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    GST Refund for Merchant Exporters

    Reviewed by CA & CS Team · Patron Accounting LLP ICAI & ICSI Registered| 15+ Years Experience| Last Updated: 11 May 2026 Verify Credentials →

    Documents: RCMC, GSTIN, IEC, supplier tax invoice (0.1%), shipping bill with supplier GSTIN, EGM, GSTR-1 Table 6A, BRC

    Fees: Refund filing starts at Rs 9,999 plus GST per claim cycle (annual retainer Rs 89,999)

    Eligibility: Registered merchant exporter with RCMC; goods exported within 90 days of supplier tax invoice

    Timeline: Provisional 90% refund within 7 days; final RFD-06 within 60 days under Section 54(7)

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      From RCMC verification and order intimation through to Rule 89(4B) Statement 4 computation, shipping bill amendment coordination, and Rule 96(10) legacy SCN representation - Patron handles the full two-route merchant exporter refund pipeline with CA-led documentary discipline and PFMS disbursal tracking.

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      Merchant Exporter GST Refund Overview

      📌 TL;DR - Merchant Exporter Refund Services at a Glance

      Merchant exporters in India can recover GST through two parallel routes. Route A: procurement at 0.1 percent concessional rate under Notification 40/2017-CT (Rate) with refund of accumulated ITC under Rule 89(4B) of CGST Rules. Route B: deemed-export supplies under Section 147 CGST Act and Notification 48/2017-CT where supplier or recipient files Form GST RFD-01 within 2 years. With Rule 96(10) omitted from 8 October 2024 by Notification 20/2024-CT, the IGST-paid export route is also fully available. Provisional 90 percent refund within 7 days under Section 54(6).

      GST refund for merchant exporters is the mechanism by which a registered trader who exports goods recovers the indirect-tax cost embedded in domestic procurement. Two parallel routes exist under the CGST Act 2017: the 0.1 percent concessional supply route under Notification 40/2017-Central Tax (Rate) and Notification 41/2017-Integrated Tax (Rate), and the deemed-export route under Section 147 CGST Act read with Notification 48/2017-Central Tax. Choosing correctly between the two affects working-capital lock-in by 6 to 9 months and refund quantum by up to 18 percent of procurement value.

      Patron Accounting LLP has filed merchant-exporter refund claims for trading houses across textiles, engineering goods, chemicals, and agro-exports since the rollout of these notifications on 23 October 2017. With Rule 96(10) omitted from 8 October 2024 by Notification 20/2024-Central Tax and the Gujarat High Court ruling in Addwrap Packaging Pvt Ltd (June 2025) extending relief to pending proceedings, the IGST-paid export route is now fully available alongside the concessional-rate and deemed-export routes. RoDTEP and GST refund stack as non-overlapping benefits.

      ParameterDetail
      Governing ActCGST Act 2017 (Section 54, Section 147) plus IGST Act 2017 (Section 16)
      Applicable ToMerchant exporters registered with GST and an Export Promotion Council or Commodity Board
      Refund TimelineProvisional 90 percent within 7 days; final order within 60 days under Section 54(7)
      CostPatron Accounting fees start at Rs 9,999 per refund cycle; govt fee nil
      Penalty for Non-Export in 90 DaysConcessional rate withdrawn; supplier liable to pay differential GST plus interest under Section 50
      Form / PortalForm GST RFD-01 on gst.gov.in
      AuthorityJurisdictional GST Refund Officer under CBIC

      Content is reviewed quarterly for accuracy.

      What Is GST Refund for Merchant Exporters

      GST refund for merchant exporters is the recovery of unutilised input tax credit or integrated tax paid on goods exported out of India by a trading entity registered under Section 22 of the CGST Act 2017. A merchant exporter is a trader who exports goods without manufacturing them and is registered with an Export Promotion Council or a Commodity Board recognised by the Department of Commerce.

      Refunds are governed by Section 54 of the CGST Act read with Section 16 of the IGST Act 2017 and Rule 89(4B) of the CGST Rules 2017. Where the supplier opts for the 0.1 percent concessional rate under Notification 40/2017, the merchant exporter applies for refund of accumulated ITC under category any other in Form GST RFD-01.

      For primary source materials see the GST portal, GST tutorial portal, CBIC notifications, DGFT RoDTEP framework, and India Code.

      2 Refund Routes at a Glance

      RouteTriggerFormTypical Turnaround
      Route A - 0.1 Percent Concessional (Notif 40/2017 + 41/2017)Physical export within 90 days of supplier tax invoiceForm RFD-01 Statement 4 (Rule 89(4B))Provisional 90% in 7 days; final in 60 days
      Route B - Deemed Export (Section 147 + Notif 48/2017)Domestic supply to AA holder, EPCG holder, or EOUForm RFD-01 Statement 5B (Rule 89(2)(g))30 to 60 days end-to-end

      Key Terms for Merchant Exporter Refund:

      TermPlain Meaning
      Merchant ExporterA trader registered with an Export Promotion Council or Commodity Board who exports goods procured from manufacturers
      Concessional Rate (0.1 percent)Reduced GST levy of 0.1 percent IGST or 0.05 percent CGST plus 0.05 percent SGST on supplies meant for export under Notification 40/2017
      Deemed ExportSupply of goods that does not leave India but is treated as export under Section 147 CGST Act and Notification 48/2017
      Rule 89(4B)Procedural rule under CGST Rules 2017 that lets merchant exporters claim refund of accumulated ITC on concessional-rate procurement
      Rule 96(10)Restriction omitted with effect from 8 October 2024 by Notification 20/2024-Central Tax that previously blocked IGST refund where concessional supplies were availed
      RCMCRegistration cum Membership Certificate from Export Promotion Council or Commodity Board - mandatory pre-condition for Notification 40/2017 benefit
      LUT (Letter of Undertaking)Bond replacement under Rule 96A allowing zero-rated export without IGST payment
      EGM (Export General Manifest)Customs document filed by carrier confirming physical export - critical for refund eligibility
      RoDTEP (Appendix 4R)Remission of Duties and Taxes on Exported Products - replaced MEIS from 1 January 2021; non-overlapping with GST refund
      Section 147 CGST ActEmpowers Central Government to notify deemed export categories - operationalised by Notification 48/2017
      APL-05 Merchant Exporter Refund
      Routes 0.1% Concessional + Deemed Export

      Who Needs This Service - 5 Merchant Exporter Categories

      Any business that buys finished goods domestically and exports them out of India qualifies as a merchant exporter and can claim GST refund under one of the two notification routes. Entities supplying to Advance Authorisation holders, EPCG holders, or Export Oriented Units also qualify under the deemed-export framework.

      • Trading houses - buying from Indian manufacturers and shipping abroad under their own IEC; primary users of Notification 40/2017 concessional rate
      • Merchant exporters supplying to SEZ units - where the dual-path question commonly arises (Notification 40/2017 vs Section 16 zero-rated route)
      • Manufacturers selling to AA/EPCG holders - operating under the deemed-export route under Section 147 and Notification 48/2017
      • Sectoral exporters - textiles, garments, engineering goods, chemicals, and agro-products with FOB turnover above Rs 50 lakh per year
      • Suppliers caught by historical Rule 96(10) demands - now eligible for relief post the 8 October 2024 omission and Addwrap Packaging Gujarat HC ruling

      Threshold and pre-condition: GSTIN registration is mandatory. If you do not yet hold a GSTIN, complete GST registration before applying for any refund. The merchant exporter must export the goods within 90 days from the date of the supplier's tax invoice as required by Notification 40/2017; failure makes the supplier liable for the differential GST plus interest under Section 50 CGST Act. RCMC from an Export Promotion Council or Commodity Board recognised by the Department of Commerce is a hard pre-condition for the concessional-rate route.

      What Patron Accounting Delivers

      ServiceWhat We Do
      Concessional Rate Compliance (Notification 40/2017)Verify supplier eligibility, prepare order copy intimation to supplier's jurisdictional officer, draft shipping-bill annotations with supplier GSTIN and tax invoice number, RCMC verification.
      RFD-01 Refund Filing (Rule 89(4B))End-to-end preparation and online submission with Statement 4 reconciliation between GSTR-1 Table 6A, GSTR-3B Table 3.1(b), and shipping bills under category any other per Circular 94/13/2019-GST.
      Deemed Export Refund Filing (Section 147)Form A intimation, Statement 5B preparation, Annexure I reconciliation, supplier-vs-recipient option strategy under Notification 49/2017-CT undertaking framework.
      90-Day Export TrackingMonthly dashboard tracking each invoice against EGM filing and shipping-bill closure; pre-Day-85 alerts to prevent Section 50 interest exposure on supplier.
      Rule 96(10) Legacy RecoveryRepresentation in pending SCN matters citing Notification 20/2024-CT (omission from 08.10.2024) and Addwrap Packaging Gujarat HC June 2025 ruling for pending proceedings.
      RoDTEP ReconciliationCross-check shipping-bill RoDTEP claim against GST refund to prevent double-recovery flags; DGFT Notification 66/2025-26 (23 March 2026) full-rate restoration mapping.
      Section 107 Appeal for Refund RejectionAPL-01 filing with 10 percent pre-deposit, defence pack with relevant case law and circular invocation; settlement rate above 80 percent on appeal.
      Our Process

      Refund Procedure (7 Sequential Steps)

      The merchant-exporter refund cycle runs through 7 sequential steps. Each step is anchored to a specific section, rule, notification, or circular - allowing trading houses and merchant exporters to audit each handoff with documentary clarity.

      Step 1

      Confirm RCMC From Export Promotion Council

      Obtain or renew Registration cum Membership Certificate (RCMC) from the relevant Export Promotion Council or Commodity Board recognised by the Department of Commerce - mandatory pre-condition for Notification 40/2017 benefit per condition (b). Valid RCMC must cover the export period. (3 to 7 working days for new RCMC.)

      RCMC mandatory pre-condition EPC or Commodity Board Notif 40/2017 condition (b)
      RCMCExport PromotionCouncil / BoardNotif 40/2017 (b)
      RCMC Confirmed 01
      Step 2

      Place Export-Purpose Order and Intimate Officer

      Place export-purpose order on the registered supplier and forward a copy to the jurisdictional tax officer of that supplier as required by Notification 40/2017 condition (d). The intimation creates documentary trail for concessional-rate eligibility. (Same day as order placement.)

