The two-year GST refund time limit and how to find the relevant date

Relevant date by refund type

• Export of goods by sea or air: the date the ship or aircraft carrying the goods leaves India.
• Export of goods by land: the date the goods pass the frontier.
• Export of services: the date of receipt of payment in convertible foreign exchange, or where payment was received in advance, the date of the invoice.
• Inverted duty structure: the due date for filing the GSTR-3B for the period in which the claim arises.
• Tax paid in excess or by mistake: generally the date of payment.
• Refund arising from an appellate or court order: the date of communication of that order.
• Deemed exports: the date on which the return relating to those supplies is filed.

Situations that change the count

When a refund application receives a deficiency memo in RFD-03, the time between filing and the memo is excluded when you file the fresh application. Refund of excess balance in the electronic cash ledger has been clarified by CBIC as not subject to the two-year limit. For refunds where tax was paid on a supply that was later treated as an inter-state supply instead of intra-state, or the reverse, specific rules apply on the relevant date; check before filing.

If your claim is close to the deadline

• File the RFD-01 with whatever complete documents you have; do not wait for perfection.
• Make sure GSTR-1 and GSTR-3B for the period are filed, otherwise the portal may not allow the claim.
• Keep proof of the relevant date, such as shipping bills with the EGM date or bank realisation certificates.
• If a deficiency memo comes, re-file at once.

If the limit has passed

The proper officer cannot condone a delay beyond the statutory limit. Some businesses argue in appeal that the relevant date was later than the officer assumed, which is a factual question supported by documents. Where amounts are large, take advice on whether a challenge is worth pursuing. For future claims, set up a monthly or quarterly refund calendar so that the clock never becomes the issue.

Get it handled for you

Refund stuck or rejected? We rebuild the claim, reply to deficiency memos and follow up with the refund officer in writing. Call or WhatsApp +91 63677 44602, or use the form below.

This guide explains the law in general terms as of October 2026. Time limits and requirements can depend on the facts of your case and on the notice you received.