Last reviewed: 13 November 2026. An exporter can either export under a Letter of Undertaking without paying IGST, or pay IGST on the export and claim it back. For goods, the shipping bill itself is the refund application, so there is no RFD-01 to file; for services, the claim is filed on the GST portal. Both routes changed in 2026: small goods consignments are no longer barred by the ₹1,000 floor, intermediaries serving overseas clients can now export, and CBIC has clarified which foreign receipts count.
Part of our GST refund series. For every refund category, the common process, time limits and interest, start with the complete GST refund guide.
Goods: how the rule 96 refund actually works
Under rule 96 of the CGST Rules, the shipping bill filed by the exporter is deemed to be an application for refund of IGST paid on the goods. It becomes a valid application only when two things are in place: the export general manifest (EGM) has been filed by the carrier, and the exporter has filed a valid GSTR-3B for the month. The GST system then transmits the invoice details reported in Table 6A of GSTR-1 to ICEGATE, Customs validates them against the shipping bill, and the refund is credited to the bank account registered with Customs against the exporter's AD code.
| Check | What must match | Typical problem |
|---|---|---|
| GSTIN | Same GSTIN on shipping bill and GSTR-1 | Exports made under one registration and returns filed under another |
| Invoice number and date | Identical in shipping bill and GSTR-1 Table 6A | A commercial invoice number used on the shipping bill and a GST invoice number in the return (the commonly seen SB005 error) |
| IGST amount | IGST in GSTR-1 and GSTR-3B not less than the shipping bill | IGST paid in GSTR-3B lower than the export invoices, or shown as a domestic supply |
| EGM | Filed and linked to the shipping bill | Carrier or agent has not filed the EGM, or it carries an error |
| Bank account | Validated account against the AD code on ICEGATE | Account changed without updating Customs records |
Mismatches are corrected at the Customs end (through the port's mismatch-resolution process) or by amending the return details, depending on which side is wrong. Refunds can also be withheld under rule 96(4) where verification is pending, for instance when the exporter is flagged on risk parameters. A withheld refund is then examined by the jurisdictional GST officer and decided by an order.
Services: the RFD-01 route
For services exported on payment of IGST, the claim is filed in RFD-01 under the category for refund of IGST paid on export of services, with an invoice-wise statement and evidence of receipt of payment. Section 54(6) allows a provisional refund of 90% of the claim, and from 1 November 2026 rule 91(2) has the portal generate the provisional order in RFD-04 within three working days of acknowledgement, subject to system risk evaluation.
The service must meet all five conditions of an export in section 2(6) of the IGST Act: supplier in India, recipient outside India, place of supply outside India, payment received in convertible foreign exchange or in Indian rupees where RBI permits, and the supplier and recipient not being merely establishments of the same person.
What changed in 2026 for exporters paying IGST
- Small consignments. Section 54(14) bars refunds below ₹1,000. From 1 November 2026 that bar no longer applies to tax paid on goods exported with payment of tax, which helps courier and postal exporters.
- Intermediaries. Section 13(8)(b) of the IGST Act was omitted by the Finance Act, 2026 with effect from 30 March 2026. The place of supply of intermediary services now follows the recipient's location, so an Indian intermediary acting for an overseas principal can qualify as an exporter and claim refunds. Our note on export of services and the intermediary change covers this in detail.
- Foreign receipts. Circular 263/09/2026-GST clarifies that proceeds received in convertible foreign exchange or in repatriable INR accounts such as SNRR and INR Nostro accounts satisfy the export condition, as does settlement by set-off against import payables done in line with RBI directions. Special Rupee Vostro receipts were already accepted under Circular 202/14/2023-GST.
- Rule 96(10) disputes. Rule 96(10), which denied IGST refunds to exporters who had used certain input concessions, was omitted from 8 October 2024. Circular 264/10/2026-GST directs that pending proceedings be decided in line with the Supreme Court's ruling, treating the omission as applying to them, and extends the same treatment to rules 89(4A) and 89(4B). It does not reopen cases that have become final.
