GST Refund and Appeal Rules by CBIC

GST Refund and Appeal Rules 2025: Complete Guide for Indian Businesses

Q: How do I apply for a GST refund?

File Form RFD-01 on the GST portal, choose the correct refund category, upload the required documents, respond promptly to any officer queries, and track the ARN. If approved, the department issues RFD-06 and processes payment.

Q: What is the time limit to claim GST refund?

Generally, you must apply for a GST refund within two years from the relevant date specified in the law. Check the specific provision that applies to your refund category.

Q: Why does GST refund get delayed?

Delays happen because of mismatches between GSTR-1 and GSTR-3B, missing export or bank documents, wrong refund category selection, pending returns, or calculation errors. Respond quickly to any notices to speed resolution.

Q: Can I appeal a rejected GST refund?

Yes. File the first appeal online using Form APL-01 within 3 months of the refund rejection order. Attach grounds of appeal (APL-01A) and pay any required pre-deposit.

Q: How do I check GST refund status?

On the GST portal go to Services → Refunds → Track Application Status and enter your ARN or application details. The portal shows stage-wise progress: filed → acknowledged → approved → paid.

Q: What is the appeal time limit under GST?

The time limit to file an appeal is generally 3 months from the date of the original order. Condonation rules are stricter in 2025.

A clear guide to GST refund and appeal rules by CBIC. Learn about the GST refund update and GST appeal process, GST refund timelines, common delays, required RFD and APL forms, and the full appeal process explained in detail for business owners who need quick, practical answers.

Noorleen Kaur Bhatia

11 Dec 2025 • 14 min read

Major GST Refund and Appeal Rules Announced by CBIC in 2025

The GST Refund and Appeal Rules by CBIC in 2025 make the process slightly tighter but also more predictable if you understand how to navigate them.

The Central Board of Indirect Taxes and Customs (CBIC) has unveiled a crucial set of amendments to the Goods and Services Tax (GST) regime through Notification No. 23/2025–CT dated 10.05.2025

Why did CBIC introduce these specific changes to the GST appeal rules?

CBIC introduced these GST circulars and notifications for exporters, small and medium enterprises (SMEs), and any taxpayer involved in filing appeals or looking for refunds under the CGST Act.

This comprehensive GST update and appeal guide walks you through everything: refund eligibility, new GST updates for SMEs, GST timelines, RFD-01 and RFD-06 forms, appeal procedures, and what to do when your refund is rejected.

All Updates in GST Refund and Appeal Rules by CBIC under CGST Act in 2025

▶ March 2025🔽 27 March 2025 — CGST (Second Amendment) Rules, 2025 | Notification 11/2025 – Central Tax

What changed:

Amended Rule 164 for refund & appeal scenarios.
Refund not allowed if tax/interest/penalty for the period already discharged, even if demand spans multiple periods.
Allowed partial appeal withdrawal (instead of withdrawing the entire appeal) for periods covered under dispute resolution scheme.

Impact:

Clearer approach to multi-period refund disputes.
Helps taxpayers withdraw only part of an appeal where issues already resolved.

🔽 March 2025 – Rule 164 Clarification (Appeal Withdrawal & Refund Eligibility)

What changed:

Clarified how partial withdrawal under Section 128A works.
Standardised officer procedure for accepting/processing partial withdrawals.

Impact:

Reduces appeal pendency.
Gives taxpayers flexibility to close parts of old cases without impacting remaining issues.

▶ April 2025🔽 April 2025 – Guidelines for Refund Scrutiny & Documentation

What changed:

New internal instructions circulated to standardize refund documentation checks.
Officers advised to rely strictly on mandatory checklists.

Impact:

Fewer discretionary document demands.
Predictable refund processing.

▶ May 2025🔽 14 May 2025 — GSTN Portal Update for Deemed Export Refunds

What changed:

GSTN updated the refund module for deemed export claims.
New workflow for recipients of deemed export (e.g., EOU units).
Updated process for shipping bill/BRC verification.

Impact:

Faster portal validation.
Fewer manual clarifications from officers.

🔽 May 2025 — Digital-only Appeal Filing Requirement

What changed:

Appeal applications must be filed exclusively online via Form GST APL-01.
No physical submission accepted.
Stricter enforcement of 3-month appeal filing deadline.

Impact:

Stronger compliance discipline.
Simplified tracking for taxpayers.

▶ September 2025🔽 22 September 2025 — CGST (Third Amendment) Rules, 2025 | Notification 13/2025

A major set of refund & appeal changes came into effect.

Key refund-related updates:

Rule 91(2):
Provisional refund order (GST RFD-04) must be issued within 7 days of acknowledgement for eligible taxpayers.
High-risk cases may skip provisional refund and go straight to full scrutiny.
Automated mismatch alerts before refund blocking.

