Share Certificate Format — Form SH-1 Under Companies Act 2013
GST Refund Experts · Updated 16 July 2026
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GST Refund Time Limit — 2 Years from the Relevant Date
Under Section 54(1) of the CGST Act, a GST refund application in Form RFD-01 must be filed within 2 years from the “relevant date” — and the relevant date changes with the type of refund. Miss it and the claim is time-barred. TaxClue’s CA team tracks your deadline, computes the refund, and files before the clock runs out.
2 Yrs
Filing Limit
60d
Sanction Deadline
7d
Provisional 90%
6%
Delay Interest
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GST Refund Time Limit2 Years — Section 54Relevant DateForm RFD-01RFD-02 in 15 Days60-Day Sanction6% Interest u/s 56CA Managed100% OnlineGST Refund Time Limit2 Years — Section 54Relevant DateForm RFD-01RFD-02 in 15 Days60-Day Sanction6% Interest u/s 56CA Managed100% Online
Direct Answer
What is the GST Refund Time Limit?
The GST refund time limit is 2 years from the “relevant date” under Section 54(1) of the CGST Act, 2017. Any person claiming a refund of tax, interest, or any other amount must file Form RFD-01 on the GST portal before this 2-year window closes. The law does not provide any general power to condone a delay beyond 2 years.
The catch: the “relevant date” is different for each type of refund. It is defined in Explanation 2 to Section 54 — for export of goods it is linked to the date of shipment, for export of services to receipt of foreign exchange or invoice, for inverted duty structure to the due date of the return for the period, and for excess payment to the date of payment. Getting the relevant date wrong is one of the most common reasons genuine refunds become time-barred.
One important exception: refund of excess balance in the electronic cash ledger (claimed under Section 49(6) read with Section 54) is not subject to the 2-year bar — CBIC has clarified that this limitation does not apply to cash-ledger balance refunds, since it is your own deposited money, not tax legally collected.
⏳
2-Year Clock Starts on the “Relevant Date” — Not the Transaction Date
For an exporter of services, the clock may start on the date foreign exchange is received — months after the invoice. For inverted duty structure, it runs from the due date of the GSTR-3B for the period in which the claim arises. Always compute the relevant date first, then the deadline.
What’s Included
- Free time-limit & relevant date check
- Refund amount computation by CA
- RFD-01 preparation & filing
- Supporting statements & annexures
- Deficiency memo (RFD-03) replies
- RFD-04 / RFD-06 order tracking
- Interest claim u/s 56 where delayed
Relevant Date Master Table
Relevant Date for Each Refund Type
Explanation 2 to Section 54 of the CGST Act defines the relevant date. The 2-year filing window for Form RFD-01 runs from this date.
| Refund Scenario | Relevant Date (2-Year Clock Starts) |
|---|---|
| Export of goods — by sea or air | Date the ship or aircraft carrying the goods leaves India |
| Export of goods — by land | Date the goods pass the customs frontier |
| Export of goods — by post | Date of despatch of goods by the Post Office to a place outside India |
| Export of services — supply completed before payment received | Date of receipt of payment in convertible foreign exchange (or INR where permitted by RBI) |
| Export of services — advance received before invoice | Date of issue of the invoice |
| Deemed exports | Date of filing the return relating to such deemed export supplies |
| Inverted duty structure — unutilised ITC u/s 54(3) | Due date for furnishing the return u/s 39 (GSTR-3B) for the period in which the refund claim arises |
| Finalisation of provisional assessment | Date of adjustment of tax after final assessment |
| Refund arising from appeal / court order | Date of communication of the judgment, decree, direction or order |
| Refund to a person other than the supplier (recipient) | Date of receipt of the goods or services by such person |
| Excess balance in electronic cash ledger | Per CBIC clarification, the 2-year limitation does not apply — can be claimed any time via RFD-01 |
| Any other case (excess / erroneous payment etc.) | Date of payment of tax |
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Inverted duty structure — note the change: before the Finance Act, 2022 amendment, the relevant date was the end of the financial year in which the ITC accumulated. It is now the due date of the Section 39 return (GSTR-3B) for the period in which the claim arises — a period-wise clock, generally a tighter deadline. See our inverted duty structure refund guide.
Departmental Timelines
How Long Does the Department Get? RFD-02 to RFD-06
01
RFD-01 Filed
Refund application filed on GST portal with statements & supporting documents. ARN generated.
Day 002
RFD-02 Acknowledgement
Officer must acknowledge a complete application (or issue deficiency memo RFD-03) within 15 days — Rule 90.
Within 15 Days03
RFD-04 Provisional (Exports)
For zero-rated supply claims, 90% of the amount is sanctioned provisionally within 7 days of acknowledgement — Section 54(6), Rule 91.
Within 7 Days04
RFD-06 Final Order
Final sanction/rejection order must be passed within 60 days of receipt of the complete application — Section 54(7).
Within 60 Days05
Credit + Interest if Late
Refund credited to bank. If sanctioned beyond 60 days, interest at 6% p.a. runs automatically under Section 56.
