GST Refund Application Time 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.
The GST refund application time limit is two years from the "relevant date". That sentence is easy to quote and easy to get wrong, because the relevant date changes with the type of refund. Below, each category is worked through with dates, so you can see exactly when your last day falls.
Under s.54(1) a refund application must be filed before two years expire from the relevant date. The relevant date is set by Explanation 2 to s.54: ship departure for exported goods, payment receipt for exported services, return due date for SEZ supplies and inverted duty, the supplier's return date for deemed exports, and the date of payment for excess tax. Cash-ledger balances have no limit (Circular 166/22/2021-GST).
How to count the two years
Three counting rules apply to every example below.
- Start from the relevant date, not the invoice or year-end. For most categories these are different dates.
- Use the due date where the law says "due date". For SEZ supplies and inverted duty, the law uses the due date for furnishing the return under s.39, not the day you actually filed. Filing GSTR-3B late does not buy extra time.
- Add back excluded periods. Time from filing an RFD-01 to a deficiency memo (Rule 90(3) proviso) is excluded for the fresh claim.
If you would like the dates checked for a batch of periods at once, our GST refund time limit service prepares a period-by-period deadline sheet.
Deadlines by category: worked examples
All examples are illustrations using a monthly GSTR-3B filer whose return is due on the 20th of the following month.
| Category | Relevant date rule | Illustration: event | Last day to file |
|---|---|---|---|
| Goods exported by sea or air (LUT or with payment) | Ship or aircraft leaves India | Vessel sailed 12 August 2025 | 11 August 2027 |
| Goods exported by land | Goods pass the frontier | Crossed 3 March 2025 | 2 March 2027 |
| Goods exported by post | Despatch by the Post Office | Despatched 18 November 2024 | 17 November 2026 |
| Services exported, payment after completion | Receipt of payment in foreign exchange or permitted INR | Payment received 5 March 2025 | 4 March 2027 |
| Services exported, advance received | Date of invoice | Invoice issued 20 January 2025 | 19 January 2027 |
| Supplies to SEZ | Due date of the return for those supplies | July 2025 supplies, return due 20 August 2025 | 19 August 2027 |
| Deemed exports | Date the supplier's return for those supplies is furnished | Return filed 18 September 2025 | 17 September 2027 |
| Inverted duty accumulation | Due date of the return for the period of the claim | October 2025, return due 20 November 2025 | 19 November 2027 |
| Excess tax paid / other cases | Date of payment of tax | Paid 10 January 2025 | 9 January 2027 |
| Refund following an appellate order | Communication of the order | Order received 3 February 2026 | 2 February 2028 |
| Tax paid under wrong head (s.77) | Payment under the correct head (Rule 89(1A)) | Correct tax paid 15 September 2025 | 14 September 2027 |
| Unregistered buyer, cancelled flat or policy | Date of the supplier's cancellation letter (Circular 188/20/2022-GST) | Letter dated 1 June 2025 | 31 May 2027 |
| Excess balance in cash ledger | No time limit | Any | No deadline |
Category notes that change the answer
Exports of goods under LUT. One RFD-01 usually covers a tax period with many shipping bills, but each shipment has its own relevant date. If you file late for a period, the older shipments in that period can be time-barred while the newer ones are not. The officer will restrict the claim to the shipments within limit, so it pays to file each period early. For how the refund itself is computed, see GST refund calculation for export without payment.
Exports with payment of IGST. The shipping bill is itself treated as the refund application under Rule 96, so the two-year question rarely arises for the original claim. It does arise where a withheld claim or a related claim must be pursued separately.
Exports of services. The relevant date is payment, not the invoice, unless you were paid in advance. A service invoiced in 2024 but paid in 2026 has a 2028 deadline.
Deemed exports. Circular 166/22/2021-GST clarified that the date of the return filed by the supplier counts, even when the recipient files the claim.
Inverted duty. Because the date is tied to the return due date for the period, the limit runs month by month. A business that has not filed inverted-duty claims for a while should check which months are nearest to expiry.
What is close to expiry as on 30 September 2026
Illustration, using the monthly due date of the 20th:
- Inverted-duty accumulation for September 2024 (return due 20 October 2024): last day 19 October 2026.
- Inverted-duty accumulation for October 2024 (return due 20 November 2024): last day 19 November 2026.
- Export of goods shipped in October 2024: deadlines fall in October 2026, shipment by shipment.
- Services paid for in October 2024: deadlines fall in October 2026.
Quarterly (QRMP) filers have different return due dates; use your own due date for the period.
Worked illustration with a deficiency memo
Illustration: A manufacturer's inverted-duty claim for November 2024 (return due 20 December 2024) has a last day of 19 December 2026. It files on 1 December 2026. On 12 December 2026 the officer issues an RFD-03 for a missing statement.
- Days from filing to deficiency memo: 11.
- Revised last day for the fresh claim: 19 December 2026 + 11 days = 30 December 2026.
- The fresh RFD-01 must go in by then, with the missing statement attached.
Without the Rule 90(3) proviso, the fresh claim would have had only seven days.
Need help with deadlines across many periods?
If you have several months of exports or inverted-duty credit waiting, the order in which you file matters. We can list every period's relevant date and last day, and file the ones closest to expiry first. See GST refund time limit support, and use the GST refund calculator to size each claim.
Key takeaways
- Two years from the relevant date, and the relevant date is category-specific.
- SEZ and inverted-duty claims count from the return due date, not your actual filing date.
- Export claims are shipment by shipment inside one RFD-01.
- A deficiency memo does not eat into your time; the gap is added back.
- Cash-ledger refunds have no deadline.
Read next
- Relevant date for a GST refund claim under section 54
- Can a GST refund be claimed after 2 years?
- The COVID exclusion period for GST refund limitation
- GST refund time limit for department: 60 days
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.