GST Refund Circular List 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.
Search for "GST refund circular" and you get dozens of numbers with no context. This page lists the CBIC circulars on refunds that the ICAI Handbook on Refunds under GST (January 2026) relies on, grouped by topic, with one line on what each says. Use it to find the right circular before replying to a deficiency memo or a notice.
The base document is Circular 125/44/2019-GST (18.11.2019), the master refund circular. It has been modified most importantly by Circular 135/05/2020-GST (clubbing across years, GSTR-2A, cash/credit split) and Circular 197/09/2023-GST (GSTR-2B from 01.01.2022). Circular 166/22/2021-GST confirms no two-year limit for cash-ledger refunds. For exports, the key ones are 8/8/2017 (LUT), 131/1/2020 (exporter SOP) and 226/20/2024 (upward price revision). Circulars bind officers, not courts: several have been read down by High Courts.
How to use this list
- Circulars are administrative clarifications. They bind the department but cannot restrict a right the Act gives. The Handbook records the Delhi High Court's observation (Pitambra Books) that the Government cannot use a circular to impose stricter conditions than the law.
- A later circular can modify an earlier one. Always read the chain, for example 125 → 135 → 173.
- Where a circular conflicts with a later rule amendment, the rule prevails.
If you have a refund order or memo that cites a circular and you are not sure it applies to your period, our GST refund process service can check the chain and draft the reply.
General procedure and processing
| Circular | Date | What it covers |
|---|---|---|
| 125/44/2019-GST | 18.11.2019 | Master refund circular: all categories in RFD-01, fully electronic from 26.09.2019; deficiency memo rules; Annexure-A document list |
| 135/05/2020-GST | 31.03.2020 | Clubbing across financial years allowed; ITC refund limited to invoices in GSTR-2A; cash/credit split for other refunds |
| 197/09/2023-GST | 17.07.2023 | GSTR-2B as the basis for ITC refunds for periods from 01.01.2022; refund after voluntary payment under Rule 96A |
| 139/09/2020-GST | (not dated in the Handbook) | GSTR-2A restriction does not apply to imports, ISD and RCM credit |
| 26/26/2017-GST | 29.12.2017 | Rectification of GSTR-3B errors; officers refer to it when GSTR-1 and GSTR-3B differ |
| 59/33/2018-GST | 04.09.2018 | Re-credit of amounts rejected (para 4.2 guidelines, also applied after appellate orders) |
| 174/06/2022-GST | (not dated in the Handbook) | Re-credit of ITC where an erroneous refund is repaid voluntarily |
For how the master circular works stage by stage, read Circular 125 GST refund explained. For what 135 changed and what survives, read Circular 135 GST refund explained.
Cash ledger, excess tax and wrong head
| Circular | Date | What it covers |
|---|---|---|
| 24/24/2017-GST | 21.12.2017 | Earlier manual route (RFD-01A) for cash-ledger refunds; replaced by electronic RFD-01 from 26.09.2019 |
| 166/22/2021-GST | 17.11.2021 | No two-year limit for excess cash-ledger balance; no unjust-enrichment certificate for it; TDS/TCS credited to the cash ledger is refundable as cash balance; relevant date for deemed exports |
| 162/18/2021-GST | 25.09.2021 | "Subsequently held" in s.77 CGST / s.19 IGST covers cases the taxpayer finds himself, not only those held by officers |
See section 77 refund of tax paid under the wrong head and refund of excess balance in the cash ledger.
