪ Value of freight and insurance part of transaction value

▪ Detailed legal reply should be filed in case of any objection

▪ Revision of refund formula for future to avoid disputes

▪ File representations through trade associations to obtain clarity

IMPACT OF EXCESS SANCTION OF REFUND

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▪ Refund formula uses the term ‘value’ denoting value arrived under Section 15 of

CGST Act

▪ Transaction value includes incidental expenses charged at the time or before

delivery

▪ Value of freight and insurance part of transaction value

▪ Detailed legal reply should be filed in case of any objection

▪ Revision of refund formula for future to avoid disputes

▪ File representations through trade associations to obtain clarity

WAY FORWARD

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Applicable w.e.f March 23, 2020

Recovery of refund amount where export

proceeds not realized

▪ If export proceeds not realized (in full or

part)

▪ Within time period as allowed under FEMA

▪ Refund amount shall be recovered to the

extent of non - realization of export

proceeds

Ruling Decision

Bhawani Textiles

(Guj HC)

▪ Arbitrary provision

▪ Prospective or retrospective applicability?

▪ Compliance by self

▪ Payment waiver by supplier?

▪ Payment received after 3 months of recovery?

TIME LIMIT ON RECEIPT OF PAYMENT – RULE 96B

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Exporter

Export goods

Refund is

sanctioned

Export proceeds

not realized

TIME LIMIT ON RECEIPT OF PAYMENT – RULE 96B

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SanctionedApplication filedRefund period

April 30, 2020March 25, 2020

January 2020

June 30, 2020May 25, 2020

February 2020

March 20, 2020February 25, 2020

April 2020

April 30, 2020

Applicability of Rule

96B

January 2020 February 25, 2020

Circular No. 135/2020 dated

March 31, 2020 -

No refund of ITC on invoices not

reflected in GSTR-2A

▪ Refund cannot be denied on account of error

committed by the vendor

▪ Ultra-vires

▪ Subject to challenge in the Courts

REFUND RESTRICTED TO INVOICES REFLECTED IN GSTR-2A

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Taxpayer

Refund is

sanctioned

Invoices not reflected

in GSTR-2A

REFUND OF CAPITAL GOODS

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Inputs and Input

servicesCapital Goods

Ruling Decision

VKC Footsteps

(Guj HC)

▪ Rules cannot override provisions under Act

▪ Ultra-vires

▪ Explanation not clearly worded

INPUTS IMPORTED UNDER ADVANCE AUTHORIZATION

Duty free

import of inputs

BCD

GST

GST

AA Holder

IGST

Exports

` 50

Refund available

Rs.50

Rs.30

Rs.100

GST regime

Without

payment of

GST

Refund of ITC

available

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No IGST exemption on imports under AA scheme !

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Rs.50

Rs.30

Rs.100


Duty free

import of inputs

BCD

GST

GST

AA Holder

IGST

Exports

` 50

GST regime

October 13,

2017

IGST

exemption

under AA

scheme

Notification 79/2017 - Customs

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Rs.50

Rs.30

Rs.100


Duty free

import of inputs

BCD

GST

GST

AA Holder

IGST

Exports

` 50

GST regime

October 13,

2017

IGST

exemption

under AA

scheme

January 23,

2018

Refund if AA

benefit

availed ?

October 23,

2017

Notification 3/2018 - CTRefund available

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Rs.50

Rs.30

Rs.100


Duty free

import of inputs

BCD

GST

GST

AA Holder

IGST

Exports

` 50

GST regime

October 13,

2017

IGST

exemption

under AA

scheme

January 23,

2018

Refund if AA

benefit

availed ?

October 23,

2017

Refund not

available

September 4,

2018

Notification 39/2018 - CT

Refund not

allowed if AA

benefit

availed

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Rs.50

Rs.30

Rs.100


Duty free

import of inputs

BCD

GST

GST

AA Holder

IGST

Exports

` 50

GST regime

October 13,

2017

IGST

exemption

under AA

scheme

January 23,

2018

Refund if AA

benefit

availed ?