      Export order to supplier Copy to supplier's officer Notif 40/2017 condition (d)
      Export OrderMerchant toSuppliercondition (d)Copy toJurisdictionalOfficerIntimation
      Order Intimated 02
      Step 3

      Receive Supply at 0.1 Percent Concessional Rate

      Receive supply at 0.1 percent concessional rate (0.05 percent CGST plus 0.05 percent SGST or 0.1 percent IGST) under Notification 40/2017-CT (Rate) or 41/2017-IT (Rate). Per CBIC Circular 37/11/2018-GST dated 15 March 2018, the concession is optional for the supplier. (Per invoice.)

      0.1% IGST or 0.05+0.05% Notif 40/2017 + 41/2017 Circular 37/11/2018 - optional
      0.1% SupplyCGST 0.05 + SGST 0.05or IGST 0.1Notif 40/2017 + 41/2017
      Supply Received 03
      Step 4

      Export Within 90 Days With Supplier GSTIN on SB

      Export goods within 90 days of the supplier's tax invoice via shipping bill or bill of export, indicating supplier GSTIN and tax invoice number on the shipping bill per Notification 40/2017 condition (c). Miss the 90-day window and supplier owes differential GST plus 18 percent interest under Section 50. (Within 90 days.)

      90-day hard deadline Supplier GSTIN + invoice No. on SB Notif 40/2017 condition (c)
      Shipping BillSupplier GSTIN + Inv No.90dNotif 40/2017 (c)
      Export Completed 04
      Step 5

      File GSTR-1 Table 6A and GSTR-3B Table 3.1(b)

      File GSTR-1 reporting the export in Table 6A and GSTR-3B in Table 3.1(b) - refund cannot be filed without these returns per Rule 89(2)(g) CGST Rules. Reconcile invoice-by-invoice with shipping bill data and EGM filing. (By 11th and 20th of following month.)

      GSTR-1 Table 6A exports GSTR-3B Table 3.1(b) Rule 89(2)(g) prerequisite
      GSTR-1Table 6AExportsGSTR-3BTable 3.1(b)Rule 89(2)(g)
      Returns Filed 05
      Step 6

      Submit Form RFD-01 With Statement 4 (Any Other)

      Submit Form GST RFD-01 on gst.gov.in under category any other with Statement 4 (for ITC refund under Rule 89(4B)) or Statement 3 (for IGST refund). Procedure detailed in CBIC Circular 94/13/2019-GST dated 28 March 2019. Reconcile to shipping bill, supplier invoice, GSTR-1 6A, GSTR-3B. ARN generated. (Day 1 to 3 of filing.)

      RFD-01 category any other Statement 4 Rule 89(4B) Circular 94/13/2019-GST
      RFD-01Statement 4Rule 89(4B)Circular 94/13/2019
      RFD-01 Filed 06
      Step 7

      Receive Provisional 90 Percent Within 7 Days

      Receive provisional 90 percent refund within 7 days of RFD-02 acknowledgement under Section 54(6) read with Rule 91(2). Balance 10 percent follows after document verification by proper officer in RFD-06 final order, within 60 days of RFD-01 filing per Section 54(7). Section 56 interest applies if delayed. (7 to 60 days end-to-end.)

      Provisional 90% in 7 days Section 54(6) + Rule 91(2) RFD-06 final in 60 days
      PFMS90% in 7 daysSection 54(6) + Rule 91
      Refund Credited 07

      Documents Required for Merchant Exporter Refund

      • GSTIN certificate of the merchant exporter
      • RCMC from Export Promotion Council or Commodity Board recognised by Department of Commerce
      • Importer-Exporter Code certificate from DGFT (new applicants can complete IEC registration before the first export)
      • Supplier tax invoice with 0.1 percent concessional rate clearly mentioned (CGST 0.05 percent + SGST 0.05 percent or IGST 0.1 percent)
      • Shipping bill or bill of export carrying supplier GSTIN and supplier invoice number per Notification 40/2017 condition (c)
      • Export General Manifest (EGM) or export report from customs confirming physical export
      • GSTR-1 return showing export in Table 6A and GSTR-3B in Table 3.1(b) for the refund period
      • BRC (Bank Realisation Certificate) where export proceeds have been received within FEMA 9-month window
      • LUT acknowledgement number where export is without payment of IGST under Rule 96A
      • CA certificate in Annexure 2 of RFD-01 where refund exceeds Rs 2 lakh
      • Order copy intimation to supplier's jurisdictional officer (concessional-rate evidence per condition (d))
      • For deemed-export route - Notification 49/2017-CT undertaking from non-claiming party (supplier or recipient)

      Worked Example - Surat Textile Merchant Exporter

      StageDetail
      Refund periodFY 2023-24 and FY 2024-25 (18 monthly cycles)
      Sector and routeSurat-based textile merchant exporter; primarily 0.1 percent concessional route under Notification 40/2017
      Total recovered across 18 cyclesRs 1,42,00,000 in accumulated ITC
      Average RFD-04 provisional 90 percent sanction6 days from RFD-02 (within 7-day Section 54(6) target)
      Average RFD-06 final sanction time54 days (well within Section 54(7) 60-day ceiling)
      Rejection rateZero - 18 of 18 cycles sanctioned in first pass
      Working capital impactRecovered 18 percent of procurement cost previously locked in ITC ledger

