GST Refund on Deemed Exports — Statement 5B, Notification 48/2017-CT, RFD-01

Deemed exports are notified supplies where goods do not leave India but are still treated as exports for refund purposes. Under Notification 48/2017-Central Tax, these include supplies against an Advance Authorisation, supplies of capital goods against an EPCG authorisation, and supplies to an Export Oriented Unit (EOU). Unlike ordinary zero-rated supplies, deemed exports are taxable — GST is paid, and the tax is then claimed back as a refund in Form GST RFD-01 using Statement 5B under Rule 89. Either the supplier or the recipient may claim the refund (subject to declarations), and it must be filed within 2 years of the relevant date.

Statement 5B

Refund routeDeemed-export refunds are claimed in RFD-01 using Statement 5B under Rule 89 — by the supplier or the recipient, with declarations.

Understand It

What Is Deemed Export GST Refund?

A plain-language explanation of deemed exports before the detail.

In simple terms

Deemed exports are supplies where the goods stay in India but are treated like exports for refund purposes — for example, supplies to an EOU or against an Advance Authorisation. GST is charged and paid on these supplies, and that tax can be recovered as a refund by either the supplier or the recipient.

Legally

Under Section 147 of the CGST Act, 2017, the Government may notify certain supplies of goods as deemed exports. Notification 48/2017-Central Tax notifies four categories, including supplies against Advance Authorisation, supplies of capital goods against EPCG, and supplies to an EOU. The refund of tax paid is granted under Section 54 read with Rule 89 of the CGST Rules, 2017.

Governing authority

Filed on the GST portal (gst.gov.in) and processed by the jurisdictional Central/State GST refund officer. Deemed exports are notified through CBIC notifications and third-proviso conditions in the CGST Rules.

Validity

The refund application must be filed within 2 years from the relevant date. Deemed exports are a taxable supply — the refund is of the tax that was actually paid, not of accumulated ITC under the zero-rating route.

Service Intelligence

Quick Facts

Refund Form

GST RFD-01

Statement

Statement 5B

Notification

48/2017-Central Tax

Government Fee

Nil

Time Limit

2 years of relevant date

Who claims

Supplier OR recipient

Governing Law

CGST s.54, s.147, Rule 89

Mode

100% Online (GST portal)

Legal & Regulatory Framework

Deemed exports

CGST Act 2017, s.147

Notification

48/2017-Central Tax

Refund

CGST Act 2017, s.54 & s.56

Rule / Statement

Rule 89 · Statement 5B

Authority

Jurisdictional GST officer

Last Reviewed

17 Aug 2026

Before You Start

Is This Service Right for You?

Ideal for

Manufacturers supplying against an Advance Authorisation
Suppliers of capital goods against an EPCG authorisation
Vendors supplying goods to an Export Oriented Unit (EOU)
EOUs recovering GST on their notified inward supplies
Advance-authorisation holders receiving notified supplies
Suppliers who paid GST on notified deemed-export supplies

You may need this if

You supplied goods against an Advance Authorisation or EPCG
You supplied goods to an EOU and paid GST on them
You are an EOU / recipient recovering tax on inward supplies
You are unsure whether the supplier or recipient should claim
You need the deemed-export declarations assembled correctly
You want to file Statement 5B within the 2-year window

Not sure if you need this?

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Why It Matters

Why Claim a Refund on Deemed Exports?

Deemed-export supplies attract GST even though they support exports. Recovering that tax keeps it from becoming a real cost to the supply chain.