Beyond 60d = Interest| Stage / Situation | Statutory Timeline | Provision |
|---|---|---|
| Acknowledgement (RFD-02) or deficiency memo (RFD-03) | 15 days from filing | Rule 90, CGST Rules |
| Provisional refund for zero-rated supplies (RFD-04) — 90% | 7 days from acknowledgement | Sec 54(6), Rule 91 |
| Final sanction order (RFD-06) | 60 days from complete application | Sec 54(7) |
| Interest on refund delayed beyond 60 days | 6% p.a. from expiry of 60 days till payment | Sec 56 |
| Interest where refund arises from a final appellate / court order and remains unpaid 60 days after the consequent claim | 9% p.a. | Proviso to Sec 56 |
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Deficiency memo resets the clock: if the officer issues RFD-03, the application is treated as not filed and a fresh RFD-01 must be submitted — and the fresh filing must itself still be within the 2-year limit. Filing a clean, complete application the first time matters. Track every stage with our GST refund status guide.
Missed the Deadline?
What Happens If You Miss the 2-Year Limit
Claim Is Time-Barred
An RFD-01 filed after 2 years from the relevant date is liable to be rejected as time-barred. There is no general condonation provision under Section 54.
Cash Ledger Is the Exception
Excess balance lying in the electronic cash ledger can still be claimed — CBIC has clarified the 2-year bar does not apply to cash-ledger balance refunds.
Limited Judicial Relief
High Courts have, in specific fact situations, granted relief on limitation — but this is litigation, not a right. Never plan around it.
COVID-Era Exclusion (Historical)
By Notification 13/2022-Central Tax, the period 1 March 2020 to 28 February 2022 was excluded from the limitation period for refund claims. Relevant only for old-period claims.
Re-Filing After RFD-03
A fresh application after a deficiency memo must also be within 2 years — deficiency cycles close to the deadline are dangerous.
File Early, Not on Day 729
Portal errors, statement mismatches, and document gaps take time to fix. A buffer of several months before the deadline is the safe practice.
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Chartered Accountants experienced in GST refunds across export, inverted duty, excess payment, and order-based claims.
Relevant Date Mapped First
We compute the correct relevant date for every invoice and period before filing — so no claim dies on limitation.
Clean First-Time Filing
Complete statements and documents from day one — minimising deficiency memos that reset the clock.
Interest u/s 56 Claimed
Where the department crosses 60 days, we pursue the 6% (or 9%) statutory interest along with your refund.
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Frequently Asked Questions
GST Refund Time Limit — Questions Answered
Under Section 54(1) of the CGST Act, a refund application in Form RFD-01 must be filed within 2 years from the relevant date. The relevant date differs by refund type — date of shipment for export of goods, receipt of foreign exchange for export of services (where supply precedes payment), due date of the GSTR-3B for the period for inverted duty structure, and date of payment of tax for excess payment cases.
If exported by sea or air: the date the ship or aircraft leaves India. By land: the date the goods pass the customs frontier. By post: the date of despatch by the Post Office to a place outside India. The 2-year window for RFD-01 runs from that date.
Where the supply of services was completed before payment was received, the relevant date is the date of receipt of payment in convertible foreign exchange (or INR where permitted by RBI). Where payment was received in advance before the invoice, it is the date of issue of the invoice. In practice, the clock generally starts on the later of the two events for each invoice-remittance pair.
No 2-year bar applies. CBIC clarified (Circular 166/22/2021-GST) that the limitation under Section 54(1) does not apply to a refund of excess balance in the electronic cash ledger, since it is the taxpayer’s own deposited money. It is still claimed through Form RFD-01, but can be filed any time.
The officer must issue an acknowledgement (RFD-02) or deficiency memo (RFD-03) within 15 days of filing. For zero-rated supply claims, 90% is sanctioned provisionally (RFD-04) within 7 days of acknowledgement. The final order (RFD-06) must be passed within 60 days of receipt of the complete application under Section 54(7).
If the refund is not sanctioned within 60 days of a complete application, interest at 6% p.a. under Section 56 runs from the expiry of the 60 days till the date of refund. Where the refund arises from a final order of an adjudicating/appellate authority or court and remains unpaid 60 days after the consequent application, the proviso to Section 56 provides 9% p.a.
Generally no — Section 54 contains no condonation provision, and late applications are rejected as time-barred. Two narrow exceptions: (1) excess cash-ledger balance has no 2-year bar; (2) for old periods, Notification 13/2022-Central Tax excluded 1 March 2020 to 28 February 2022 (COVID period) from the limitation computation. Courts have occasionally granted relief in exceptional facts, but that is uncertain litigation — not a plan.
After the Finance Act, 2022 amendment, it is the due date for furnishing the return under Section 39 (GSTR-3B) for the period in which the claim arises. Earlier it was the end of the financial year in which the ITC accumulated. Each tax period therefore has its own 2-year deadline — see our inverted duty structure refund guide.
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