      Common Merchant Exporter Refund Challenges and Patron Solutions

      ChallengeImpactHow Patron Accounting Solves It
      Supplier GSTIN missing on shipping billShipping bill filed without supplier GSTIN and tax invoice number breaches Notification 40/2017 condition (c) - refund rejected on procedural groundsPatron coordinates with the CHA to file a customs amendment under Section 149 of the Customs Act 1962 and submit a shipping-bill amendment letter with supporting EGM evidence and supplier tax invoice trail
      Refund stuck because GSTR-1 and GSTR-3B mismatchInvoice-level differences between Table 6A of GSTR-1 and Table 3.1(b) of GSTR-3B trigger Rule 89(2)(g) refund block - common where multiple shipments span return cyclesPatron's team reconciles Table 6A of GSTR-1 with Table 3.1(b) of GSTR-3B invoice by invoice and files DRC-03 corrections where invoice-level differences exceed Rs 1 lakh; supplementary GSTR-1 amendments via Table 9A in next return
      Past Rule 96(10) demand notice for IGST refundPre-08.10.2024 SCN or order-in-original demanding repayment of IGST refund on the ground that concessional supplies were availed alongsidePatron relies on the Gujarat High Court ruling in Addwrap Packaging Pvt Ltd v Union of India (June 2025) and Notification 20/2024-Central Tax to seek quashing of pending SCNs and orders-in-original where final adjudication has not taken place as on 8 October 2024
      90-day export window missedGoods not exported within 90 days of supplier tax invoice date triggers Notification 40/2017 condition (c) breach - supplier liable for differential GST plus 18 percent interest under Section 50Patron assists in filing an extension application before the jurisdictional Commissioner under the CBIC procedure clarified in Circular 37/11/2018-GST dated 15 March 2018 with reason narrative and supporting export documentation
      Order copy not intimated to supplier's officerNotification 40/2017 condition (d) requires order copy intimation to supplier's jurisdictional officer; non-compliance is cited by department to deny concessional ratePatron's discipline ensures order copy intimation at the time of order placement; for past periods - condonation petition before Commissioner with bona fide explanation and substantial-compliance argument
      RoDTEP claim flagged as overlapping with GST refundRoDTEP claim on shipping bill from Appendix 4R sometimes flagged as overlapping with GST refund on the same SB; both refunds frozen pending clarificationPatron prepares RoDTEP-vs-GST reconciliation map - RoDTEP remits embedded central, state, and local levies not refunded under GST; GST refund is on input GST. Both are non-overlapping benefits per DGFT Notification 66/2025-26

      Merchant Exporter Refund Fees and Pricing

      Fee ComponentAmount
      Patron Accounting Professional Fees (LUT Filing - Annual)Starting from Rs 4,999 per LUT (Exl GST and Govt. Charges)
      Single Refund Filing (RFD-01, up to 25 invoices, single tax period)Rs 9,999 per filing (Exl GST and Govt. Charges)
      Bulk Refund (Multi-Month, up to 100 invoices, 3-month window)Rs 24,999 per filing (Exl GST and Govt. Charges)
      Deemed Export Refund Filing (Statement 5B under Section 147)Rs 16,999 per refund cycle (Exl GST and Govt. Charges)
      Rule 96(10) Legacy SCN RepresentationRs 49,999 per representation (Exl GST and Govt. Charges)
      Annual Refund Retainer (12-month, unlimited filings up to 500 invoices)Rs 89,999 per annum (Exl GST and Govt. Charges)
      RCMC Application or Renewal SupportRs 7,999 per filing (Exl GST and Govt. Charges)
      RoDTEP Reconciliation ServiceRs 12,999 per quarter (Exl GST and Govt. Charges)
      Shipping Bill Amendment Coordination (Section 149 Customs Act)Rs 14,999 per amendment (Exl GST and Govt. Charges)
      Section 107 Appeal (Refund Rejection)Rs 60,000 plus success fee (Exl GST and Govt. Charges)
      Success Fee (Discretionary on Recovery)1 to 3 percent of refund recovered (on actual recovery)
      Government / Statutory FeesNo separate government fee for RFD-11 or RFD-01 filing

      All fees and charges listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on the volume of work and the complexity involved.

      Professional service charges for drafting, filing, and representation are separate from the statutory fees. The exact fee depends on the complexity of the case, disputed amount, and number of hearings required. Contact us for a detailed quote.

      Get a free Merchant Exporter Refund consultation - Call +91 945 945 6700 or WhatsApp us. No-obligation assessment.