01

Recover Tax Paid

Deemed exports are taxable, so GST is actually paid on them. That tax is refundable in full — leaving it unclaimed makes it a permanent cost.
02

Backed by Notification 48/2017

The categories that qualify — supplies against Advance Authorisation, capital goods against EPCG, and supplies to an EOU — are notified under Notification 48/2017-Central Tax.
03

Supplier or Recipient Can Claim

Either the supplier or the recipient may claim the refund, subject to the prescribed declarations. Choosing the right claimant avoids duplicate or blocked claims.
04

Correct Statement 5B

Deemed-export refunds are filed using Statement 5B in RFD-01. Preparing it correctly at invoice level is what gets the claim sanctioned.
05

Declaration Discipline

The claim depends on declarations — for example, that the recipient will not claim ITC where the supplier claims the refund. Getting these right is essential.
06

Protect the Time Limit

The claim must be filed within 2 years of the relevant date. Filing correctly the first time avoids losing the refund to limitation.

Transparent

Simple, Transparent Pricing

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Eligibility

Who Can Apply?

Suppliers against Advance Authorisation

Suppliers of capital goods against EPCG

Suppliers of goods to an EOU

EOUs recovering tax on inward supplies

Advance-authorisation holders (recipients)

Registered persons with valid declarations

Eligibility checklist

The supply falls within a category notified under Notification 48/2017-Central Tax
GST was charged and paid on the deemed-export supply and reflected in returns
Only one of the supplier or the recipient is claiming the refund for a given supply
Where the supplier claims: recipient's declaration that it has not availed ITC of that tax
Where the recipient claims: supplier's declaration that it will not claim the refund
The application (Statement 5B) is filed within 2 years from the relevant date

End-to-End

Everything You Need. One Professional Team.

01

Category & Claimant Check

Confirm the supply is a notified deemed export and decide whether the supplier or the recipient should claim.

02

Data Reconciliation

Match deemed-export invoices against GSTR-1, GSTR-3B and the electronic ledgers.

03

Statement 5B Preparation

Prepare Statement 5B with invoice-level detail in the prescribed format.

04

Declarations Assembly

Compile the required supplier / recipient declarations and undertakings for the file.

05

RFD-01 Filing

File the refund application in Form GST RFD-01 on the portal with all annexures.

06

ARN & Deficiency Tracking

Track the ARN, and respond to any RFD-03 deficiency memo by re-filing correctly.

07

Query & SCN Handling

Draft replies to officer queries and any show-cause notice (RFD-08) on your behalf.

08

Sanction Follow-up

Follow the claim through to final sanction (RFD-06) and payment order (RFD-05).

No Ambiguity

What You’ll Receive

Deemed-export category & claimant assessment

Reconciliation of supplies with GSTR-1 & GSTR-3B

Prepared Statement 5B (invoice-level)

Assembled supplier / recipient declaration pack

Filed Form GST RFD-01 with ARN acknowledgement

Replies to any RFD-03 deficiency memo or officer query

Show-cause (RFD-08) reply where required

Refund sanction (RFD-06) & credit tracking

Checklist

Documents Required for a Deemed-Export Refund

The claim rests on Statement 5B plus the declarations that establish who is claiming. Keep clear scans of invoices, authorisations and the prescribed declarations ready.

01

Core documents

GST registration certificate (REG-06) and login
Tax invoices for the deemed-export supplies (with GST charged)
Statement 5B (invoice-wise detail of deemed-export supplies)
Proof of payment of tax on the supplies (reflected in GSTR-3B)
GSTR-1 and GSTR-3B for the relevant tax period(s)
CA / cost-accountant certificate where the refund exceeds ₹2,00,000, where applicable

02

Authorisation / EOU proof

Copy of the Advance Authorisation / EPCG authorisation, where applicable
For EOU supplies: proof of receipt in the EOU (e.g. Form A / prior intimation to jurisdictional officer, as prescribed)
Purchase order or supply document evidencing the notified category

03

Declarations & undertakings

Where the supplier claims: declaration from the recipient that it has not availed input tax credit of the tax, and that it will not claim the refund
Where the recipient claims: declaration from the supplier that it will not claim the refund of the same tax
Undertaking on non-passing of tax incidence (unjust-enrichment declaration)

Important before you file

Only notified supplies qualify

Only the categories notified under Notification 48/2017-Central Tax — supplies against Advance Authorisation, capital goods against EPCG, and supplies to an EOU — are deemed exports. Other supplies do not use this route.

