GST Refund Undertaking Format 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.
A GST refund claim carries undertakings, meaning promises to repay if a later fact goes against you. They are not the same as the Letter of Undertaking (LUT) you file in RFD-11 before exporting. This guide gives specimen wording for each refund undertaking and explains where each one applies.
Refund undertakings are filed with or after the RFD-01 claim. The main ones are: (1) the section 16(2)(c) undertaking to repay if your supplier has not paid the tax; (2) for exports of goods, the undertaking under section 16 IGST read with Rule 96B to repay if export proceeds are not realised; (3) the deemed-export recipient's undertaking under Rule 89(1) letting the supplier claim; and (4) the undertaking not to file an appeal under the Explanation to Rule 93, which triggers PMT-03 re-credit. The LUT in FORM GST RFD-11 (Rule 96A) is a separate, pre-export document.
Refund undertakings vs the LUT: keep them apart
| Point | Refund undertakings (this article) | LUT in RFD-11 |
|---|---|---|
| Legal basis | s.16(2)(c); s.16 IGST with Rule 96B; Rule 89(1) proviso; Rule 93 Explanation | Rule 96A; s.16(3) IGST |
| When given | With the refund claim, or after a rejection order | Before export, usually once per financial year |
| Purpose | Protect revenue after the refund is paid | Permit export without paying IGST |
| Promise made | Repay refund with interest if a condition fails | Pay tax with interest if goods are not exported or payment not received within the time allowed |
| Where filed | Inside RFD-01, or to the proper officer | Separate RFD-11 on the portal |
If you are looking for the LUT itself, see LUT (Letter of Undertaking) filing. The rest of this article is about undertakings in the refund file. Our GST refund process service handles both, but they are filed at different times.
Undertaking 1: Section 16(2)(c), the supplier-payment undertaking
Section 16(2)(c) conditions ITC on the tax having actually been paid to the Government by your supplier. The CBIC checklist requires this undertaking in almost every RFD-01 category. The original form text also refers to section 42(2), a matching provision since omitted.
Specimen (adapt before use). I/We hereby undertake to pay back to the Government the amount of refund sanctioned, along with interest, in case it is found subsequently that the requirements of clause (c) of sub-section (2) of section 16 of the CGST/SGST Act have not been complied with in respect of the amount refunded. For M/s ______ (GSTIN ______) | Authorised signatory: ______ | Date: ______
Illustration. A refund of ₹5,00,000 of unutilised ITC is sanctioned. Later it emerges that a supplier who accounted for ₹40,000 of that credit never paid the tax. The undertaking commits the claimant to repay the relatable refund with interest, without contesting the premise.
Undertaking 2: Export proceeds, section 16 IGST read with Rule 96B
For refunds on export of goods, the checklist adds an undertaking tied to Rule 96B. If refund of unutilised ITC or IGST has been paid but the sale proceeds are not realised in India within the period allowed under FEMA (including extensions), the exporter must deposit the refund with interest within 30 days of that period ending. If the RBI writes off the realisation requirement, no recovery is made. If proceeds come in later, the recovered amount is refunded on evidence produced within three months of realisation.
Specimen (adapt before use). I/We hereby undertake that, in respect of the exports covered by this claim, if the sale proceeds are not realised in full or in part within the period allowed under the Foreign Exchange Management Act, 1999 (including any extension), I/we shall deposit the refund relatable to the unrealised amount, along with applicable interest, within thirty days of expiry of that period, in terms of rule 96B of the CGST Rules, 2017.
For more on the recovery mechanics, see Rule 96B recovery where export proceeds are not realised.
Undertaking 3: Deemed exports, the recipient's undertaking
Under the proviso to Rule 89(1), a deemed-export refund may be filed by the recipient, or by the supplier where the recipient does not avail ITC on those supplies and furnishes an undertaking that the supplier may claim the refund.
Specimen (to be given by the recipient, on its letterhead, adapt before use). We, M/s ______ (GSTIN ______), recipient of deemed export supplies under invoices listed below from M/s ______ (GSTIN ______), hereby undertake that we have not availed and shall not avail input tax credit of the tax paid on the said supplies, and have not claimed and shall not claim refund of such tax. We have no objection to the supplier claiming refund of the tax paid on these supplies. Invoice No. / Date / Value / Tax: ______
For the documents that go with it, see deemed export refund: who claims and the undertakings.
Undertaking 4: Not to file an appeal, which releases PMT-03 re-credit
When ITC-based refund is rejected, the debited credit is not re-credited straight away. Under the Explanation to Rule 93, a refund is deemed rejected only when the appeal is finally rejected or the claimant gives an undertaking in writing that he shall not file an appeal. The master refund circular says the officer re-credits the rejected amount through FORM GST PMT-03 only after receiving that undertaking or the final appellate outcome.
Specimen (adapt before use). To the Proper Officer, ______ (jurisdiction) Ref: Order in FORM GST RFD-06 No. ______ dated ______ (ARN ______) I/We hereby undertake that I/we shall not file an appeal against the rejection of ₹______ in the above order, and request re-credit of the said amount to the electronic credit ledger by an order in FORM GST PMT-03.
Think before signing. Once you give it, the rejected portion is final. See re-credit of rejected refund in PMT-03.
Drafting tips
- Name the period, ARN and amount. An undertaking without identifiers is a common deficiency.
- Sign as the authorised signatory shown in the registration. For online undertakings, the DSC or EVC used for RFD-01 serves as the signature.
- Don't mix them. An RFD-11 LUT does not cover the Rule 96B refund undertaking, and the reverse is also true.
Need help with refund undertakings?
Undertakings look routine, but each one creates a repayment obligation. We review which ones your claim actually needs, draft them to your facts, and advise on the no-appeal undertaking before you give up a right. See our GST refund process service, or start at the GST refund hub.
Key takeaways
- Refund undertakings protect revenue after a refund. The LUT (RFD-11) is a separate pre-export permission.
- The section 16(2)(c) undertaking appears in almost every RFD-01 category.
- Export-of-goods claims add a Rule 96B undertaking on realisation of proceeds.
- Deemed-export suppliers need the recipient's undertaking under the Rule 89(1) proviso.
- An undertaking not to appeal is what releases PMT-03 re-credit of rejected ITC. Use it deliberately.
Read next
- GST refund declaration form: formats
- CA certificate for GST refund: format
- Deemed export refund: who claims and the undertakings
- How to claim a GST refund on exports without payment (LUT)
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.