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GST Refund Temporary Registration: How Unregistered Applicants File

Notification 26/2022-CT and Circular 188/20/2022-GST (27.12.2022) created the route. The applicant obtains temporary registration on the portal using PAN, choosing the same...

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GST
Published
September 30, 2026
Last updated
Oct 1, 2026
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6 min
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Last updated: October 2026Applies to: FY 2026-27Verified against: Government sources

If you are not registered under GST but paid GST on a flat booking or a long-term insurance policy that was later cancelled, the GST portal lets you file a refund claim yourself. To do that, you first take a temporary registration on the portal. It is not a normal GST registration: it exists only so that you can file the refund application and receive the money.

Before you start: check you actually need this

The route exists only where the supplier cannot refund the GST itself. The ICAI Handbook on Refunds, summarising Circular 188/20/2022-GST, says that if the supplier can still issue a credit note under s.34 at the time of cancellation, the supplier should refund the tax directly and no application by the unregistered person is needed. So the first step is to ask the builder or insurer. Eligibility and the documents are covered in GST refund for unregistered persons on cancelled contracts. Our excess tax paid refund service can check this before you register.

Step 1: Temporary registration

RequirementDetail
IdentifierYour PAN
State/UTThe same State or UT in which your supplier (builder or insurer) is registered
AuthenticationAadhaar authentication
Bank accountIn your own name and linked to your PAN

If you have contracts with suppliers registered in two different States, you need a temporary registration in each of those States, because each refund application relates to a supplier in that State.

Step 2: Prepare Statement 8 and the documents

Statement 8 is the statement inserted into RFD-01 by Notification 26/2022-CT for this category, and it is uploaded as a PDF. Along with it, Rule 89(2)(ka) and (kb) require:

DocumentRule
Invoice details: number, date, value, tax paid and payment details, with copies of invoices89(2)(ka)
Proof of payment made to the supplier89(2)(ka)
Agreement, registered agreement or contract with the supplier89(2)(ka)
Supplier's letter cancelling or terminating the agreement or contract89(2)(ka)
Details and proof of the amount received back from the supplier89(2)(ka)
Supplier's certificate: tax paid on these invoices, not adjusted by credit note, and no refund claimed or to be claimed by the supplier89(2)(kb)

No CA certificate on unjust enrichment is needed where an unregistered person who has borne the tax claims the refund (proviso to Rule 89(2)(m)). Proof of tax payment is part of the file.

Step 3: File RFD-01

Log in with the temporary registration and file RFD-01 under the category "Refund for Unregistered Person". Keep in mind:

  • the claim cannot exceed the tax shown in the invoices;
  • one application per supplier;
  • separate applications for suppliers registered in different States/UTs; and
  • under s.54(14), no refund is paid where the amount is below ₹1,000.

Step 4: Time limit

Two years from the relevant date. For these cancelled long-term contracts, Circular 188/20/2022-GST treats the date of issue of the cancellation letter by the supplier as the relevant date, because the service for the unrendered portion was never received. Count carefully: see relevant date for a GST refund claim.

Step 5: Processing and sanction

The proper officer processes the claim like any other RFD-01: acknowledgement in RFD-02 or a deficiency memo in RFD-03, then a sanction order in RFD-06 with a detailed speaking order. Where the supplier refunded less than the full amount you paid, only the tax proportionate to the amount refunded is granted.

Illustration. A policyholder paid premiums of ₹10,00,000 plus GST of ₹1,80,000 on a long-term policy (illustration). The insurer terminates the policy and refunds ₹8,00,000 of premium, with no GST.

ItemAmount
GST paid₹1,80,000
Premium refunded as a share of premium paid₹8,00,000 ÷ ₹10,00,000 = 80%
GST refundable on proportionate basis₹1,44,000

The refund is paid to the PAN-linked bank account you gave at registration. Under s.54(8)(e), where the unregistered person has borne the tax, the refund is paid to that person, not to the Consumer Welfare Fund.

Common problems

ProblemFix
Temporary registration taken in your home State, not the supplier'sRegister in the supplier's State/UT
Bank account not in your name or not linked to PANUse your own PAN-linked account
Supplier refuses the (kb) certificateAsk for it in writing, citing Rule 89(2)(kb); without it the claim is incomplete
Supplier could still issue a credit noteThe supplier should refund the tax; this route is not available
Two suppliers in one applicationFile separately for each supplier
Claim filed more than two years after the cancellation letterTime-barred; see time-barred refund remedies

For the home buyer's version of this process, see GST refund on flat cancellation.

Need help with a temporary registration refund?

We can check whether the supplier should refund the tax directly, obtain the supplier's certificate, set up the temporary registration in the right State and file the claim with Statement 8. See our unregistered-person and excess tax refund support, or the full GST refund service.

Key takeaways

  • Temporary registration lets an unregistered buyer file a GST refund on a cancelled flat booking or long-term insurance policy.
  • Register with PAN in the supplier's State/UT, complete Aadhaar authentication and give a PAN-linked bank account in your name.
  • File RFD-01 under "Refund for Unregistered Person" with Statement 8 and Rule 89(2)(ka)/(kb) documents.
  • File separately for each supplier; the claim cannot exceed tax on the invoices.
  • The two years run from the supplier's cancellation letter.

Read next

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.

Quick recapKey facts & short answers

Key Facts About GST Refund Temporary Registration

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

What is temporary registration for a GST refund?

A registration an unregistered person obtains on the GST portal, using PAN, only to file a refund claim under "Refund for Unregistered Person".

In which State should I take temporary registration?

In the same State or UT as the supplier from whom you bought the service.

One person should own every deadline. A deadline that belongs to everyone belongs to no one.

— TaxClue Compliance Desk

GST Refund Temporary Registration: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Vikas Sharma Verified expert Tax & Compliance Expert

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

People also ask

Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

A registration an unregistered person obtains on the GST portal, using PAN, only to file a refund claim under "Refund for Unregistered Person".

In the same State or UT as the supplier from whom you bought the service.

Yes. Circular 188/20/2022-GST, as summarised in the ICAI Handbook, requires Aadhaar authentication and a bank account in your name linked to your PAN.

The statement in RFD-01 for refunds claimed by unregistered persons, uploaded as a PDF with the supporting documents.

No. A separate application is needed for each supplier, and for suppliers in different States.

Then the builder should refund the GST directly, and you do not need to apply.