IGST Refunds

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K M Guru Rajesh, Deputy Commissioner IGST Refunds Resolution of Errors

Transcript of IGST Refunds

Page 1: IGST Refunds

K M Guru Rajesh, Deputy Commissioner

IGST RefundsResolution of Errors

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GSTR1/3B ReturnsShipping Bill/

EGMICES

Flow of Data

GSTN

Rule 96 of the

CGST Rules

2017

Export with

payment of

Taxes

Matching between the two

data sources is done at

Invoice level

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• Once the GSTR-1 and GSTR-3B are filed “CORRECTLY”, then the data will match with the GST Network and it will transmit

the data to ICES (Indian Customs EDI Systems).

• On receipt of the data from the GST Server, an integration between Shipping Bill and data received from the GSTN takes

place.

• If no mismatch / error is found while integration, Systems tags the Shipping Bill as “Ready” for scroll

generation. PFMS (Public Financial Management System) is the portal to remit the amount to the exporter’s account

against the eligible shipping bills/invoices.

• “ Not Ready” tag is given to the Shipping Bill in two situations, namely:

A. Either the data pertaining to the Shipping Bill/Invoice, has not been sent by the GST Network to ICES (i.e.

Customs Portal).

B. Or the data has been received from the GSTN, but the same has been stuck into some error code(s) while

integration.

• If systems notice any mismatch between Shipping Bill data and GST data, it generates Response Codes viz. SB001, SB002,

SB003, SB004, SB005 and SB006.

IGST refund Procedure

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• If systems notice any mismatch between Shipping Bill data and GST data, it generates Response Codes (IGST Refund

Error Codes) viz. SB001, SB002, SB003, SB004, SB005 and SB006.

Data Received from GSTN, but stuck becauseof Errors

• Response Code SB001 :

It is generated when Shipping Bill Number or Shipping Bill Date at ICES is not matched with what is mentioned in the

GSTR-1.

Solution:

Same can be corrected by using Table 9A of GSTR-1.

• Response Code SB002 :

It is generated when Local EGM has not been filed or filed with some errors.

Solution:

Same can be corrected with the help of Container/Shipping Line Agent.

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• Response Code SB003 :

This error occurs when GSTIN declared in the SB does not match with the GSTIN used to fill the corresponding

GST Returns.

Solution:

Same can be corrected by using Table 9A of GSTR-1. However, it is to be noted that there is no provision of

amendment in the Shipping Bill once the EGM is filed.

• Response Code SB004 :

Record already received from the GSTN.

Solutions

For this Error no action is required from the exporter.

Data Received from GSTN, but stuck becauseof Errors.. (Cont..)

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• Response Code SB005 :

It is generated when Invoice Number or Date of Shipping Bill does not match with what is mentioned

in the GSTR-1

Solution:

a. Same can be corrected by using Table 9A of GSTR-1.

b. Exporter may also approach Customs formation (from where export took place) along with Annexure

‘A’ (Concordance Table). Officers at Customs formations have been allotted physical interface to rectify

the error.

Further New Circular 5/2021 dated 17.02.2021 allows correction of invoice mismatch errors

irrespective of date of filing of the shipping bill with a payment of Rs. 1000/- as Fees.

Data Received from GSTN, but stuck becauseof Errors.. (Cont..)

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Response Code SB006 :

It is generated when either EGM at Gateway has not been filed or filed with some errors.

Solution:

a. Get the EGM filed

b. If EGM at Gateway is filed with some errors get it corrected with the help of Shipping Line Agent.

You might get Error Code “C” which mean mismatch of Container Number. For this, officers at Gateway

port has been given physical interface (PREV_OFF) to correct this error. (Now Port of export can do)

Apart from this Error Code “M” (Gateway Port Code in Truck Summary is different from Actual Gateway

Port) and Error Code “L” (Leo Date>Sail Date) may be corrected at Local Customs Locations.

Once the above corrections are made, the gateway port has been given the option to Revalidate EGM in the

EGM role to validate the gateway EGM with the corrected values. Even in cases where the local EGM/truck

summary is submitted after the filing of the Gateway EGM for some reason, the option to Revalidate EGM

should be used first.

Data Received from GSTN, but stuck becauseof Errors.. (Cont..)

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SB001 This may occur due to a mismatch between the SB No.

furnished in GSTR-1/6A and the SB No. with customs.

The possible reason for such mismatch could be a

clerical error made by the exporter at the time of filling

of GSTR-1/6A

It can be rectified by making amendments in GSTR-1 by using Form 9A.