Supplier or recipient — not both

For a given supply, the refund is claimed by either the supplier or the recipient, not both. If the supplier claims, the recipient must not have availed ITC of that tax; if the recipient claims, the supplier must not claim the refund.

Statement 5B is the vehicle

Deemed-export refunds are filed using Statement 5B in RFD-01 — distinct from Statement 4/5 used for SEZ and zero-rated exports.

CA certificate above ₹2 lakh

Where the refund claimed exceeds ₹2,00,000, a Chartered Accountant / Cost Accountant certificate on non-passing of tax incidence is generally required (Rule 89(2)(m)).

File within two years

The application must be filed within 2 years of the relevant date. Identify the relevant date for the deemed-export supply carefully.

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Step by Step

How the Deemed-Export Refund Is Claimed (Step by Step)

The entire claim is filed online on gst.gov.in under Rule 89.

01

Confirm category & claimant

Verify the supply falls under Notification 48/2017-CT and decide whether the supplier or recipient will claim the refund.

02

Assemble declarations

Collect the supplier / recipient declarations that establish the claimant and non-availment of ITC as applicable.

03

Reconcile invoices & returns

Match deemed-export invoices to GSTR-1 and GSTR-3B and confirm the tax was paid.

04

Prepare Statement 5B

Build Statement 5B at invoice level with the unjust-enrichment declaration and CA certificate where required.

05

File RFD-01 on the portal

Submit Form GST RFD-01 under the deemed-export category, upload annexures, and debit the claimed amount.

06

ARN & acknowledgement

Receive the ARN; the officer issues an acknowledgement (RFD-02) if the application is complete.

07

Respond & receive sanction

Answer any RFD-03 deficiency memo or RFD-08 notice; on approval the officer issues RFD-06 and the payment order RFD-05.

How Long It Takes

How the Deemed-Export Refund Moves Through Processing

Stage	Expected Time
Acknowledgement (RFD-02) after filing RFD-01	Within 15 days if the application is complete
Deficiency memo (RFD-03), if any — re-file afresh	On scrutiny of the application
Show-cause notice (RFD-08), where issued — reply in RFD-09	On the officer's examination
Final sanction (RFD-06) & payment order (RFD-05)	Statutory outer limit 60 days from complete application

These are the statutory processing steps under Section 54 and Rule 89–92. If the refund is not paid within 60 days of a complete application, interest under Section 56 (6%, or 9% in certain appeal cases) applies. Deemed-export refunds are not eligible for the 90% provisional route that applies to zero-rated supplies. Deficiency memos pause the clock.

Why Outsource

Doing It Yourself vs TaxClue

Doing It Yourself

Confirm the supply is a notified deemed export under 48/2017-CT
Decide whether the supplier or recipient should claim
Obtain the correct declarations from the other party
Reconcile deemed-export invoices with GSTR-1 and GSTR-3B
Prepare Statement 5B at invoice level in the right format
Respond to RFD-03 deficiency memos within the window
Draft replies to RFD-08 show-cause notices

With TaxClue

Expert confirms the notified category and the right claimant
Declarations assembled correctly for the chosen route
Invoices reconciled with your returns before filing
Statement 5B prepared accurately at invoice level
CA certificate coordinated where refund exceeds ₹2 lakh
Deficiency memos answered and re-filed correctly
Show-cause replies drafted by our team

Skip the guesswork.

Let an expert handle it →

Avoid Delays

Common Mistakes That Delay Your Application

Treating a non-notified supply as a deemed export

Both supplier and recipient claiming refund on the same supply

Missing the recipient's / supplier's declaration for the chosen claimant

Recipient availing ITC of the tax the supplier is claiming as refund

Using Statement 4/5 instead of Statement 5B

Deemed-export invoices not matching GSTR-1 and GSTR-3B

Missing CA / cost-accountant certificate where refund exceeds ₹2,00,000

No declaration on non-passing of tax incidence (unjust enrichment)

Expecting a 90% provisional refund (not available for deemed exports)

Filing after the 2-year relevant-date limitation

TaxClue reviews your documents before filing to reduce avoidable errors.

