GST Refund Time Limit 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.
When people search for a GST refund time limit extension, they are usually thinking of the COVID relief. For refund claims, the government did not extend a date. It excluded a whole window, 1 March 2020 to 28 February 2022, from the two-year count. Every claim that benefited has now run out, but the exclusion still decides appeals against refunds that were rejected as time-barred.
Notification 13/2022-Central Tax excluded the period 1 March 2020 to 28 February 2022 from the computation of limitation for filing refund applications under s.54 and s.55. Days inside that window do not count toward the two years in s.54(1). There is no general power to extend the refund time limit today; the remaining tools are the relevant-date rules, the deficiency-memo exclusion and the cash-ledger exception.
What the exclusion actually says
Section 168A of the CGST Act lets the government, on the Council's recommendation, extend time limits that cannot be met because of force majeure. Using that power, Notification 13/2022-CT dated 5 July 2022 provided that the period from 1 March 2020 to 28 February 2022 shall be excluded in computing the period of limitation for filing a refund application under s.54 or s.55.
Two features matter:
- It is an exclusion, not an extension to a fixed date. You take the two-year count, stop it on 29 February 2020, and restart it on 1 March 2022.
- It covers refund applications under both sections: ordinary refunds under s.54 and refunds for UN bodies and embassies under s.55.
Note that the ICAI Handbook on Refunds (January 2026 edition) focuses on current procedure and does not reproduce this notification; the text should be read from the notification itself when relied on in an appeal.
If you are working through an old rejection, our GST refund time limit review recomputes the limitation for each period with the exclusion applied.
How to count it: three situations
The excluded window is exactly two years long (730 days). That gives a simple rule of thumb: for a claim whose count was running on 1 March 2020, the deadline moves by two years.
| Where the relevant date falls | How to count | Illustration |
|---|---|---|
| Before 1 March 2020, deadline would have fallen inside the window | Days used before 1 March 2020 count; the balance runs from 1 March 2022 | Relevant date 15 June 2019: original deadline about 14 June 2021, revised about 14 June 2023 |
| Inside the window | Nothing counts until 1 March 2022; full two years from then | Relevant date 10 October 2020: deadline around the end of February 2024 |
| On or after 1 March 2022 | No effect | Normal two-year count |
The illustrations use round dates. When an actual appeal turns on a few days, count them exactly, including leap-year days.
Why it still matters in 2026
By the end of February 2024 the last claims protected by the exclusion had expired. So nobody can use it today to file a new claim. It matters in two places:
- Pending appeals. Refunds for 2018–2022 periods rejected as time-barred where the order ignored the excluded window. The appellate authority or GSTAT can set these aside.
- Rejections that are still within the appeal time. Old claims are still being decided; a rejection order issued now can still be challenged.
If an order says "time-barred" for a period between 2018 and early 2022, check it against the exclusion before anything else. It is one of the most common errors in old refund orders.
Worked illustration
Illustration: An exporter of services received payment for a completed service on 15 June 2019. It filed RFD-01 for the ITC refund on 20 March 2023. The officer rejected the claim as time-barred on the view that the two years ended in June 2021.
| Step | Calculation |
|---|---|
| Relevant date | 15 June 2019 (receipt of payment, Explanation 2(c) to s.54) |
| Days used before 1 March 2020 | 15 June 2019 to 29 February 2020 = 260 days |
| Balance of the two years | 730 − 260 = 470 days |
| Balance runs from | 1 March 2022 |
| Revised deadline | about mid-June 2023 |
| Filing date | 20 March 2023: within time |
The rejection is wrong on limitation. The exporter would appeal the RFD-06 rejection order, citing Notification 13/2022-CT, and the merits of the claim would then be examined.
Other routes when time looks short today
Since there is no active extension now, the tools that remain are:
- Relevant date: it differs for exports, services, SEZ, inverted duty and appellate orders, and is often later than assumed.
- Deficiency memo exclusion: the proviso to Rule 90(3) excludes time from filing to the RFD-03 for the fresh claim.
- Cash ledger: excess balance has no two-year limit at all (Circular 166/22/2021-GST).
Each of these is worked through in GST refund deadline worked examples by category and can a GST refund be claimed after 2 years?.
Need help with an old refund rejected as time-barred?
If a refund for 2018–2022 was rejected on limitation, the exclusion window may reverse the result. We can recompute the dates, check whether the appeal is still in time and draft the grounds. See our GST refund time limit support or, if an order is already in hand, GST refund rejection support. For all refund categories, see our GST refund services.
Key takeaways
- Notification 13/2022-CT excluded 1 March 2020 to 28 February 2022 from limitation for refund applications under s.54 and s.55.
- It pauses the count; it does not set a new fixed date.
- Every protected claim expired by the end of February 2024; the exclusion now matters mainly in appeals.
- Today there is no general extension power for refund limitation; check relevant date, deficiency-memo time and the cash-ledger exception instead.
Read next
- GST refund time limit: two years and the relevant date explained
- Appealing a refund rejection order
- GST refund rejected as time-barred: remedies
- GST refund deadline worked examples by category
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.