      Merchant Exporter Refund Timeline by Stage

      StageEstimated Timeline
      RCMC application or renewal (Export Promotion Council)3 to 7 working days (new RCMC); same day for renewal
      LUT filing (Form RFD-11) and ARN generationSame day to 1 working day
      Order placement and intimation to supplier's officerSame day as order
      Concessional-rate supply receipt and tax invoicePer supplier delivery schedule
      90-day export hard deadlineWithin 90 days of supplier tax invoice (Notif 40/2017 condition (c))
      GSTR-1 Table 6A filingBy 11th of following month (monthly filers)
      GSTR-3B Table 3.1(b) filingBy 20th of following month (monthly filers)
      Form GST RFD-01 portal filing with Statement 4Same day from data ready
      Provisional 90 percent refund (RFD-04)Within 7 days of RFD-02 (Section 54(6) + Rule 91)
      Document scrutiny by officer15 to 30 days post acknowledgement
      Final order RFD-06 (balance 10 percent)Within 60 days of RFD-01 filing under Section 54(7)
      Bank credit after RFD-051 to 5 days
      Deemed-export refund cycle (Statement 5B)30 to 60 days end-to-end
      Interest on delay beyond 60 days6 percent per annum (Section 56); 9 percent for appellate orders
      Rule 96(10) legacy claim relief in writ jurisdiction3 to 9 months (per Gujarat HC and Kerala HC rulings)
      Statutory time limit under Section 54(1)2 years from relevant date

      Note on the parallel statutory clocks: Section 54(6) of CGST Act 2017 read with Rule 91 of CGST Rules 2017 mandates provisional 90 percent refund within 7 days of RFD-02 for zero-rated supplies. Section 54(7) caps the final RFD-06 at 60 days from RFD-01. Section 56 interest at 6 percent per annum applies from Day 61 (9 percent for appellate orders). Three statutory clocks run together: 9-month FEMA window for export-proceeds realisation, 2-year refund limitation under Section 54(1), and 90-day export deadline under Notification 40/2017 condition (c) - miss any and consequences differ but each is material.

      Key Benefits

      4 Reasons Why CA-Led Merchant Exporter Refund Filing Beats DIY or Software-Only

      Working Capital Recovery Within 7 Days via Provisional 90 Percent

      DIY filings often miss the Rule 91(2) procedural requirements for provisional sanction - resulting in 45 to 90 day waits for any cash. Patron's quarterly discipline ensures provisional 90 percent refund credited within 7 days of RFD-02 acknowledgement under Section 54(6) - typically recovering Rs 5 to Rs 25 lakh per cycle of working capital that would otherwise sit in the Electronic Credit Ledger.

      Section 50 Interest Exposure Eliminated Through 90-Day Tracking

      Notification 40/2017 condition (c) requires export within 90 days of supplier tax invoice; failure makes the supplier liable for differential GST plus 18 percent interest under Section 50. Patron's invoice-level tracking dashboard with Day-85 alerts prevents this exposure - critical for trading houses with high-frequency procurement cycles spanning multiple supplier GSTINs.

      Refund Rejection Risk Cut Through 3-Way Reconciliation

      Most rejection grounds for merchant exporters trace to GSTR-1 Table 6A vs GSTR-3B Table 3.1(b) vs shipping-bill mismatches. Patron's quarterly discipline reconciles all three at invoice level, files Table 9A amendments where needed, and prevents the most common rejection vector. Zero rejection rate across 18 cycles for our Surat textile client portfolio.

      Rule 96(10) Legacy Recovery Expertise Post October 2024

      Pre-October-2024 Rule 96(10) SCNs and demands continue to trickle into trading houses. Patron's representation pack invoking Notification 20/2024-Central Tax (omission from 08.10.2024) and the Gujarat High Court ruling in Addwrap Packaging Pvt Ltd v UOI (June 2025) for pending proceedings has unlocked retrospective relief for over Rs 30 crore of stuck refunds across our client base.

      Trusted by Indian Merchant Exporters

      10,000+ Businesses | 4.9 Google Rating | 50,000+ Documents Filed | 15+ Years of Merchant Exporter and GST Compliance Experience

      Trusted By

      Hyundai, Asian Paints, Bridgestone, and 200+ Indian merchant exporters across textiles (Surat, Tirupur, Bhilwara), engineering goods (Ludhiana, Rajkot, Coimbatore), chemicals (Vapi, Ankleshwar, Vadodara), agro-products (Kochi, Tuticorin, Vijayawada), pharmaceuticals (Hyderabad, Ahmedabad), and gems and jewellery (Mumbai, Jaipur, Surat).

      Outcome Proof

      A Surat-based textile merchant exporter recovered Rs 1.42 crore in accumulated ITC across 18 monthly cycles between FY 2023-24 and FY 2024-25 through the 0.1 percent concessional route under Notification 40/2017 with Rule 89(4B) refund - zero rejection rate, average RFD-04 provisional 90 percent in 6 days from RFD-02, average RFD-06 final within 54 days (within Section 54(7) 60-day ceiling).

      With offices in Pune, Mumbai, Delhi, and Gurugram, Patron Accounting serves merchant exporters across India - both in-person and remotely.

      2 Refund Routes for Merchant Exporters - 0.1 Percent Concessional vs Deemed Export

      ParameterRoute A: 0.1 Percent Concessional RateRoute B: Deemed Export
      Governing NotificationNotification 40/2017-CT (Rate) and 41/2017-IT (Rate)Notification 48/2017-Central Tax
      Relevant SectionSection 11 CGST Act (partial exemption)Section 147 CGST Act (deemed exports)
      Rate of GST0.1 percent IGST or 0.05 percent CGST plus 0.05 percent SGSTStandard rate paid; refund claimed back
      Goods Leave India?Yes - physical export within 90 days of supplier invoiceNo - supplied to AA / EPCG / EOU domestically
      Who Files RefundMerchant exporter under Rule 89(4B)Supplier or recipient under Rule 89(2)(g) (not both)
      Form / StatementForm GST RFD-01 category any other with Statement 4Form GST RFD-01 category deemed exports with Statement 5B
      Time Limit2 years from relevant date (Section 54(1))2 years from return-filing date
      Pre-ConditionsRCMC + 90-day export + supplier GSTIN on SB + order intimationNotification 48/2017 category match + Notification 49/2017 undertaking
      Procedural CircularCircular 94/13/2019-GST dated 28 March 2019Circular 233/27/2024-GST dated 10 September 2024
      Best ForTrading houses physically exporting goods from IndiaDomestic suppliers to AA holders, EPCG holders, EOU units

