ITC refund on freight charges GST - export

[KS Bhat]

I am Exporter year 22-23 Total ITC from freight 100000 spread across the year Can i claim refund of the same in the month of Dec 2025 I do not have any local sales only export sales ITC claimed in 3B and matching with 2A/2B  

[Sadanand Bulbule]

Since you say your export period is 2022-23, by December 2025 it is already more than two years from the "relevant date" for most shipments.

That means your refund claim for that unutilised ITC is likely time-barred under Section 54[1]. The question of matching 3B with 2A/2B does not play any favaourable game in this situaion.

[YAGAY and SUN]

Under GST Rule 89, refund of unutilised ITC for export of goods without payment of tax must be filed within 2 years from the “relevant date,” which is generally the date of export (shipping bill/LEO date). There is no restriction just because the ITC relates to FY 2022–23, and ITC on freight (if eligible and reflected in 2A/2B and claimed in GSTR-3B) can be included.]

So, you may claim the refund in December 2025 only if it falls within 2 years from the relevant export dates; otherwise, the claim becomes time-barred.

[KASTURI SETHI]

Regarding computation of time limit for filing refund claim also focus on Clause (a) of Explanation 2 below sub-section 15 of Section 54 of CGST Act AND Clause (c) of sub-section 15 of Section 54 of CGST Act. Go into depth.

[Shilpi Jain]

You can consider doing your exports with payment of tax and set off this ITC and claim refund. Time limit issue of 2023 will not apply in this case. Time lmit of 2 years will start from date of the export that you do with payment of tax.

AI Summary

ITC on export freight must be claimed within two years from the export date; matching does not extend the time.
Refund of unutilised input tax credit on freight for exports must be claimed within two years from the relevant export date (typically shipping bill/LEO). Late claims are time barred regardless of GSTR 3B/2A matching. The computation of the two year limitation depends on statutory explanations defining the relevant date. Alternatively, exporters may opt to export with payment of tax, utilise ITC, and claim refund, in which case the limitation period runs from the date of those taxable exports.