Rule 89(1) and (2): Who Applies, and With What Evidence

Rule 89 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.

A refund application is judged on its annexures, not its form. Rule 89(2) lists them, category by category, and most rejections trace to something on that list.

Rule 89(1): any person claiming refund of any tax, interest, penalty, fees or any other amount paid may file an application in FORM GST RFD-01 electronically. For a supply to an SEZ unit or developer, the application is filed by the supplier — or, in specified cases, by the SEZ unit or developer where it is the recipient of a supply on which tax was paid. Rule 89(2) then prescribes the documentary evidence to be furnished, by category.

Who applies

The person who bore the tax, in most cases.

For a supply to an SEZ unit or developer: the application is filed by the supplier of goods after the goods have been admitted in full into the SEZ for authorised operations, as endorsed by the specified officer of the Zone; or by the supplier of services along with evidence of receipt of services for authorised operations, endorsed by the specified officer.

For deemed exports: either the supplier or the recipient, on the conditions in the deemed export notification — with the other furnishing an undertaking that it will not claim. Deemed exports →

For excess balance in the cash ledger: the registered person.

For tax paid on a supply not provided: the person who paid.

The Rule 89(2) list

(a) The reference number of the order and a copy of the order passed by the proper officer, an appellate authority, Appellate Tribunal or court resulting in the refund, or the reference number of the payment of the amount specified in s.107(6) and s.112(8) claimed as refund.

(b) A statement containing the number and date of shipping bills or bills of export and the number and date of the relevant export invoices, in a case where the refund is on account of export of goods.

(c) A statement containing the number and date of invoices as provided in Rule 46 along with the evidence regarding the endorsement specified in the second proviso to sub-rule (1), in the case of supply of goods made to an SEZ unit or developer.

(d) A statement containing the number and date of invoices, the evidence regarding the endorsement, and the details of payment along with the proof thereof made by the recipient to the supplier for authorised operations, in the case of supply of services made to an SEZ unit or developer.

(e) A declaration to the effect that the SEZ unit or developer has not availed input tax credit of the tax paid by the supplier, in the case of supply of goods or services to an SEZ.

(f) A declaration to the effect that the goods have been received by the recipient and a declaration that no input tax credit has been availed, in the case of deemed export.

(g) A statement containing the number and date of invoices along with such other evidence as may be notified, in the case of deemed export.

(h) A statement showing the details of the amount of claim on account of excess payment of tax.

(i) A statement containing the number and date of invoices received and issued during a tax period, in a case where the claim relates to refund of unutilised input tax credit.

(j) A declaration that the incidence of tax has not been passed on, where the amount claimed does not exceed ₹2 lakh.

(k) A certificate in Annexure 2 of FORM GST RFD-01 issued by a chartered accountant or a cost accountant, certifying that the incidence of tax has not been passed on, where the amount claimed exceeds ₹2 lakh.

The ₹2 lakh line

Section 54(4) and its proviso set the structure:

• the application must be accompanied by documentary evidence establishing the refund is due, and evidence that the incidence of tax was not passed on;
• but where the amount claimed is less than ₹2 lakh, a declaration by the applicant, based on the documentary or other evidence available with him, suffices.

Above ₹2 lakh, the CA or CMA certificate is required.

Rule 89(2) proviso disapplies clauses (j) and (k) — the declaration and the certificate — where the refund is claimed under s.54(8)(a) to (f), which are the categories to which unjust enrichment does not apply. Section 54(8): unjust enrichment →

So an exporter, a zero-rated supplier, or a claimant of unutilised credit does not need the certificate, whatever the amount.

The SEZ endorsement

Clauses (c), (d) and (e) all turn on it.

For goods: an endorsement by the specified officer of the Zone that the goods have been admitted in full into the SEZ for authorised operations.

For services: evidence of receipt of services for authorised operations, endorsed by the specified officer, plus proof of payment by the recipient to the supplier.

Plus a declaration that the SEZ unit or developer has not availed input tax credit of the tax paid by the supplier.

That last declaration is what prevents a double benefit — the supplier claiming refund of tax it paid, and the SEZ unit claiming credit of the same tax. It has to be obtained from the SEZ entity, which means the supplier's refund depends on the recipient's cooperation. SEZ registration and supplies →

Rule 89(3): the debit requirement

Where the application relates to refund of input tax credit, the electronic credit ledger shall be debited by the applicant by an amount equal to the refund so claimed.

So the credit leaves the ledger when the claim is filed, not when it is sanctioned. Where the claim is rejected, the amount is re-credited through FORM GST PMT-03. Re-credit of a rejected refund →

Key takeaways

• RFD-01 electronically, with the Rule 89(2) evidence for the category.
• