GST Refund Alert: Annexure-B Utility Mandatory Now

May 26, 2026 CA ALOK KUMAR GST Refund

GST Refund Alert: Annexure-B Utility Mandatory from 18 May 2026

GST refund filing has become more structured from 18 May 2026. GSTN has introduced a standardised Annexure-B Offline Utility for specified refund applications involving accumulated Input Tax Credit, commonly known as ITC.

Earlier, taxpayers generally uploaded Annexure-B in PDF format. Now, for covered refund categories, Annexure-B has to be prepared through the prescribed offline utility, converted into JSON format and uploaded on the GST portal while filing refund application in Form GST RFD-01.

This update is important for exporters, SEZ suppliers, manufacturers, traders and businesses claiming refund of accumulated ITC. Taxpayers dealing with GST refund filing, GST return filing, GST registration and ITC reconciliation should carefully understand this change before filing refund claims.

Legal Background of GST Refund

GST refund is governed mainly by Section 54 of the CGST Act, 2017. It provides the legal framework for claiming refund of tax, interest or any other amount paid by a taxpayer.

Under Section 54(3), refund of unutilised ITC is allowed mainly in two situations:

Zero-rated supplies made without payment of tax; and
Accumulation of ITC due to inverted duty structure, where the rate of tax on inputs is higher than the rate of tax on outward supplies.

The filing procedure is provided under Rule 89 of the CGST Rules, 2017, which provides for electronic filing of refund application in Form GST RFD-01 through the common portal.

CBIC has also issued important refund-related circulars, including Circular No. 125/44/2019-GST dated 18 November 2019 and Circular No. 135/05/2020-GST dated 31 March 2020, which deal with electronic refund processing and Annexure-B reporting requirements.

What Has Changed?

The main change is that Annexure-B is no longer a simple PDF attachment for the covered refund categories. It has now become a structured data statement.

Earlier: Annexure-B was generally uploaded as PDF.
Now: Annexure-B must be prepared in the offline utility, converted into JSON and uploaded on the GST portal.

This change is intended to improve automation, invoice-level verification and system-based validation of refund claims.

For businesses claiming accumulated ITC refund, proper reconciliation of books, purchase register, GSTR-2B and GSTR-3B is now very important. For regular GST compliance, taxpayers may refer to GST filing services.

Refund Categories Covered

The Annexure-B Offline Utility is applicable mainly to the following refund categories:

Export of goods or services without payment of tax
This applies where exports are made under LUT/Bond and refund of accumulated ITC is claimed.
Supplies to SEZ unit or SEZ developer without payment of tax
This applies where zero-rated supplies are made to SEZ without payment of tax.
Refund due to inverted duty structure
This applies where ITC accumulates because input tax rate is higher than output tax rate.
Export of electricity without payment of tax
This category is also covered where accumulated ITC refund is claimed.

Therefore, the utility is not applicable to every GST refund. It is mainly applicable to specified refund applications involving accumulated ITC.

Why Annexure-B Is Now More Important

Annexure-B contains invoice-wise details of inward supplies on which ITC has been claimed and refund is sought. Since the new utility uses structured data, taxpayers must report details correctly.

Important fields include:

Supplier GSTIN
Invoice number
Invoice date
HSN/SAC code
Category of inward supply
Taxable value
Tax amount
Eligible ITC
Blocked or ineligible ITC
ITC reversals
Relevant GSTR-2B period

Any incorrect reporting may result in validation errors, invalid document report, deficiency memo or delay in refund processing.

For refund-related reconciliations, businesses may take support for GST ITC reconciliation.

Structure of Annexure-B Offline Utility

The Annexure-B Offline Utility broadly contains:

Table 1 – Reversal Details
Table 2 – HSN/SAC-wise inward invoice details for which ITC has been claimed in GSTR-3B

Invoice details must be reported HSN/SAC-wise and category-wise. The inward supplies should be classified as:

Inputs
Input services
Capital goods

This classification is important because refund eligibility may differ depending on the nature of ITC.

Invoices with Multiple HSN/SAC Codes

Many purchase invoices contain more than one HSN/SAC code or more than one category of supply. For example, one invoice may include goods, services and capital items.

In such cases, the invoice should not be reported as one combined entry. It should be split into separate line items.

Each line item should represent:

One HSN/SAC code; and
One category of inward supply.

Taxable value and tax amount should also be divided proportionately.

This is a common area where mistakes may happen. Businesses should not prepare Annexure-B mechanically from the purchase register without checking HSN/SAC-wise details.

Duplicate Document Validation

The utility applies duplicate document validation generally on the basis of:

Supplier GSTIN
Invoice number
Invoice date
Category of inward supply
HSN/SAC code

If the same invoice details are repeated with identical parameters, it may create validation issues. Therefore, taxpayers should clean the data before generating the JSON file.