Exports and zero-rated supplies
| Circular | Date | What it covers |
|---|---|---|
| 8/8/2017-GST (amended by 40/14/2018-GST) | 04.10.2017 | LUT/bond procedure for exports without payment of tax |
| 5/5/2017-GST, 88/07/2019-GST | 11.08.2017, 01.02.2019 | Exports to Nepal and Bhutan and SEZ supplies as exports even if paid in INR (with 8/8/2017) |
| 48/22/2018-GST | 14.06.2018 | Supplies to SEZ units and developers |
| 108/27/2019-GST | 18.07.2019 | Goods sent abroad for exhibition or on consignment |
| 131/1/2020-GST | 23.01.2020 | Standard operating procedure for verification of exporters flagged as risky |
| 147/03/2021-GST | 12.03.2021 | The 1.5× cap on export value also applies inside Adjusted Total Turnover in Rule 89(4) |
| 160/16/2021-GST | 20.09.2021 | Goods with NIL export duty are not "subjected to export duty"; ITC refund not barred |
| 161/17/2021-GST | 20.09.2021 | An Indian company and a foreign company are separate persons (relevant to export of services to group entities) |
| 175/07/2022-GST | 06.07.2022 | Refund on export of electricity (Statement 3B) |
| 226/20/2024-GST | 11.07.2024 | Refund of additional IGST on upward price revision after export; relevant date is the debit note date |
For the export side in full, see GST refund for exporters.
Inverted duty
| Circular | Date | What it covers |
|---|---|---|
| 135/05/2020-GST (para 3.2) | 31.03.2020 | No refund where input and output are the same goods |
| 173/05/2022-GST | 06.07.2022 | Substituted para 3.2: refund allowed where a concessional notification lowers the output rate at the same point of time |
| 181/13/2022-GST | 10.11.2022 | Amended Rule 89(5) formula (Notification 14/2022-CT) applies to applications filed on or after 05.07.2022 |
Parts of Circular 181 have been challenged successfully. See inverted duty refund: Circular 181 cannot override section 54(3). Our inverted duty refund service handles these claims.
Deemed exports
| Circular | Date | What it covers |
|---|---|---|
| 14/14/2017-GST | 06.11.2017 | Procurement procedure for EOU, EHTP, STP and BTP units under deemed exports |
| 147/03/2021-GST | 12.03.2021 | Tax on deemed export supplies made available as ITC to recipients so they can claim refund on the portal |
| 172/04/2022-GST | 06.07.2022 | That ITC is not ITC under Chapter V, so section 17 restrictions do not apply to it |
| 166/22/2021-GST | 17.11.2021 | Relevant date is the supplier's return date, whoever files the claim |
Special categories
| Circular | Date | What it covers |
|---|---|---|
| 188/20/2022-GST | 27.12.2022 | Unregistered buyers on cancelled flat or long-term insurance contracts: temporary registration, Statement 8, relevant date = supplier's cancellation letter |
| 36/10/2018, 43/17/2018, 63/37/2018, 68/42/2018 | 2018 | UIN agencies (UN bodies, embassies) refunds in RFD-10, including compensation cess |
| 60/34/2018-GST | 04.09.2018 | Canteen Stores Department refunds (manual, earlier procedure) |
| 227/21/2024-GST | 11.07.2024 | CSD refunds filed electronically in RFD-10A |
Three chains worth remembering
- Clubbing periods: 125 (bar across financial years) → 135 (bar removed).
- Invoice matching: 135 (GSTR-2A) → 197 (GSTR-2B from 01.01.2022), with 139 exceptions for imports, ISD and RCM.
- Same-goods inverted duty: 135 (no refund) → 173 (allowed under concessional notifications) → High Court rulings reading the restriction down.
Need help matching a circular to your refund?
Officers often quote one circular without the later one that modified it. We read the full chain for your period, then answer the memo or notice on that footing. See our GST refund process support, or begin at the GST refund hub.
Key takeaways
- Circular 125/44/2019 is the master refund circular; read it with 135 and 197.
- Circular 166/22/2021 removes the two-year limit for cash-ledger refunds.
- Export refunds lean on 8/8/2017, 131/1/2020, 147/03/2021 and 226/20/2024.
- Inverted duty: 135 → 173 → 181, and the courts have limited parts of these.
- Circulars bind officers but cannot restrict rights given by the Act.
Read next
- Circular 125 GST refund explained
- Circular 135 GST refund explained
- GST refund rules list: Rule 89 to 97A
- Refund rejection on non-statutory conditions (Tata Steel)
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.