Deemed Export Refund Documents 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.
Most deemed export refunds that fail do so on paperwork, not on eligibility. The supply may genuinely be to an EOU or an Advance Authorisation holder, but a missing acknowledgement, an unsigned undertaking or a Statement 5B that does not match the returns is enough for a deficiency memo. This guide lists what each side needs.
Rule 89(2)(g) requires a statement of invoices along with the evidence notified for deemed exports. For a supplier claim, that evidence is in Notification 49/2017-CT: for AA/EPCG supplies, the acknowledgement by the jurisdictional tax officer of the authorisation holder; for EOU supplies, the endorsed tax invoice and the EOU's undertakings that it has not availed ITC and will not claim refund. For a recipient claim, the invoices go in Statement 5B with the recipient's undertaking and a declaration that the supplier has not claimed. Both sides give the s.16(2)(c) undertaking and the Rule 89(2)(l) declaration or 89(2)(m) CA certificate.
The legal hook: Rule 89(2)(g)
Rule 89(2)(g) asks for "a statement containing the number and date of invoices along with such other evidence as may be notified in this behalf, in a case where the refund is on account of deemed exports". The "other evidence" was notified in Notification 49/2017-CT, and the procedure for EOU and similar units is in Circular 14/14/2017-GST. Circular 125/44/2019-GST then set out the undertakings each side must give. Our deemed exports refund service works from this checklist when preparing a claim.
Supplier's document checklist
| Document | Applies to | Source |
|---|---|---|
| Statement 5B: invoice number, date, value, tax | All deemed exports | Rule 89(2)(g) |
| Acknowledgement by the jurisdictional tax officer of the AA or EPCG holder that the supplies were received | Supplies against AA or EPCG | Notification 49/2017-CT |
| Tax invoice endorsed by the EOU that the supplies were received | Supplies to EOU | Notification 49/2017-CT; Circular 14/14/2017-GST |
| Undertaking by the recipient that it has not availed ITC on the supplies | Supplies to EOU (and all supplier claims, per Circular 125) | Notification 49/2017-CT |
| Undertaking by the recipient that it will not claim refund and the supplier may claim | Supplies to EOU (and all supplier claims) | Notification 49/2017-CT; Rule 89(1) second proviso |
| Copy of Form-A prior intimation from the EOU | Supplies to EOU | Circular 14/14/2017-GST |
| Declaration under Rule 89(2)(g) | All | Handbook Annexure |
| Undertaking in relation to s.16(2)(c) | All | Handbook Annexure |
| Self-declaration (up to ₹2 lakh) or CA certificate in Annexure 2 (above ₹2 lakh) on unjust enrichment | All | Rule 89(2)(l)/(m) |
The recipient's undertaking must be uploaded electronically by the supplier with the application, as the ICAI Handbook on Refunds notes.
Recipient's document checklist
| Document | Source |
|---|---|
| Statement 5B listing the invoices on which refund is claimed | Rule 89(2)(g); Circular 125/44/2019-GST |
| Undertaking that refund is claimed only for the invoices in Statement 5B and does not exceed the ITC availed in the valid return for the period | Circular 125/44/2019-GST (as amended by Circular 147/03/2021-GST) |
| Declaration that the supplier has not claimed refund on these supplies | Circular 125/44/2019-GST |
| Supplier's undertaking that it will not claim refund | Handbook, Types of Refund chapter |
| Documents required under Circular 14/14/2017-GST (Form-A, endorsed invoice, Form-B records for EOU/EHTP/STP/BTP units) | Handbook Annexure |
| Declaration under Rule 89(2)(g); undertaking on s.16(2)(c) | Handbook Annexure |
| Self-declaration or CA certificate on unjust enrichment | Rule 89(2)(l)/(m) |
The recipient also debits its electronic credit ledger by the amount claimed when filing. See supplies to EOU: deemed export refund by recipient for why.
Statement 5B: getting it right
Statement 5B is the invoice-level table of deemed export supplies. Common errors:
- Invoices not in GSTR-1 Table 6C. The supplier reports deemed export invoices in Table 6C of GSTR-1 and the value in Table 3.1(a) of GSTR-3B. A mismatch between Statement 5B and the supplier's return stalls the claim.
- Recipient claims more than ITC availed. The undertaking caps the claim at the ITC availed in the valid return for the period.
- Mixed periods. Keep invoices in the tax period in which they belong; the relevant date is tied to the supplier's return for those supplies.
- Missing endorsement numbers. Link each invoice to its endorsement or acknowledgement so the officer can trace it.
Illustration. A supplier to an AA holder files a claim for 12 invoices totalling ₹90,00,000 with GST of ₹16,20,000 (illustration). Statement 5B lists all 12. The jurisdictional officer's acknowledgement is available for 10 invoices (GST ₹13,50,000). The officer can sanction only ₹13,50,000 and will issue a deficiency memo or reject the balance. Collect the two missing acknowledgements before filing.
Unjust enrichment: which paper
| Refund amount claimed | What to attach |
|---|---|
| Up to ₹2 lakh | Self-declaration under Rule 89(2)(l) |
| Above ₹2 lakh | CA or cost accountant certificate in Annexure 2 to RFD-01 under Rule 89(2)(m) |
The Handbook's annexure lists this requirement for both supplier and recipient deemed export claims. For the format, see CA certificate for GST refund.
Before you file
- Agree in writing with the counterparty which side is claiming.
- Collect the acknowledgement (AA/EPCG) or endorsed invoice (EOU) for every invoice.
- Reconcile Statement 5B with the supplier's GSTR-1 Table 6C.
- Get the undertakings signed on letterhead by an authorised signatory.
- Check the two-year limit from the date of the supplier's return.
Need help assembling a deemed export refund file?
We can reconcile Statement 5B with the returns, collect the right acknowledgements and undertakings from your counterparty, and file and respond to any RFD-03 memo. See our deemed export refund support, or the GST refund calculator for other refund types.
Key takeaways
- Rule 89(2)(g) needs a statement of invoices plus the evidence notified in Notification 49/2017-CT.
- AA/EPCG supplies need the jurisdictional officer's acknowledgement; EOU supplies need the endorsed invoice and undertakings.
- Recipients file Statement 5B with an undertaking capping the claim at ITC availed, and a declaration that the supplier has not claimed.
- Both sides attach the s.16(2)(c) undertaking and the unjust-enrichment declaration or CA certificate.
- Reconcile Statement 5B with the supplier's GSTR-1 Table 6C before filing.
Read next
- Deemed export refund: who claims and the undertakings
- GST refund checklist: documents for each type
- GST refund undertaking format
- How to respond to a GST refund deficiency memo (RFD-03)
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.