October 23,

2017

September 4,

2018

Refund not

allowed if AA

benefit

availed

October 9,

2018

Notifications +

Circular issued

to clear

anomaly


Refund available

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Rs.50

Rs.30

Rs.100


Duty free

import of inputs

BCD

GST

GST

AA Holder

IGST

Exports

` 50

GST regime

October 13,

2017

IGST

exemption

under AA

scheme

January 23,

2018

Refund if AA

benefit

availed ?

October 23,

2017

September 4,

2018

Refund not

allowed if AA

benefit

availed

October 9,

2018

Notifications +

Circular issued

to clear

anomaly


Refund availableNotification

54/2018 - CT

Refund not

available

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Rs.50

Rs.30

Rs.100


Duty free

import of inputs

BCD

GST

GST

AA Holder

IGST

Exports

` 50

GST regime

October 13,

2017

IGST

exemption

under AA

scheme

January 23,

2018

Refund if AA

benefit

availed?

October 23,

2017

September 4,

2018

Refund not

allowed if AA

benefit

availed

October 9,

2018

Notifications +

Circular issued

to clear

anomalyRefund available

March 23,

2020

Explanation

inserted


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Rs.50

Rs.30

Rs.100


Duty free

import of inputs

BCD

GST

GST

AA Holder

IGST

Exports

` 50

Refund available

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Ruling Decision

Cosmo Films

(Guj HC)

Zaveri & Co.

(Guj HC)

Balkrishna Industries

(Guj AAR)

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REFUND TO SEZ UNITS ON EXPORT OF GOODS

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Ruling Decision

Vaachi International

(GSTAA - AP)

Britannia Industries

(Guj. HC)

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▪ Reason for accumulation?

▪ Export qualifies to be zero rated supply

▪ Rule 89(1) allows only supplier to claim

refund

▪ No refund to SEZ unit, if no export is made

by them, refund can only be sought by

supplier to SEZ

Without payment of taxOn payment of tax

EXPORT WITH PAYMEMT v. WITHOUT PAYMENT

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Factors

ITC on Capital Goods

Limit on Value of Exported Goods

Benefit as under Advance

Authorization

Disbursement

Procedural requirements

REFUND TYPES

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Output Stage Refund

Input Stage Refund

(Accumulated ITC)

Others

Inputs / Input

services used in

zero-rated supplies

Inverted duty

structure

IGST paid on

zero rated

supplies

Deemed

exports

Tax payment

under wrong

heads

Excess

payment of tax

Assessment /

Appeal / Any

other order

Other reasons

INVERTED DUTY STRUCTURE

37

5%

18%

Outward side

Inward side

Under Inverted Duty structure, refund granted as per below formula:

Net ITC

Turnover of Goods Tax payable on

supply of goodsAdjusted Total Turnover

Net ITC mean ITC availed on inputs

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DecisionRuling

VKC Footsteps

(Guj HC)

Transtonnelstroy Afcons Joint Venture

(Mad. HC)

Pending before SC

No benefit to Traders?

REFUND TYPES

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Output Stage Refund

Input Stage Refund

(Accumulated ITC)

Others

Inputs / Input

services used in

zero-rated supplies

Inverted duty

structure

IGST paid on

zero rated

supplies

Deemed

exports

Tax payment

under wrong

heads

Excess

payment of tax

Assessment /

Appeal / Any

other order

Other reasons

Meaning of deemed exports

(Notification 48/2017 dated October 18, 2017)

DEEMED EXPORTS

Supply of goods to Advance Authorization holder

Supply of capital goods to EPCG Authorization holder

Supply of goods to EOU / STP / EHTP / BTP

Supply of gold by Bank or PSU against Advance Authorization

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DEEMED EXPORTS

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▪ Refund of GST

available

▪ Benefit available

either to supplier or

recipient

Deemed ExporterAA or EPCG

Holder / EOU

Supply of goods

GSTExports goods

Deemed

Exporter

AA or EPCG

Holder / EOU

OR

Refund of GST available

DEEMED EXPORTS

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▪ Refund of GST

available



recipient

Deemed Exporter

Supply of goods

GSTExports goods

Deemed

Exporter


Gives declaration that

no ITC has been

availed

AA or EPCG

Holder / EOU

Files application

for refund

DEEMED EXPORTS

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▪ Refund of GST

available



recipient


Holder / EOU

Supply of goods

GSTExports goods

AA or EPCG

Holder / EOU


Files application

for refund

EXPORT REFUND IMPLICATIONS


Holder / EOU

GSTExport of goods

Without payment of tax*

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GST

AA or EPCG Holder /

EOU claims refund

Supplier or

Recipient claims

refund

*Export on payment of tax

cannot be made

Other

Procurements

REFUND TYPES

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Output Stage Refund

Input Stage Refund

(Accumulated ITC)

