CA Certificate explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
A CA certificate for a GST refund is the unjust-enrichment certificate in Annexure 2 of FORM GST RFD-01. It confirms that the tax you want back has not been passed on to your customer. It is needed only for claims above ₹2 lakh, and only in refund types where unjust enrichment applies.
Rule 89(2)(m) requires a certificate in Annexure 2 of RFD-01, issued by a chartered accountant or cost accountant, where the refund claimed exceeds ₹2 lakh. It confirms that the incidence of tax, interest or other amount has not been passed on. Up to ₹2 lakh, a self-declaration under Rule 89(2)(l) is enough. No certificate is needed for cases under section 54(8)(a), (b), (c), (d) or (f), such as exports and unutilised ITC, for an unregistered person who bore the tax, or for excess cash-ledger refunds.
When the certificate is required
The test has two parts: the amount, and whether unjust enrichment applies to the category.
| Refund type | Unjust enrichment applies? | Up to ₹2 lakh | Above ₹2 lakh |
|---|---|---|---|
| Excess payment of tax | Yes | Self-declaration 89(2)(l) | CA/CMA certificate 89(2)(m) |
| Refund arising from assessment/appeal/other order | Generally yes | Self-declaration | Certificate |
| "Any other" ground | Yes | Self-declaration | Certificate |
| SEZ supplies with payment, deemed exports | Listed in the circular checklist | Self-declaration | Certificate |
| Exports, unutilised ITC (LUT, SEZ without payment, inverted duty) | No: s.54(8)(a)/(b) | Not legally required | Not legally required |
| Tax on a supply not provided, no invoice issued | No: s.54(8)(c) | Not required | Not required |
| Wrong head of tax (s.77) | No: s.54(8)(d) | Not required | Not required |
| Excess cash-ledger balance | No (Circular 166/22/2021-GST) | Not required | Not required |
| Unregistered person who bore the tax | Rule 89(2)(m) second proviso | – | Not required |
The CBIC checklist still lists the 89(2)(l)/(m) item against some ITC categories, so the portal may prompt for it. If your claim falls under an exempt clause, a short note citing the proviso is usually enough. Many applicants still attach the certificate to avoid a deficiency memo. Our GST refund process team can tell you which applies to your category before you pay for a certificate.
Specimen Annexure 2 certificate
This specimen follows the substance of Annexure 2 to RFD-01. Adapt it to your facts. The CA should issue it on letterhead with UDIN, as required by ICAI for certificates.
CERTIFICATE UNDER RULE 89(2)(m) OF THE CGST RULES, 2017 (Annexure 2 to FORM GST RFD-01), specimen to adapt This is to certify that in respect of the refund amounting to ₹________ (Rupees ________ only) claimed by M/s ________ (legal name), GSTIN ________, for the tax period ________ under the category "________", the incidence of tax, interest or any other amount claimed as refund has not been passed on to any other person. This certificate is based on the examination of the books of account and other relevant records and returns particulars maintained/furnished by the applicant, including sales invoices, credit notes, price lists and ledger accounts for the period. Signature: ________ Name of Chartered Accountant/Cost Accountant: ________ Membership No.: ________ Firm Registration No.: ________ UDIN: ________ Place: ________ Date: ________
What the CA actually checks
A certificate is not a formality. Explanation (ii) to Rule 89(2) says that where tax has been recovered from the recipient, the incidence is deemed to have been passed on to the ultimate consumer. So the CA looks for evidence that it was not recovered:
- Invoices. Did the tax invoice charge GST to the customer? If so, the burden has moved to the customer unless a credit note reversed it.
- Credit notes. Were credit notes issued under section 34 to reverse the tax charged?
- Accounting. Is the excess tax sitting as a receivable or expense in the claimant's books, rather than recovered from debtors?
- Pricing. Was the price fixed and inclusive, so that a tax error came out of the supplier's margin?
- Returns. Does the excess show in GSTR-3B, and is it absent from the recipient's recovery?
Illustration. A trader paid ₹3,00,000 of IGST on a transaction that was actually intra-State. The customer was billed IGST. The trader pays CGST+SGST correctly and seeks the IGST back under section 77. Section 54(8)(d) covers this, so no unjust-enrichment certificate is required. Now take a different trader who paid ₹3,00,000 extra tax through a GSTR-3B keying error, never billed to anyone. That is an excess-payment refund above ₹2 lakh, and it needs the Annexure 2 certificate backed by the ledger showing the tax was borne by the trader.
Where the certificate is uploaded
Upload it with the RFD-01 application among the supporting documents. The ARN is generated only after all statements, declarations and documents are uploaded. A missing certificate in a category that needs one is a standard ground for a deficiency memo in RFD-03.
Need help with the unjust-enrichment test?
If your claim is above ₹2 lakh and arises from excess payment, an order, or a cancelled supply, we can review whether the tax was passed on, arrange the Annexure 2 certificate, and file the claim. See GST refund process support. For refunds of tax paid in excess or under the wrong head, see excess tax paid refunds.
Key takeaways
- The CA certificate is the Annexure 2 unjust-enrichment certificate under Rule 89(2)(m).
- It is needed only above ₹2 lakh and only where unjust enrichment applies. Below that, a Rule 89(2)(l) self-declaration suffices.
- Exports, unutilised ITC, supplies not provided, s.77 cases and notified classes are outside it (s.54(8)(a) to (d), (f)).
- Excess cash-ledger refunds need no certificate (Circular 166/22/2021-GST).
- Tax recovered from the recipient is deemed passed on, so the CA's evidence must show otherwise.
Read next
- GST refund declaration form: formats
- GST refund undertaking format
- Section 77: refund of tax paid under the wrong head
- Refund of excess balance in the electronic cash ledger
Disclaimer: Positions stated as on 30 September 2026, based on the CGST Act and Rules as amended, the Finance Act 2026, and the ICAI Handbook on Refunds under GST (January 2026). Verify current notifications before filing.