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Refund of ITC on Capital Goods in Case of Export: What the Rules Allow

The Rule 89(4) formula refunds "Net ITC", defined as ITC availed on inputs and input services during the relevant period. ITC on capital goods is excluded, and the ICAI Refunds...

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September 30, 2026
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Last updated: October 2026Verified against: Government sources

Exporters who have just bought machinery, laptops or plant often see a large credit balance and assume it can be refunded along with other export credit. Under the LUT route it cannot. The refund formula counts credit on inputs and input services only. There are still lawful ways to turn that credit into cash, and one clear mistake to avoid.

Why capital goods credit is outside the refund formula

Section 54(3) allows refund of unutilised ITC on zero-rated supplies made without payment of tax. How much is refundable is set by Rule 89(4):

Refund = Turnover of zero-rated supply × Net ITC ÷ Adjusted Total Turnover

"Net ITC" is credit on inputs and input services. The same design applies to inverted-duty refunds, where the Handbook notes that "inputs" do not include services or capital goods. Answering the direct question in its FAQ section, the Refunds Handbook states that ITC on capital goods is explicitly excluded and is not eligible for refund under the zero-rated formula.

Credit typeEnters Net ITC for the LUT refund?Other use
Inputs (raw material, packing, consumables)Yes—
Input services (freight, rent, professional fees, cloud)Yes—
Capital goods (machinery, computers, tools)NoPay IGST on exports or domestic output tax
Blocked credit under section 17(5)NoNot available at all

If you need your credit ledger split correctly before filing, our LUT export refund team prepares the Net ITC working line by line.

Worked illustration: the LUT route

A manufacturer's quarter looks like this (round figures for illustration):

  • export turnover (lower of FOB and invoice value): ₹1.2 crore;
  • domestic turnover: ₹30 lakh;
  • ITC on inputs and input services: ₹12 lakh;
  • ITC on a new machine bought this quarter: ₹9 lakh;
  • domestic output tax paid from the ledger: ₹4 lakh.

Refund = 120 × 12 ÷ 150 = ₹9.6 lakh.

The ₹9 lakh on the machine does not enter the formula. It stays in the ledger and gets used against domestic output tax over time. With domestic output of only ₹4 lakh a quarter, the credit can take several quarters to absorb. That is the practical problem for export-heavy businesses.

The IGST route: how capital goods credit gets used

Where exports are made on payment of IGST, the tax is paid from the electronic credit ledger, and capital goods credit can be used for it like any other credit. The IGST is then refunded: for goods, through the shipping bill under Rule 96; for services, through RFD-01 under Rule 96(9). The Refunds Handbook lists this as an advantage of the IGST route: exporters can encash ITC, including credit accumulated on capital goods, that might not otherwise be refundable.

Same illustration on the IGST route. Assume an 18% rate for illustration. IGST on exports of ₹1.2 crore = ₹21.6 lakh. Assume the domestic output tax is paid in cash, so the ledger still holds ₹12 lakh (inputs) + ₹9 lakh (capital goods) = ₹21 lakh. The exporter pays ₹21 lakh from the ledger and ₹0.6 lakh in cash, and Customs refunds the full ₹21.6 lakh. The machine credit is now cash.

LUT routeIGST route
Refund in this quarter₹9.6 lakh₹21.6 lakh
Capital goods creditStays in the ledgerUsed and refunded
Tax paid up frontNone₹21.6 lakh, via ledger and cash
Risk if the claim failsDeficiency memo or rejectionRejected ITC is not re-credited automatically

Limits on switching to the IGST route

  • Restricted goods. Section 16(4) of the IGST Act lets the Government notify which exports may be made on payment of IGST. Notification 01/2023-Integrated Tax allows all goods and services except the goods listed in its table. Check your HSN before switching.
  • Data discipline. The IGST refund on goods only flows when GSTR-1 Table 6A, GSTR-3B Table 3.1(b), the shipping bill and the export manifest agree. See IGST refund not received: Table 6A mismatch.
  • Old Rule 96(10). This restriction on the IGST route for exporters receiving concessional or deemed-export supplies was omitted from 08.10.2024.
  • Choose per invoice, not both. The third proviso to section 54(3) bars an ITC refund on supplies where IGST refund is claimed.

If capital goods credit went into an LUT claim

This is a common audit point. The Refunds Handbook's position is that the excess refund has to be repaid with interest and any penalty. After the 47th GST Council meeting, Circular 174/06/2022-GST set up a re-credit mechanism: where the amount is voluntarily repaid, the corresponding credit can be restored to the electronic credit ledger. Correct it before the department raises it; see erroneous refund recovery and re-credit through PMT-03.

Need help recovering capital goods credit?

If machinery credit is locked up because your output is mostly exports, the choice between routes needs to be made with real numbers. We model both, check whether your products can go on the IGST route and file the claims. See our export refund under LUT service, or IGST refund support if you move to the payment route.

Key takeaways

  • Capital goods ITC is not refundable through the Rule 89(4) formula on the LUT route.
  • Net ITC covers inputs and input services only; keep capital goods credit out of the working.
  • The IGST route lets you pay export tax with capital goods credit and get it refunded.
  • Check Notification 01/2023-Integrated Tax before switching routes.
  • A wrong claim must be repaid with interest; Circular 174/06/2022-GST allows re-credit on voluntary repayment.

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 Refund of ITC

  • 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.

Can an exporter under LUT get a refund of ITC on machinery?

No. The Rule 89(4) formula refunds only credit on inputs and input services. Machinery credit stays in the ledger for use against output tax.

Are laptops and servers capital goods for this purpose?

If they are capitalised in the books, yes, and their credit is outside Net ITC. Many IT exporters overlook this; see GST refund for software exporters.

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

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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.

No. The Rule 89(4) formula refunds only credit on inputs and input services. Machinery credit stays in the ledger for use against output tax.

If they are capitalised in the books, yes, and their credit is outside Net ITC. Many IT exporters overlook this; see GST refund for software exporters.

No. The inverted-duty formula also excludes capital goods and input services.

The LUT permits exports without payment of tax; it does not force you to use it for every invoice. GSTR-1 records "with payment" or "without payment of tax" invoice by invoice, so report each export consistently and never claim both refunds on the same invoice.

The Refunds Handbook warns that the corresponding ITC is not automatically re-credited, and the exporter may have to pursue it. That is the main risk of the IGST route.

No. The cap limits the export turnover for goods in the LUT formula. It has nothing to do with capital goods credit, which is outside the formula anyway.