SB002 EGM not filled Exporter may approach the Shipping Lines file the EGM immediately. If EGM is already filed by shipping Line correctly, “Revalidate EGM”

option may be used by EGM Officer.

SB003 GSTIN mismatchSame can be corrected by using Table 9A of GSTR-1.

If PAN is given instead of GSTIN, Undertaking is required to be submitted.

SB004 RECORD ALREADY RECEIVED This error code occurs due to duplicate/repeat transmission of SB-Invoice record from GSTN.

The previous transmission would have already been validated for IGST refund by ICES.

SB005 Invoice Mismatch This is the most common error faced by the exporters, which occurs due to mismatch of invoice number as declared in the Invoice Table in

the SB and that declared in the GSTR 1 for the same supply. This can happen due to:

a) Typographical mistake while entering data in GSTR 1 or the SB.

b) The exporter uses two sets of invoices, one invoice for GST and another invoice for exports resulting in mismatch of invoice numbers

If SB005 is due to a data entry mistake in GSTR 1, it can be amended now in Form 9A.

But any mistake in the SB cannot be amended once EGM is filed.

SB006 Gateway EGM not available – In case of ICDs, if the

Gateway EGM is not filed electronically or is stuck in

some error, response code SB006 shall appear.

It is well known practice that cargos originating from ICD’S, Local EGM has been filled Manually whereas Gateway EGM has been filed

online, due to which system is not able to reconcile the data between local and gateway EGM and hence IGST refund gets blocked.

Therefore CBIC vide Circular No. 42/2017- Customs. dated 07.11.2017 instructed that all the custodians /carriers/shipping lines

operating at ICDs/Gateway ports should file EGM online. It is re-iterated that as the first step, the concerned stakeholders at the originating

ICDs should file the local EGMs online

Summary

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Other Errors..

Error Code Indicates Responses and Actions

SB000

This response code comes when all

the decided parameters like GSTIN,

SB number, Invoice Number etc.

match between GSTN and Customs

databases. This code implies that

the SB is ripe for inclusion in the

IGST refund scroll.

a) The exports might have been made under bond or LUT, hence not liable for refund.

b) If a shipping bill covers multiple invoices, few of the invoices might have been

successfully validated with code SB000 whereas other invoices might be stuck with

any of the other errors.

c) Higher rate of Drawback has been claimed for that SB, thus making the SB

ineligible for IGST refund.

d) Where the IGST claim amount is less than Rs. 1000/-.

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• In all the above cases, the scroll amount shall automatically become zero and the SBs shall not be

included in the refund scroll.

• There are two more reasons where the SBs will figure in the Temporary IGST Scroll but not in the Final

Scroll. This could happen if there is an alert/suspension on the IEC in ICES or if the account of the

IEC is not validated by PFMS.

• PFMS Errors—City Customs public notice 45/2020 City Customs.

• (https://www.icegate.gov.in/Download/Bank_Account_Management_Advisory_150720.pdf)

Other Errors..

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a) Cases where the exporter has erroneously declared that the shipment is without payment of IGST,

although they have declared and paid the IGST in GST Returns.

b) SBs with error code SB003, where the exporter has either declared a different GSTIN in the SB or has only

declared PAN, and the corresponding returns have been filed through another GSTIN with the same PAN

In case of (b), an undertaking may be obtained from the GST registered unit which has filed the returns that

they have no objection to the refund being granted to the exporter who has filed the Shipping Bill and that

they will not claim any IGST Refund for exports under that SB separately. Once satisfied, the officer may

sanction the applicable IGST Refund through the Officer Interface.

Other Measures:

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• The validation procedure for IGST refund is run only for those SBs where EGM has been filed and for which the GSTN has

transmitted the GSTR 1 returns data to Customs.

• conditions for GSTN to transmit the data:

a) Both, GSTR1/6A and GSTR3B should have been filed for that supply

b) The IGST paid on exports declared in GSTR 3B should not be less than that declared in GSTR1/6A

c) There are no missing invoices in GSTR1 for that supply

• Even after the correct filing of returns as above, their SBs do not reflect in this report, Exporters are advised to write to GSTN

helpdesk.

• For such SBs, system will throw up an error that

“There is no information received from GSTN for this SB”.

• It is advised to correct the inconsistencies in GST Returns by contacting GSTN helpdesk

Non Transmission of Returns Data from GSTN

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Insert GSTN home page screen shot

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Scenario 1 : Non Filing of GSTR-1 / Table 6A of GSTR-1 / GSTR 3B

• Refund can’t be processed unless GSTR-1/Table 6A of GSTR-1 and/or GSTR-3B are filed.