Appeal-related updates:

New Form GST APL-02A introduced.
Allows single-member bench appeals for cases without a substantial question of law.
Updated timelines for appellate proceedings.

Impact:

Faster refund turnaround for compliant taxpayers.
Better risk classification and fraud-proofing.
Faster disposal of smaller appeal cases.

▶ October 2025🔽 1 October 2025 — Provisional Refund Restriction for High-risk Taxpayers

What changed:

Provisional refunds may be withheld if the risk engine flags mismatches, excessive ITC patterns, or abnormal refund behaviour.

Impact:

Genuine taxpayers unaffected.
High-risk taxpayers face tighter checks.

Let’s break it down step by step.

Changes in GST Refund and Appeal Rules in 2025

GST Refund & Appeal Rules have affected the businesses in 2025 in the following ways:

Category	Earlier Rule	Updated Rule (2025)	Impact on Businesses
Refund Processing Time	Up to 60 days, with delays common	Officers advised to issue provisional refunds faster, stricter internal timelines	Faster working capital release
Refund Filing Mode	Online + occasional physical document checks	Completely digital, no physical submissions allowed	Easier tracking, fewer visits to department
Appeal Filing Mode	Online + optional physical submission	Only online through APL-01 and APL-01A	Clearer audit trail, reduced paperwork
Reasoned Orders for Rejection	Sometimes vague or generic	Officers must issue detailed, reasoned orders	Stronger transparency; easier to appeal
Refund Tracking Dashboard	Basic status updates	New stage-wise dashboard (filed → acknowledged → approved → paid)	Clear visibility of refund progress
Time Limit for First Appeal	3 months + extended condonation allowed	3 months; condonation stricter and more limited	Taxpayers must act faster
Refund for Exporters/SEZ	Same priority but slower processing	Priority + faster provisional refunds	Exporters get quicker liquidity
Mandatory Documentation	Flexible scrutiny depending on officer	Standardised checklist for key refund types	Predictable process; fewer rejections
Inverted Duty Structure Refund	Frequent clarifications asked	Predefined calculation templates introduced	Fewer errors; reduced scrutiny
Bank Verification for Refunds	Done manually in some cases	Automated PFMS-led verification	Fewer bank-related delays
Mismatch Procedures	Manual notices common	Automated mismatch alerts before refund blocking	Helps taxpayers fix issues early
Clarification Timeline	No strict guideline	Taxpayers must respond within specified time or refund may be rejected	Encourages timely compliance
Appeal Pre-Deposit	10% of disputed tax	Unchanged, but now digital-only	Faster payment processing
Tribunal Appeals	Depended on state-level rollout	Gradual activation of GST Appellate Tribunal benches in more states	Faster second-level appeals

The 2025 updates focus on cutting processing time and reducing refund disputes. Here’s what this really means for businesses:

Faster refund approvals for zero-rated supplies
Exporters and SEZ units get priority processing with stricter documentary checks. GST refund timelines remain 60 days, but officers are now encouraged to issue provisional refunds quickly.
Digital-only appeal submissions

Appeals must be filed online on the GST portal through:
Form GST APL-01 for the first appeal
Digital documentation only, no physical filings

Mandatory reason behind refund rejections
Officers must give clear grounds for rejecting refunds, making the appeal process cleaner.
Automated refund tracking dashboard
You can now track refund stages: filed → acknowledged → approved → paid → credited.
Stricter time limits for appeals
The default limit stays three months from the date of order, but the condonation rules are more rigid.

Overall, the rules aim to reduce back-and-forth and push both taxpayers and officers to stick to timelines.

What are the Different GST Refund Categories?

Different GST refund categories include:

Refund Category	Who Can Claim	Key Documents Required	Timeline (Approx.)
Refund of IGST on Exports	Exporters of goods & services	Shipping Bill, BRC/FIRC, GSTR-1, GSTR-3B, LUT/Bond	7–30 days (priority)
Refund of Unutilised ITC (Zero Rated Supplies)	Exporters without payment of IGST	LUT/Bond, export invoices, statement of exports	30–60 days
Inverted Duty Structure Refund	Manufacturers where input GST > output GST	Purchase register, sales register, calculation sheet	45–60 days
Excess Cash Ledger Balance	Any taxpayer	NIL (basic supporting only)	7–15 days
Refund of Wrong Tax Paid	Taxpayer who paid IGST instead of CGST+SGST or vice versa	Proof of tax payment, invoices	30–45 days
Refund on Account of Assessment/Order	Taxpayer who won an appeal or rectification case	Copy of appellate order, challans, computations	30–45 days
Refund for SEZ Supplies	Suppliers to SEZ developer/unit	SEZ endorsement, invoice, LUT/Bond	30–60 days
TDS/TCS Refund	Govt bodies, e-commerce operators	TDS/TCS statements	15–30 days
Excess Tax Paid Due to Mistake	Any taxpayer	Proof of double payment, challans	15–30 days

Who Can Claim GST Refund in India 2025

Not every taxpayer is eligible for a GST refund in India 2025, so let’s clarify the categories.