- Non-realisation. Under rule 96B, a refund must be returned with interest if export proceeds are not realised within the FEMA period. Circular 263 confirms no recovery is made where the realisation requirement has been written off by the RBI or the authorised dealer bank.
Worked example: one month's export of goods
An exporter ships goods worth ₹40,00,000 in August 2026 under three shipping bills and pays IGST of ₹7,20,000 at 18%, using input tax credit. Two shipping bills are refunded within the month. The third shows an invoice mismatch because the shipping bill carries invoice EXP/112 while GSTR-1 shows 2026-27/112. The fix is to align the record at Customs, after which the refund of that bill is released through ICEGATE. Nothing is filed in RFD-01 for any of the three bills.
IGST route or LUT route?
Paying IGST and claiming it back keeps credit moving and is useful where input credit is large and fully usable. Exporting under LUT avoids blocking cash but requires a formula-based claim of unutilised credit. The comparison is in our guide to refunds of unutilised ITC on exports under LUT. The IGST route is not available, as a matter of law, for certain notified goods, and where IGST paid is refunded, the same supply cannot also earn a refund of credit or drawback of central tax.
Frequently asked questions
Do I need to file RFD-01 for refund of IGST paid on export of goods?
No. Under rule 96 the shipping bill is deemed to be the refund application once the EGM is filed and a valid GSTR-3B is on record. The GST system shares the GSTR-1 Table 6A data with ICEGATE and Customs credits the refund to the bank account linked to the AD code.
Why is my IGST export refund not received?
Usually because of a data mismatch: invoice number or date differs between the shipping bill and GSTR-1, the EGM is missing, IGST in GSTR-3B is lower than the export invoices, or the bank account is not validated with Customs. The refund may also be withheld under rule 96(4) pending verification.
Can I claim refund of IGST below ₹1,000 on a small export?
From 1 November 2026, yes for goods exported with payment of tax. The Finance Act, 2026 amended section 54(14) so that the ₹1,000 floor does not apply to these refunds. Other refund categories remain subject to the floor, computed on the total across tax heads.
How is IGST refund on export of services claimed?
Through RFD-01 on the GST portal, with an invoice-wise statement and proof of receipt of payment. The claim qualifies for a 90% provisional refund, and the portal generates the provisional order within three working days of acknowledgement from 1 November 2026.
Are payments received in an SNRR account valid for export of services?
Yes. Circular 263/09/2026-GST treats receipts in convertible foreign exchange or in repatriable INR accounts such as SNRR and INR Nostro accounts as meeting the payment condition of section 2(6) of the IGST Act, and accepts RBI-compliant set-off against import payables.
Can an intermediary claim an export refund now?
For supplies from 30 March 2026, the place of supply of intermediary services to an overseas recipient is the recipient's location, because section 13(8)(b) of the IGST Act has been omitted. If the other export conditions are met, the supply is zero-rated and refund routes are open.
We review eligibility, build the computation and reconciliations from your books and returns, file the RFD-01, and handle deficiency memos, show cause notices and appeals until the claim is closed. The outcome rests with the proper officer; our work is to put a complete, defensible claim in front of them.
GST refund servicesGST refund support for exportersGST notices and appealsBook a consultation
This article is for general information and does not constitute advice on any specific case. Sources: sections 54 to 56 and 77 of the CGST Act, 2017; rules 89 to 97 of the CGST Rules, 2017 as amended by Notification No. 05/2026-Central Tax dated 26 October 2026; Notification No. 03/2026-Central Tax; CBIC circulars cited in the text. Rules, forms and portal functionality change; confirm the current position on the CBIC tax repository and the GST portal before filing. Firm details: Somesh Chandak & Associates, Chartered Accountants, Unit 119, 1st Floor, Centura Square IT Park, SG Barve Road, Wagle Estate, Thane West 400604. FRN 158694W.