      Related GST and Merchant Exporter Compliance Services

      Merchant exporter refund work rarely sits in isolation. Most trading houses need adjacent compliance running in parallel:

      • GST Refund - parent practice covering all Section 54 refund categories beyond merchant exports such as inverted duty structure, excess balance, or appeal-related refunds
      • GST Returns - monthly GSTR-1 (Table 6A for exports) and GSTR-3B (Table 3.1(b)) that anchor every merchant-exporter refund claim under Rule 89(2)(g)
      • GST Annual Returns - GSTR-9 and GSTR-9C reconciliation that must precede any refund audit in a financial year
      • GST Audit - for merchant exporters above the prescribed turnover threshold; departmental GSTR-9C reconciliation
      • GST Registration - mandatory under Section 22 CGST Act for any merchant exporter; pre-condition for RCMC and IEC
      • GSTAT Appeal - Exporters - escalation route when Section 107 appeal on merchant-exporter refund rejection is adverse; pre-deposit and grounds preparation

      Legal and Compliance Framework

      Section 16 of IGST Act 2017

      Defines zero-rated supply (exports + SEZ). Section 16(3) provides two refund routes for merchant exports: LUT/bond without IGST payment with refund of accumulated ITC under Rule 89(4), or IGST-paid with refund of IGST under Rule 96. Post Rule 96(10) omission (08.10.2024), both routes are fully available without earlier concessional-supply restriction.

      Section 54 of CGST Act 2017

      Section 54(1) - 2-year limitation from relevant date. Section 54(3) - refund of unutilised ITC. Section 54(6) - provisional 90 percent refund for zero-rated supplies within 7 days of RFD-02. Section 54(7) - final refund within 60 days. Section 56 - 6 percent interest if delayed beyond 60 days; 9 percent for appellate orders.

      Section 147 of CGST Act 2017

      Empowers the Central Government to notify deemed exports. Operationalised by Notification 48/2017-Central Tax dated 18 October 2017 listing four categories: supply against Advance Authorisation, supply of capital goods against EPCG Authorisation, supply to Export Oriented Units, and supply of gold by notified bank or PSU against Advance Authorisation.

      Rule 89(4B) of CGST Rules 2017

      Specifies how a merchant exporter who has procured goods at the 0.1 percent concessional rate under Notification 40/2017 or 41/2017 may claim refund of input tax credit blocked due to rate inversion. Filed in Form GST RFD-01 under category any other. Procedure laid down in CBIC Circular 94/13/2019-GST dated 28 March 2019.

      Rule 96(10) of CGST Rules 2017 - OMITTED 08.10.2024

      Between 23 October 2017 and 8 October 2024, exporters who used concessional supplies could not also claim IGST refund on payment of tax. Notification 20/2024-Central Tax dated 8 October 2024 omitted this rule prospectively. The Gujarat High Court in Addwrap Packaging Pvt Ltd v Union of India (decided 13 June 2025) held that the omission applies to all proceedings pending as on 8 October 2024 where final adjudication had not taken place - effectively granting retrospective relief.

      Notification 40/2017-Central Tax (Rate) and 41/2017-Integrated Tax (Rate)

      Both dated 23 October 2017. Concessional rate of 0.05 percent CGST plus 0.05 percent SGST or 0.1 percent IGST on supplies to merchant exporters. Conditions: (a) supplier registered with EPC/Commodity Board; (b) recipient registered with EPC/Commodity Board; (c) export within 90 days with supplier GSTIN and invoice number on shipping bill; (d) order copy intimated to supplier's jurisdictional officer.

      Notifications 48/2017-CT and 49/2017-CT (18 October 2017)

      Notification 48/2017-CT lists 4 categories of deemed exports under Section 147. Notification 49/2017-CT prescribes evidence requirements - undertaking from the non-claiming party that they will not claim refund on the same invoice (supplier or recipient option).

      CBIC Circulars 37/11/2018-GST, 94/13/2019-GST, and 233/27/2024-GST

      Circular 37/11/2018-GST dated 15 March 2018 - concessional rate is optional for the supplier. Circular 94/13/2019-GST dated 28 March 2019 - procedure for merchant exporter ITC refund under Rule 89(4B), filed in RFD-01 under category any other. Circular 233/27/2024-GST dated 10 September 2024 - relaxation for AA holders and 100 percent EOUs against past Rule 96(10) recovery proceedings.

      RoDTEP and MEIS Framework

      MEIS was discontinued and RoDTEP replaced it from 1 January 2021. RoDTEP administered by DGFT separately from GST refund - remits embedded central, state, and local levies not refunded under GST. Rates under Appendix 4R range from 0.3 to 4.3 percent of FOB value; e-scrips on ICEGATE. DGFT Notification 66/2025-26 dated 23 March 2026 restored RoDTEP rates and value caps to full notified levels. RoDTEP and GST refund are non-overlapping benefits.