1. Exporters (goods or services)

Zero-rated supplies
Refund of unutilized ITC
Refund on IGST paid on exports

2. SEZ developers and SEZ units

For supplies received with payment of IGST.

3. Inverted duty structure cases

When input GST > output GST.

4. Excess balance in cash ledger

Common after mistakes or bulk payments.

5. Refund due to assessment, appeal or order

If the court or appellate authority rules in your favour.

6. Wrong tax paid due to classification error

Example: You paid IGST but should have paid CGST + SGST.

7. TDS/TCS refunds for government bodies or e-commerce operators

8. Excess payment of tax due to a mistake

Happens more often than people admit.

A GST refund claim is possible if you fall under these categories.

GST Forms for Refund & Appeals (2025)

Before proceeding forward with the GST refund and appeal by CBIC, understand which RFD and APL to fill for smooth claims:

Form	Purpose	Used For
RFD-01	Refund application form	All refund categories
RFD-01A	Manual version for specific cases	Transitional/manual refunds (rare now)
RFD-02	Acknowledgement of refund application	Officer-issued
RFD-03	Deficiency memo	When application needs correction
RFD-04	Provisional refund sanction order	Export refunds
RFD-05	Payment order for refunds	Issued after approval
RFD-06	Final refund sanction/rejection order	Main refund order
RFD-07A/B	Withholding order/withdrawal order	When refund is withheld or released
RFD-08	Show-cause notice for refunds	Officer seeks clarification
RFD-09	Reply to RFD-08	Taxpayer submits clarification
APL-01	First appeal form	Appeal against adjudicating authority
APL-01A	Grounds of appeal	Detailed reasoning
APL-02	Acknowledgment for appeal	Issued after filing APL-01
APL-03	Notice for hearing	Appellate authority
APL-04	Final appellate order	Appeal outcome
APL-05	Application to tribunal	Used for second appeal
PMT-06	Payment of pre-deposit	Mandatory for appeal

Step-by-Step GST Refund Process 2025-2026

Start → Identify refund category
Prepare documents (invoices, LUT/Bond, BRC/FIRC, bank proof, returns)
Login GST Portal → Services → Refunds → Application for Refund
Select category → Fill RFD-01 (enter tax period, bank details, calculations)
Upload supporting docs → Submit → ARN generated
Portal does automated pre-checks:
- If mismatch or missing docs → RFD-03 (Deficiency) → taxpayer must respond within portal → go to step 4 after correction
- If no issues → forwarded to officer
Officer review:
- If minor query → RFD-08 (Show Cause) → taxpayer replies via RFD-09 → officer re-evaluates
- If approves provisional refund → RFD-04 issued → provisional amount paid (if applicable)
- If rejects/partially accepts → RFD-06 issued (reasoned order)
Payment stage:
- Approved → RFD-05/RFD-07A payment order → PFMS verification → amount credited to bank
If rejected or short-paid → taxpayer may file appeal (go to Appeal Flowchart)

Quick tips: track ARN in portal dashboard, keep bank IFSC/name accurate, and respond to RFD-03/RFD-08 within the timeline.

Let's understand the documents required for claiming GST refund by CBIC.

Documents Required for GST Refund in 2025

GST refund online India, GST RFD-01, documents for GST refund

The safer approach: keep all your tax and invoice records ready for at least 6 years.

Why GST Refund Gets Delayed & How to Avoid Rejection

To avoid GST rejection, identify the reason behind the GST delay and quickly find solutions to GST refund mistakes in 2025:

Common GST Error	Reason behind GST Delay	How to Avoid GST Rejection
Mismatch between GSTR-1 and GSTR-3B	Incorrect reporting or late amendments	Reconcile monthly, amend GSTR-1, correct tax values
Wrong refund category selected	Confusion between categories	Understand refund type carefully; use help text on the portal
Missing export documents	Missing BRC/FIRC or shipping bills	Keep export docs updated; upload correct files
Bank account mismatch	Name or IFSC mismatch in PFMS	Update bank details in GST portal & validate
ITC claimed on blocked credits	Mistakenly claimed ITC on ineligible inputs	Reverse blocked ITC before filing
Officer issues deficiency memo (RFD-03)	Incomplete or incorrect application	Refile corrected RFD-01 with all documents
Refund rejected due to unclear calculations	ITC and turnover mismatch	Use standard calculation templates
Delayed response to notice (RFD-08)	Taxpayer misses deadline	Respond quickly via RFD-09 with full evidence
Export turnover mismatch with ICEGATE	Customs data not matching GST data	Correct invoices, ensure proper linkage
LUT/Bond expired	Not renewed for the new financial year	Renew LUT annually before April

GST Appeal Process Explained (2025 Edition)

If your refund is rejected or reduced, the next step is the appeal process.

