The GSTN portal update on 08.05.2025 aims to streamline refund filing for exporters by shifting to an invoice-based process and eliminating unnecessary steps like selecting refund periods. While this is a welcome move, on-ground challenges like refund pile-ups, data mismatches, and officer delays persist.
Categories Affected by the Update on 08.05.25
-
Export of Services with payment of tax
-
Supplies to SEZ (Unit or Developer) with payment of tax
-
Deemed Exports (where the supplier files for refund)
Key Changes Introduced (08.05.2025)
| Aspect | Previous System | New System (Post 08.05.2025) |
|---|---|---|
| Period Selection | Manually select From–To | Auto-handled by system |
| Refund Basis | Tax period-based | Invoice-based |
| Invoices Editing | Amendable anytime | Locked post-application |
| Application Trigger | After period closure | Directly by refund category |
| Document Uploads | General attachments | Specific statements: 2, 4, 5B |
| Amendment Option | Allowed | Only if refund is withdrawn or deficiency memo issued |
Step-by-Step Refund Filing Process
Step 1: Return Filing
-
Ensure GSTR-1 and GSTR-3B are filed for all periods till refund date.
Step 2: Start Refund Application
-
Navigate to: Services > Refunds > Application for Refund
-
Select correct category → Click Create Refund Application
Step 3: Invoice-Based Auto Selection
-
Portal auto-fetches eligible invoices from GSTR-1. No need for manual filtering.
Step 4: Upload Statement
-
Use these formats:
-
Statement 2 – Export of Services
-
Statement 4 – SEZ Supplies
-
Statement 5B – Deemed Exports
-
Step 5: Attach Supporting Docs
-
Export invoices, FIRC/BRC, SEZ endorsements, Rule 89(2) declarations, CA Certificates (if refund > ₹2 lakh)
Step 6: Submit with EVC/DSC
-
Application gets an ARN. Track refund using this reference.
Step 7: Invoice Locking
-
Post submission, invoices used get locked.
-
Can be unlocked only if:
-
Application is withdrawn
-
A deficiency memo is issued
-
How to Expedite Piled-Up Refunds (Real-World Actions)
| Issue | Immediate Action |
|---|---|
| Old ARNs stuck | Withdraw → Reapply using new system |
| Deficiency Memo received | Refile with corrected data, maintain same ARN |
| Mismatch in invoices | Reconcile GSTR-1 vs refund statement using Excel |
| Delay >60 days | Apply for interest u/s 56 |
| No update from officer | Raise ticket on GST Helpdesk → Follow up via email |
| Bulk refund monitoring | Use Excel Refund Tracker Template below |
Excel-Based Refund Tracker Template
Maintain columns as below:
| ARN | Refund Category | Period | Amount | Status | Filing Date | Deficiency Memo (Y/N) | Refile Date | Officer Notes |
|---|
Standard Operating Procedure (SOP) for Internal Use
SOP Title: Monthly GST Refund Filing for Exporters
Objective: Timely, accurate, and compliant refund application for eligible exports.
Key Responsibilities:
-
Accounts Team: Ensure returns (GSTR-1/3B) filed correctly
-
Export Compliance Team: Gather export invoices, FIRC/BRC
-
GST Consultant/Manager: Reconcile GSTR-1 with invoice sheet, upload Statements
Frequency: Monthly, within 7 days of return filing
Attachments to Maintain:
-
Invoices (matched with GSTR-1)
-
Refund Tracker
-
Statement Templates 2/4/5B
-
CA Declarations
-
SEZ endorsements
Advisory to Exporters: Strategic Actions Now
-
Avoid Annual Refunds – Move to monthly claim filing
-
Systematic Filing – Create SOPs internally with assigned roles
-
Early Escalation – Use Helpdesk, grievance redressal if stuck beyond 45–60 days
-
Officer Engagement – Submit polite summary sheets via email or visit
-
Portal Hygiene – File returns timely, avoid mismatches, track credits and liabilities
-
Avoid Bulk Errors – Use invoice validation tools or GST compliance software
-
Record Everything – Maintain ARN, responses, filing snapshots for audit readiness
Conclusion
The GSTN reforms dated 08.05.2025 reflect a clear shift towards digitized, faster, and cleaner refund processing. However, only exporters who adapt their internal controls, systems, and documentation will truly benefit.