      Addwrap Packaging Pvt Ltd v Union of India (Gujarat HC, June 2025)

      The Gujarat High Court held that the Notification 20/2024-Central Tax omission of Rule 96(10) applies to all proceedings pending as on 8 October 2024 where final adjudication had not taken place. The judgment provides framework for retroactive refund recovery for past periods where rejection was based on Rule 96(10) restriction.

      Who qualifies as a merchant exporter under GST?

      A merchant exporter is a person registered under the CGST Act who is also registered with an Export Promotion Council or a Commodity Board recognised by the Department of Commerce, and who buys goods from a registered domestic supplier for the purpose of export. Notification 40/2017-Central Tax (Rate) dated 23 October 2017 anchors this definition for the purpose of the 0.1 percent concessional GST rate.

      What is the 0.1 percent concessional GST rate for merchant exporters?

      Under Notification 40/2017-CT (Rate) and Notification 41/2017-IT (Rate), a registered supplier may charge GST at only 0.05 percent CGST plus 0.05 percent SGST or 0.1 percent IGST on goods supplied to a registered merchant exporter. The merchant exporter must export those goods within 90 days of the supplier's tax invoice date and indicate the supplier GSTIN and invoice number on the shipping bill or bill of export.

      Can a merchant exporter claim refund of IGST paid on exports?

      Yes. With Rule 96(10) omitted from 8 October 2024 by Notification 20/2024-Central Tax, merchant exporters may now export on payment of IGST and claim refund without the earlier restriction that blocked the route where concessional supplies had been availed. The Gujarat High Court in Addwrap Packaging Pvt Ltd v Union of India (June 2025) extended this relief to all proceedings pending as on 8 October 2024.

      Merchant exporter ka GST refund kaise milega?

      Merchant exporter do raaste use kar sakta hai: pehla, supplier se 0.1 percent concessional rate par maal kharidkar Rule 89(4B) ke under accumulated ITC ka refund Form RFD-01 me file karna; doosra, IGST pay karke export karna aur refund claim karna (Rule 96(10) ab omitted hai 8 October 2024 se). 90 din ke andar export hona zaroori hai aur shipping bill par supplier ka GSTIN aur invoice number aana chahiye Notification 40/2017 condition (c) ke hisaab se.

      What is Rule 89(4B) of the CGST Rules?

      Rule 89(4B) of the CGST Rules 2017 specifies how a merchant exporter who has procured goods at the 0.1 percent concessional rate under Notification 40/2017 or 41/2017 may claim refund of input tax credit. The refund is filed in Form GST RFD-01 under category any other, and the procedure is laid down in CBIC Circular 94/13/2019-GST dated 28 March 2019.

      How long does a merchant-exporter GST refund take?

      The proper officer must grant a provisional 90 percent refund within 7 days of the acknowledgement in Form RFD-02 under Section 54(6) of the CGST Act read with Rule 91 of the CGST Rules. The balance 10 percent follows after document verification, with the final order in Form RFD-06 due within 60 days of the original RFD-01 filing under Section 54(7). Section 56 interest at 6 percent per annum applies if delayed.

      What is the difference between merchant export and deemed export?

      Merchant export under Notification 40/2017 involves physical movement of goods out of India by a trading entity within 90 days of supplier tax invoice. Deemed export under Section 147 and Notification 48/2017 covers supplies to Advance Authorisation holders, EPCG holders, and EOUs where goods stay in India but are treated as exports for tax purposes. Refund mechanics, timelines, and forms differ.

      RoDTEP aur GST refund saath me mil sakta hai kya?

      Haan, lekin double-claim allowed nahi hai. RoDTEP DGFT ke through e-scrips de raha hai jo basic customs duty pay karne ke liye use hota hai. GST refund alag se file hota hai unutilised ITC ya IGST paid par. Dono ke beech ek hi tax twice claim nahi karna chahiye. DGFT Notification 66/2025-26 ne RoDTEP rates restore kar diye full notified levels par. Dono benefits non-overlapping hain.

      Has MEIS been replaced by RoDTEP for merchant exporters?

      Yes. The Merchandise Exports from India Scheme (MEIS) was discontinued and the Remission of Duties and Taxes on Exported Products (RoDTEP) scheme replaced it from 1 January 2021. DGFT Notification 66/2025-26 dated 23 March 2026 restored RoDTEP rates and value caps to full notified levels under Appendix 4R and 4RE. RoDTEP and GST refund are non-overlapping benefits.

      What documents are mandatory for a merchant exporter refund?

      GSTIN, RCMC from the Export Promotion Council or Commodity Board, IEC certificate, supplier tax invoice at 0.1 percent rate, shipping bill or bill of export carrying supplier GSTIN and invoice number, EGM or export report, GSTR-1 with Table 6A, GSTR-3B with Table 3.1(b), BRC, and a CA certificate in Annexure 2 of RFD-01 where the refund exceeds Rs 2 lakh.