Here’s a simple take on how it works.

When can you file an appeal?

You can appeal if you disagree with:

Refund rejection
Refund short-payment
Assessment order
Demand order
Penalty order
Any adverse order under GST

If your refund is rejected or reduced, the next step is the GST appeal process. Here’s a simple take on how it works.

Where to file a GST appeal?

First Appeal → Appellate Authority under GST
Second Appeal → GST Appellate Tribunal (if operational in your state)

Time limit for GST appeal

3 months from issue of order
Additional 1 month if delay is justified Beyond that, appeals are usually not accepted.

Forms used for GST Appeal

First appeal → GST APL-01
Grounds for appeal → APL-01A
Acknowledgment → APL-02

Documents needed for GST Appeal

Copy of order being appealed
Statement of facts
Grounds for appeal
Certified copies if required
Supporting proofs (invoices, returns, emails, exports records, etc.)

What happens during the GST appeal?

You file APL-01 online.
Pay a mandatory pre-deposit (usually 10% of the disputed amount).
Appellate authority reviews the case.
Hearing is scheduled if required.
Final order is issued (APL-04).

If the ruling is in your favour, refund or relief is processed accordingly.

How to File a GST Appeal Online in 2025

Here’s a process to file GST appeal online easily in 2025-2026.

Receive adverse order (RFD-06 / assessment / demand / penalty) → Decide to appeal
Check appeal window → 3 months from order date (condonation possible but stricter)
Prepare grounds of appeal (facts, legal points, supporting docs)
Login GST Portal → Services → User Services → Appeals → File APL-01
- Attach APL-01A (detailed grounds) and certified copies where required
- Pay pre-deposit via PMT-06 (usually 10% of disputed tax, confirm exact requirement)
ARN generated → Acknowledgement (APL-02)
Appellate authority reviews:
- Admit appeal → issue notice for hearing (APL-03) OR decide on documents
- Dismiss admissibility → order issued (APL-04)
Hearing (if scheduled): present oral arguments and evidence
Final order (APL-04):
- If favourable → direction for refund/adjustment/payment reversal
- If unfavourable → consider second appeal to Tribunal (APL-05) or higher remedies
Execute outcome: department processes the refund/payment as per the order.

Quick tips: preserve a chronological file of orders, challans, and communication; keep pre-deposit ready; use concise, pointwise grounds.

Conclusion

The 2025 GST refund and appeal rules make the process more structured, but they also demand cleaner compliance. If your records are organized and reconciliations are done consistently, refunds can move faster, and appeals become easier to win. For MSMEs, this clarity means better cash flow and fewer disputes, something every growing small business needs.

GST Refund and Appeal Rules 2025 — FAQ

GST

GST Refund & Appeal Rules 2025 — FAQ

Quick answers to common refund and appeal questions for Indian businesses (RFD / APL forms, timelines, checks).

1. What are the GST Refund Rules in 2025?

GST Refund Rules in 2025 define the process, timelines, forms, eligibility, and documentary requirements for claiming refunds under GST in India. The 2025 updates emphasise fully digital filing, clearer reasoned orders for rejections, and stricter timelines for appeals.

2. How do I apply for a GST refund?

File Form RFD-01 on the GST portal, choose the correct refund category, upload the required documents, respond promptly to any officer queries, and track the ARN. If approved, the department issues RFD-06 (final order) and processes payment.

3. What is the time limit to claim GST refund?

Generally, you must apply for a GST refund within two years from the relevant date specified in the law. Check the specific provision that applies to your refund category because some cases vary.

4. Why does GST refund get delayed?

Delays typically happen because of mismatches between GSTR-1 and GSTR-3B, missing export or bank documents, wrong refund category selection, pending returns, or calculation errors. Responding quickly to RFD-03 or RFD-08 notices speeds up resolution.

5. Can I appeal a rejected GST refund?

Yes. File the first appeal online using Form APL-01 within 3 months of the refund rejection order. Attach the grounds of appeal (APL-01A) and pay any required pre-deposit as per the order.

6. How do I check GST refund status?

On the GST portal go to Services → Refunds → Track Application Status and enter your ARN or application details. The portal now shows stage-wise progress: filed → acknowledged → approved → paid.

7. What is the appeal time limit under GST?

The time limit to file an appeal is generally 3 months from the date of the original order. Condonation may be available in exceptional cases but rules around condonation have tightened in 2025.