Resolution:

• Ensure Filing of GSTR -1 & GSTR 3-B.

• Exporters having turnover below 1.50 crores may voluntarily opt for Monthly Filing of GSTR-1 for getting Refund quicker.

Scenario 2: Incorrect Filing of GSTR-1

• Detail of shipping bill and port code not mentioned in Table 6A/GSTR-1.

• Taxpayers who had filed GSTR 1E (Table 6A) with deficiencies, due to which their refund of IGST paid on export were not

processed, subsequently, filed GSTR 1 with corrected data of Table 6A. However, such data was not allowed to be integrated again

in Table 6A because the taxpayer had already filed his GSTR 1E (Table 6A).

Resolution:

• Amend Table 6A data through Table 9A of subsequent GSTR 1.

• Exporters need to provide Complete and Correct Data while filing Table 6A of GSTR-1.

Role of the Exporter

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Scenario 3: Incorrect Filing of GSTR 3B

a) IGST paid in Table 3.1(b) of GSTR 3B is lesser than total IGST claimed in Table 6A of GSTR-1 for the same period. It is one of validation

check by GSTIN that aggregate IGST paid amount claimed in Table 6A of GSTR-1 is not higher than IGST paid amount indicated in

Table under column 3.1(b) of GSTR-3B of corresponding month.

b) Total IGST, payable through export invoices specified under Table 6A of GSTR 1, is not specified correctly under Table 3.1(b) of GSTR3B

and incorrectly mentioned under Table 3.1(a) [domestic supplies] i.e. While correct details of exports have been declared in Table 6A of

GSTR-1, in GSTR-3B, export data has been disclosed as domestic supplies.

Resolution:

1. If IGST paid has been reported in GSTR-3B in 3.1(a)[domestic supplies] instead of 3.1(b)[exports] and IGST shown to have been paid

under Table 6A of GSTR 1 of that tax period, appropriate adjustment may be done in subsequent month.

2. If IGST paid on exports has been declared as ZERO in Table 3.1(b), whereas, IGST shown to have been paid under Table 6A of GSTR 1

for that tax period, the correct amount can be declared and offset while filing GSTR 3B of subsequent tax period.

3. If IGST paid on exports declared in Table 3.1(b) is lesser that the total IGST shown to have been paid under Table 6A and Table 6B of

GSTR 1, differential amount of IGST can be paid through GSTR 3B of subsequent tax period.

*Where adjustments have been made in Form GSTR-3B of multiple months, corresponding adjustments in Form GSTR-1 should also

preferably be made in the corresponding months.

Role of the Exporter..

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Circular No 04/2021 dated 16.02.2021

Extension of Board Circular 12/2018 –Customs dated 29.05.2018

CA Certificate for the period April 2019 to March 2020 and April 2020 to March 2021 shall be furnished by 31.03.2021 and

30.10.2021 respectively

1. Cases where there is no short payment

• For the exporters where Amount paid against form 3.1(a) and 3.1(b) is greater than the cumulative IGST Amount indicated

in GSTR-1

• Total IGST, payable through export invoices specified under Table 6A of GSTR 1, is not specified correctly under Table 3.1(b)

of GSTR3B and incorrectly mentioned under Table 3.1(a) [domestic supplies]

• Customs Policy wing will send list to GSTN

• GSTN will transmit the records to Customs EDI System and confirmation email to Exporters and Refund would be

sanctioned.

• CA Certificate to be submitted to the port of Export * and copy of the same to Jurisdictional GST office.

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Circular No 04/2021 dated 16.02.2021…

2. Cases where there is a short payment

• For the exporters where Amount paid against form 3.1(a) and 3.1(b) is less than the cumulative IGST Amount indicated in

GSTR-1

• Customs Policy wing will send list to GSTN and All Customs Zones.

• GSTN will inform Exporters by e-mail to observe the procedure under this circular

• Exporter will have to make the payment of IGST equal to short payment and proof of payment shall be submitted to DC/AC

of Customs in port of export and Refund would be sanctioned.

• CA Certificate to be submitted to the port of Export * and copy of the same to Jurisdictional GST office.

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Case 4: Incorrect Filing of Shipping Bill

As per Rule 96 of the CGST Rules 2017, the shipping bill filed by an exporter shall be deemed to be an

application for refund of integrated tax paid on the goods exported out of India.

If Exporter opts LUT/NA or mentions “0” against “IGST Paid” field, it will keep away the exporter to avail refund

claim even if they have paid the IGST as the exporter himself has declared the same in the Shipping Bill.

• Resolution

Approach Jurisdictional Customs Office.

• Role of the Exporter..

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Thank You