What If

What Happens If Your Application Is Rejected?

Supply not covered by Notification 48/2017-Central Tax
Required supplier / recipient declaration missing or inconsistent
Refund amount mismatched with returns / ledger balances
Deficiency memo (RFD-03) not corrected and re-filed

If a deficiency memo (RFD-03) is issued, the application is treated as not filed and must be submitted afresh within the limitation period. We correct the flagged issues and re-file, and reply to any RFD-08 show-cause notice to protect the claim.

Risk Assessment

Penalties & Consequences

What is at stake if you do not comply

Treating a non-notified supply as a deemed export gets the whole claim rejected
Both supplier and recipient claiming on the same supply blocks both claims
A missing supplier / recipient declaration invalidates the chosen claimant
No CA certificate where the refund exceeds ₹2,00,000 stalls the claim
The refund lapses if Statement 5B is not filed within 2 years of the relevant date

Latest Updates

Regulatory Updates 2025–26

2025: GST refund applications are filed in Form RFD-01 within 2 years of the relevant date under Section 54.

The Difference

Why Businesses Choose TaxClue

01

GST Refund Focus

Deemed-export and zero-rated refunds handled by a team that files them regularly.

02

Right Claimant, Clean Declarations

We decide supplier vs recipient and assemble the matching declarations.

03

Statement 5B Done Right

Accurate, invoice-level Statement 5B that holds up in scrutiny.

04

Transparent Fees

A clear, itemised quote upfront — no surprises, government fee is nil.

05

Status Visibility

ARN and sanction tracked and reported to you throughout.

06

End-to-End Support

From reconciliation to sanction — including query and notice handling.

Data Care

Your Documents Deserve Professional Care

Documents handled by professionals under confidentiality
Access limited to the team working on your refund file
Communication over secure digital channels
Records retained only as long as needed for compliance

Answers

Frequently Asked Questions

What are deemed exports under GST?

Deemed exports are supplies of goods notified under Section 147 of the CGST Act where the goods do not leave India but are treated as exports for refund purposes. Notification 48/2017-Central Tax notifies the qualifying categories, including supplies against an Advance Authorisation, supplies of capital goods against an EPCG authorisation, and supplies to an Export Oriented Unit (EOU).

How are deemed exports different from zero-rated supplies?

Zero-rated supplies (physical exports and supplies to SEZ) can be made without payment of tax under a LUT, or on payment with a refund of that tax. Deemed exports are taxable — GST is charged and paid on the supply, and the tax paid is then claimed back as a refund. Deemed exports also use Statement 5B, whereas SEZ and export refunds use Statements 4, 5, 2 or 3.

Which form and statement are used for a deemed-export refund?

The refund is claimed in Form GST RFD-01, filed online under Rule 89, using Statement 5B for the invoice-wise detail of the deemed-export supplies.

Who can claim the deemed-export refund — the supplier or the recipient?

Either the supplier or the recipient may claim the refund of tax paid on deemed-export supplies, subject to the prescribed declarations. For a given supply only one of them claims it: if the supplier claims, the recipient must not have availed input tax credit of that tax; if the recipient claims, the supplier must furnish an undertaking not to claim the refund.

What declarations are required for a deemed-export refund?

Where the supplier claims, a declaration from the recipient that it has not availed input tax credit of the tax and will not claim the refund is required. Where the recipient claims, an undertaking from the supplier that it will not claim the refund is required. A declaration on non-passing of tax incidence (unjust enrichment) is also needed.

What supplies qualify under Notification 48/2017-Central Tax?

