Goods And Service Tax - Refund for export of goods without payment of tax

[THYAGARAJAN KALYANASUNDARAM]

Dear Experts,

One of my client has ITC ledger balance of ₹ 36,58,471/- pertaining to F.Y. 2017-18. He has claimed refund for the period July-December 2017 as below:

Turnover of Zero rated sales/Adjusted Turnover*Net ITC

1,06,379/33,12,748 * 27,85,461 = 89,447/-

During the above period, the ITC was huge,however, proportionate Zero rated sales was very low.The sale pertaining to the ITC mentioned above was made during Febuary 2018.

Therefore, now we are filing refund for Jan-Mar 2018 as follows:

2,32,54,500/2,98,10,877*4,68,759 = ₹ 3,65,664/-

We are unable to claim refund of ₹ 22,00,000/- (approx) in the above case as the Net ITC for the period Jan - March 2018 comes to ₹ 4,68,759/- only and the carry forward of balance pertaining to July-Dec 2017 doesn't get reflected.

Please let us know the possibilities for claiming the ITC.

Thanks in advance.

AI Summary

GST refund for export without tax: claim proportionate or inverted-tax relief, consolidate periods or use 'Any Other' claim
Refundable input tax credit for exports without payment of tax is limited to the proportionate ITC attributable to zero rated supplies; alternatively, claimants may seek relief under an inverted duty structure when input tax rates exceed output rates. To address credits arising in earlier periods, taxpayers may consolidate adjacent tax periods or use an "Any Other" claim category due to portal restrictions, supporting the filing with an explanation and relying on administrative guidance and relevant judicial precedents. Prompt filing is essential where limitation periods approach, and computations must reflect the ratio of zero rated turnover to adjusted turnover and net ITC.