IGST Refund on Exports Cannot Be Denied for Typo in GST Return | HC

Case Details: Ruhi Siraj Makda vs. Union of India - [2025] 177 taxmann.com 623 (Gujarat) 

Judiciary and Counsel Details

• Bhargav D. Karia & Pranav Trivedi, JJ.
• Hiren J. Trivedi for the Petitioner
• C.B. Gupta for the Respondent

Facts of the Case

The petitioner, an exporter, had paid IGST on goods exported. While filing return in Form GSTR-1, the petitioner inadvertently made a typographical error by entering the IGST amount as ‘Zero’ in Table 6A, where export details are filled in. However, the corresponding IGST was duly paid and reflected in Form GSTR-3B under Table 3.1(a) instead of Table 3.1(b). As a result of this error, the IGST scroll generated online in ICEGATE showed nil refund payable. Despite documents evidencing exports as zero-rated supplies, the Customs department withheld refund on the ground of mismatch between GST return data and customs data. Aggrieved, the petitioner approached the High Court seeking release of refund, and the matter was accordingly placed before the High Court.

High Court Held

The High Court held that refund of IGST paid on exports could not be denied merely on account of a typographical error in the GST return where documentary evidence established that the exports had taken place as zero-rated supplies. It was observed that the petitioner had undisputedly exported goods and paid IGST, and was therefore entitled to refund under Rule 96 of the CGST Act read with Gujarat GST Rules. The Court ruled that the Customs authorities could not withhold refund solely on the basis of a mismatch between GST data and customs data. Accordingly, the respondents were directed to sanction the refund of IGST paid together with statutory interest from the date of shipping bills till the date of actual refund.

List of Cases Reviewed

• Amit Cotton Industries v. Principal Commissioner of Customs [2019] 107 taxmann.com 167/75 GST 33/29 GSTL 200 (Gujarat) (para 16), followed

List of Cases Referred to

• Amit Cotton Industries v. Principal Commissioner of Customs [2019] 107 taxmann.com 167/75 GST 33/29 GSTL 200 (Gujarat) (para 16), followed