      Quick Answers

      • What is the GST rate for merchant exporters? 0.1 percent IGST or 0.05 percent CGST plus 0.05 percent SGST under Notification 40/2017-CT (Rate).
      • Which form is used for merchant exporter refund? Form GST RFD-01 filed online on gst.gov.in under the category any other with Statement 4.
      • Within how many days must goods be exported? 90 days from the supplier tax invoice date under Notification 40/2017 condition (c).
      • Is Rule 96(10) still in force? No. It was omitted with effect from 8 October 2024 by Notification 20/2024-Central Tax.
      • Where do I register as a merchant exporter? With any Export Promotion Council or Commodity Board recognised by the Department of Commerce.
      • Can SEZ supplies use the 0.1 percent rate? Notification 40/2017 strictly covers supplies to merchant exporters; SEZ supplies follow Section 16 IGST Act zero-rated route.
      • Time limit for merchant exporter refund? 2 years from the relevant date under Section 54(1) CGST Act.

      Merchant Exporter Refund Statutory Deadlines and 4 Parallel Clocks

      Four statutory clocks run together for a merchant exporter. Miss any one and the consequences differ but each is material:

      • 90-day export window - from supplier tax invoice date under Notification 40/2017 condition (c); failure makes supplier liable for differential GST plus 18 percent interest under Section 50 CGST Act
      • 9-month FEMA realisation window - RBI Master Direction on Export of Goods and Services; without timely realisation or RBI extension, refund eligibility lapses
      • 2-year refund limitation under Section 54(1) - counted from relevant date (date of export proceeds realisation); statutory bar; no condonation under Section 54
      • LUT FY 2026-27 renewal - before 31 March 2026 (or first export of FY 2026-27); every export from 1 April 2026 attracts IGST upfront if LUT not on record under Rule 96A
      • RFD-02 acknowledgement window - within 15 days of ARN under Rule 90(2); escalate via grievance under Rule 90 if officer fails
      • RFD-04 provisional 90 percent - within 7 days of RFD-02 under Section 54(6) + Rule 91(2)
      • RFD-06 final sanction - within 60 days of RFD-01 under Section 54(7); 6 percent Section 56 interest if delayed; 9 percent for appellate orders
      • RCMC validity - typically 5-year validity from Export Promotion Council; renewal before expiry to maintain Notification 40/2017 eligibility
      • Section 107 appeal - within 3 months of RFD-06 rejection; 10 percent pre-deposit; condonable +1 month under Section 107(4)
      • Section 112 GSTAT appeal - within 3 months of Appellate Authority order; additional 10 percent pre-deposit

      Engage Patron Accounting for merchant exporter compliance retainer - share GSTIN, RCMC details, IEC, sector, supplier mix, and last 12 months export turnover. Call +91 945 945 6700 or WhatsApp us now.

      Talk to Patron's Merchant Exporter Refund Team

      GST refund for merchant exporters is the difference between recovering 18 percent of procurement cost and watching it sit in the Electronic Credit Ledger indefinitely. Notification 40/2017-CT (Rate), Notification 41/2017-IT (Rate), Notification 48/2017-CT, and Notification 49/2017-CT give exporters two distinct but specific paths - the 0.1 percent concessional rate route with Rule 89(4B) refund of accumulated ITC, and the deemed-export route under Section 147 CGST Act with supplier-or-recipient option.

      Each route has its own evidence trail and deadlines. With Rule 96(10) omitted from 8 October 2024 by Notification 20/2024-Central Tax and the Gujarat High Court ruling in Addwrap Packaging Pvt Ltd v UOI (June 2025) extending relief to all proceedings pending as on the omission date, the IGST-paid export route is now fully available without the historical concessional-supply restriction. MEIS has been replaced by RoDTEP from 1 January 2021; DGFT Notification 66/2025-26 (23 March 2026) restored RoDTEP rates and value caps to full notified levels under Appendix 4R and 4RE - RoDTEP and GST refund stack as non-overlapping benefits.

      Patron Accounting LLP's CA and CS team handles these filings end-to-end - from RCMC verification and order intimation through to Rule 89(4B) Statement 4 computation, GSTR-1 Table 6A and GSTR-3B Table 3.1(b) reconciliation, shipping bill amendment coordination under Section 149 Customs Act, RFD-06 final-order tracking, and Rule 96(10) legacy SCN representation. With offices in Pune, Mumbai, Delhi, and Gurugram and a national client base of 10,000-plus businesses including 200+ active merchant exporters across textiles, engineering goods, chemicals, agro-products, pharmaceuticals, and gems and jewellery, we are equipped to manage refund cycles for trading houses of any volume.

      Book a Free Consultation - No Obligation.

      Related GST and Merchant Exporter Compliance Services

      End-to-end GST refund and merchant exporter compliance coverage - from RCMC through to GSTAT Section 112 escalation for refund rejection appeals.

      Content Created: 8 May 2026  |  Last Updated: 11 May 2026  |  Next Review: 8 August 2026  |  Reviewed By: CA & CS Team · Patron Accounting LLP

      Reviewed every 3 months under Tier 1 freshness cycle. Triggers for earlier review: any GST Council notification on Notification 40/2017 conditions or Rule 89(4B), CBIC circular on merchant exporter refund procedure, DGFT notification on RoDTEP rates or Appendix 4R/4RE, RBI master direction on FEMA realisation, or HC/SC ruling on Rule 96(10) legacy proceedings.