ITC Reversals Must Be Correctly Reported

The utility also requires correct reporting of ITC reversals. Taxpayers should carefully consider:

Reversal under Rule 38, Rule 42 and Rule 43
Blocked credit under Section 17(5) of the CGST Act
Other reversals reported in Table 4(B)(2) of GSTR-3B

Wrong reporting of reversals may directly affect the eligible refund amount and may lead to departmental objection.

How to Upload Annexure-B JSON in RFD-01

The general process is:

Login to GST portal
Go to Services > Refunds > Application for Refund
Select the relevant refund category
Prepare Annexure-B in the offline utility
Generate JSON file
Upload JSON file in Form GST RFD-01
Validate uploaded data
Check valid and invalid document reports
Submit the refund application with DSC/EVC
Download ARN acknowledgement

Taxpayers should not manually edit the JSON file. If correction is required, revise the offline utility and generate a fresh JSON file.

GSTR-2B Validation: Key Precaution

The new system may validate invoice details with GSTR-2B. Therefore, before filing refund application, taxpayers should verify:

Whether supplier has reported invoice in GSTR-1/IFF
Whether invoice appears in GSTR-2B
Whether GSTIN, invoice number and invoice date match
Whether tax amount matches with books
Whether ITC is eligible and not blocked
Whether ITC has already been reversed

For businesses facing mismatch issues, professional support in GST return filing and ITC reconciliation can help avoid refund delays.

Practical Checklist Before Filing GST Refund

Before filing refund application, taxpayers should check:

Correct refund category
ITC reconciliation with GSTR-2B
HSN/SAC-wise invoice breakup
Classification of inputs, input services and capital goods
Blocked credit under Section 17(5)
ITC reversals in GSTR-3B
Duplicate invoice entries
Latest version of Annexure-B Offline Utility
Correct JSON generation
Complete supporting documents

Supporting documents may include export invoices, LUT, FIRC/BRC, shipping bills, SEZ endorsement, purchase invoices and reconciliation statements.

Common Mistakes to Avoid

Taxpayers should avoid:

Uploading old PDF Annexure-B
Using outdated utility
Wrong HSN/SAC reporting
Wrong classification of ITC
Claiming ITC without GSTR-2B reconciliation
Duplicate invoice entries
Wrong invoice date format
Incorrect ITC reversal reporting
Claiming blocked credit
Manually editing JSON file

Such mistakes may result in validation errors, deficiency memo, refund rejection or delay.

What If GST Refund Is Rejected?

If GST refund is rejected fully or partly, the taxpayer should examine the rejection order carefully. Common reasons may include documentation gaps, ITC mismatch, GSTR-2B mismatch, export proof issues, SEZ endorsement issues or incorrect refund computation.

Where the rejection is legally or factually incorrect, the taxpayer may file appeal under Section 107 of the CGST Act. For such cases, refer to GST appeal filing in Form APL-01.

If the matter goes beyond the first appellate stage, professional support may be required for GSTAT appeal filing.

For refund objections, notices, deficiency memos or demand-related matters, taxpayers may also refer to GST notice reply and demand defence.

Why This Update Matters for Businesses

This update shows that GST refund processing is moving towards structured reporting, automated verification and invoice-level validation.

It is especially important for:

Exporters
SEZ suppliers
Manufacturers
E-commerce sellers
High-volume traders
Businesses facing inverted duty structure
Entities regularly claiming accumulated ITC refund

For businesses in Delhi NCR and across India, professional guidance in GST compliance, GST return filing and GST refund filing can help avoid unnecessary refund delays.

Professional Assistance for GST Refund Filing

CA Alok Kumar provides professional support for:

GST registration
GST return filing
GST refund filing
ITC reconciliation
Export refund documentation
SEZ refund documentation
Inverted duty structure refund computation
Annexure-B Offline Utility preparation
JSON file review before upload
Refund deficiency memo reply
GST notice reply
GST appeal filing
GSTAT appeal filing

Conclusion

The Annexure-B Offline Utility is an important procedural change in GST refund filing. From 18 May 2026, specified refund claims involving accumulated ITC must be supported by structured JSON-based Annexure-B reporting.

Taxpayers should focus on invoice-level accuracy, HSN/SAC-wise reporting, GSTR-2B reconciliation, ITC eligibility and proper documentation before filing refund application.

Need Help in GST Refund Filing?

For GST refund filing, Annexure-B Offline Utility preparation, ITC reconciliation, RFD-01 filing, refund notice reply or appeal against refund rejection, contact CA Alok Kumar’s GST team.

Call / WhatsApp: +91-9818167102
Website: caalokkumar.com

Official Source References

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