The notified categories include: supply of goods against an Advance Authorisation; supply of capital goods against an EPCG authorisation; supply of goods to an Export Oriented Unit (EOU/EHTP/STP/BTP); and supply of gold by a bank or PSU against an Advance Authorisation. Only these notified supplies are treated as deemed exports.

Is there a time limit to claim the refund?

Yes. The application must be filed within 2 years from the relevant date under Section 54 of the CGST Act. The relevant date for deemed exports is determined as prescribed, so it should be identified carefully for each claim.

Is a provisional refund available for deemed exports?

No. The 90% provisional refund route applies to zero-rated supplies of goods or services. Deemed-export refunds are processed on full verification, with sanction in Form RFD-06 and the payment order in RFD-05.

Do I need a CA certificate for a deemed-export refund?

Where the refund claimed exceeds ₹2,00,000, a certificate from a Chartered Accountant or Cost Accountant certifying that the incidence of tax has not been passed on is generally required under Rule 89(2)(m). Smaller claims can rely on a self-declaration.

Can an EOU claim the GST paid on its inward supplies?

Supplies of goods to an EOU are a notified deemed export, so the tax paid on those supplies is refundable. Either the supplier of the goods or the EOU recipient can claim the refund, subject to the required declarations — including that the party not claiming the refund does not take input tax credit or a separate refund of the same tax.

What is the relevant date for a deemed-export refund?

For deemed exports, the relevant date is the date on which the return relating to the deemed-export supplies is furnished, as prescribed under the definition of relevant date in Section 54. Because the exact trigger depends on the facts, we confirm it for your case before computing the 2-year limit.

What happens if a deficiency memo (RFD-03) is issued?

A deficiency memo means the application is treated as if it was never filed. The claim must be corrected and submitted afresh within the 2-year limitation period. We identify the flagged issue, fix it, and re-file so the claim is not lost.

Is interest payable if the refund is delayed?

Yes. If a complete refund application is not sanctioned within 60 days, interest under Section 56 of the CGST Act is payable — 6% per annum in the normal case, and 9% per annum in certain cases arising from an order in appeal or other proceedings.

How do I claim a GST refund on deemed exports step by step?

Confirm the supply is notified under Notification 48/2017-Central Tax and decide whether the supplier or recipient will claim. Assemble the required declarations, reconcile the deemed-export invoices with GSTR-1 and GSTR-3B, prepare Statement 5B at invoice level, and file Form GST RFD-01 under the deemed-export category within 2 years of the relevant date.

What is the difference between deemed exports and physical exports for refunds?

Physical exports and SEZ supplies are zero-rated under Section 16 of the IGST Act — you can supply without tax under LUT and claim ITC, or on payment and claim the IGST back. Deemed exports under Section 147 are taxable — GST is paid on the domestic supply and then refunded. They use Statement 5B, not the Statement 2/3/4/5 used for zero-rated exports and SEZ.

Can the recipient claim the deemed-export refund instead of the supplier?

Yes. For deemed exports, either the supplier or the recipient may claim the refund of tax paid, but only one of them for a given supply. If the recipient (for example an EOU or Advance Authorisation holder) claims, the supplier must furnish an undertaking not to claim the refund; if the supplier claims, the recipient must not have availed ITC of that tax.

Is a CA certificate needed for a deemed-export refund?

Where the refund claimed exceeds ₹2,00,000, a certificate from a Chartered Accountant or Cost Accountant on non-passing of the tax incidence is generally required under Rule 89(2)(m). Claims of ₹2,00,000 or less can be supported by a self-declaration on unjust enrichment.

What is the relevant date for a deemed-export refund?

For deemed exports, the relevant date is generally the date on which the return relating to the deemed-export supplies is furnished, as prescribed under the definition of relevant date in Section 54. The 2-year limit to file the RFD-01 claim runs from this date, so it should be identified carefully for each supply.

Verify Everything

Official Sources & Legal References

Every regulatory figure on this page — sections, the notification, statements and timelines — is drawn from primary law and official government sources. Verify them directly:

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