Others

Inputs / Input

services used in

zero-rated supplies

Inverted duty

structure

IGST paid on

zero rated

supplies

Deemed

exports

Tax payment

under wrong

heads

Excess

payment of tax

Assessment /

Appeal / Any

other order

Other reasons

REFUND OF TAX PAID IN WRONG HEAD – Section 77

CGST + SGST paid

IGST payable…

▪ Refund available for amount paid under

wrong head

▪ No interest on belated payment

Liability

CGST + SGST

Paid IGST instead of CGST + SGST

Claim refund of IGST and pay CGST + SGST

Interest liability?

45

Ruling Decision

Adithya & Ambadi Traders

(Ker HC)

Shree Nanak Ferro Alloys

(Jha HC)

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REFUND TYPES

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Output Stage Refund

Input Stage Refund

(Accumulated ITC)

Others

Inputs / Input

services used in

zero-rated supplies

Inverted duty

structure

IGST paid on

zero rated

supplies

Deemed

exports

Tax payment

under wrong

heads

Excess

payment of tax

Assessment /

Appeal / Any

other order

Other reasons

EXCESS TAX PAID - REFUND v. ADJUSTMENT

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Explanation 2 to Section 54 - Time limit to apply refund

Circular No. 26/26/2017 dated December 29, 2017, allows adjustment

Unjust Enrichment applicability

UNJUST ENRICHMENT

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Shift of burden of taxes

▪ Nature of deposits

▪ Burden of proof

▪ Recipient of supply can claim

o Exempt supplies by recipient

▪ Write-off in financial statements

▪ Increase in cost

▪ CA Certificate

UNJUST ENRICHMENT

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Shift of burden of taxes

▪ Allied Photographic India (SC) –

Uniformity in price

▪ Solar Pesticide Pvt. Ltd. (SC) –

Incidence in Financial Statements

▪ Aditya Industries (SC) – Credit Notes

issued subsequently

TDS

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APPLICABILITY

Page 51

Contract Value > Rs. 2,50,000

NN 50/2018 – Central Tax, dated September 13, 2018

Effective October 1, 2018

@ 2%

(1% CGST + 1% SGST)

Or

(2% IGST)

DEDUCTOR

Page 52

Local Authority

Department or an establishment of CG or SG

Society established by CG or SG or LA

Governmental Agencies

Public Sector Undertakings

Section – 51(1) NN: 33/2017 dated September 15, 2017

Tamil Nadu Coop. Silk

Producers Federation

Ltd., 2020 (32) GSTL 506

(AAR - GST- TN)

DEDUCTOR

Page 53

Local Authority

Department or an establishment of CG or SG

Society established by CG or SG or LA

Governmental Agencies

Public Sector Undertakings

Section – 51(1) NN: 33/2017 dated September 15, 2017

An authority or a board or any other body:

(i) Set-up by an act of Parliament or a State

Legislature; or

(i) Established by any Government,

with 51% or more participation by way of

equity or control, to carry out any function

Shapoorji Paloonji & Co.

Pvt. Ltd., 2016 (42) STR

681 (Pat.)

TRANSACTIONS

Page 54

Exempt Supplies

Non-taxable supplies

Advance for goods or services

RCM supplies

Supply by unregistered supplier

TRANSACTIONS

Page 55

Delhi

Delhi

Delhi

Supplier

Delhi

Maharashtra

Maharashtra

Recipient

Delhi

Delhi

Maharashtra

Place of Supply TDS

Maharashtra Maharashtra Delhi

PROCEDURE

Page 56

Deposit – Section 51(2)

TDS Certificate – Section

51(3)

Within 10 days of

succeeding month

Process Due Date

Within 5 days of deposit of

TDS

Interest @ 18%

Non-compliance

Late fees @ 200 / day

Return Filing – Rule 66 10th of the succeeding

monthLate fees @ 200 / day

Q&A

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