GSTN Switches to Invoice-Based Refund Filing for Exports and SEZ Supplies

GSTN Advisory, Dated 08-05-2025

The Goods and Services Tax Network (GSTN) has introduced significant changes to the refund application mechanism for three specific categories of taxpayers engaged in outward supply transactions. These include –

1. Export of Services with Payment of Tax
2. Supplies Made to SEZ Unit/SEZ Developer with Payment of Tax
3. Refunds by Suppliers of Deemed Exports

1. Key Changes Introduced

1. Shift from Tax Period-Based to Invoice-Based Filing – Under the earlier system, taxpayers were required to select a specific tax period while filing refund applications for the above-mentioned categories. With the new update, GSTN has eliminated the tax period selection requirement and moved to an invoice-based filing approach. This aims to streamline the refund process and reduce the complexities associated with period-wise reconciliation.

2. Locking of Invoices – Once a refund application is filed and invoices are uploaded, those invoices will be locked in the system. This means they cannot be edited, amended, or reused in any other refund application, thereby minimising the chances of duplication or erroneous claims. Invoices will be unlocked only under the following circumstances –

• If the taxpayer withdraws the refund application voluntarily, or
• If a deficiency memo is issued by the tax officer, indicating that certain corrections or clarifications are required.

3. Upload of Eligible Invoices as per Prescribed Format – Taxpayers are required to upload eligible invoices in the prescribed statement templates provided in the advisory. These statements must be filled accurately and uploaded at the time of filing the refund claim to ensure successful processing under the revised framework.

2. Purpose and Expected Outcome

This revamped procedure is expected to –

• Enhance transparency and traceability of refund claims.
• Reduce the administrative burden on taxpayers.
• Minimise errors related to period selection and duplicate invoice claims.
• Expedite refund processing timelines by ensuring cleaner, invoice-linked data.

Taxpayers falling under the affected categories are advised to familiarise themselves with the updated procedures and ensure compliance with the latest advisory and invoice uploading guidelines to avoid delays in refund processing.

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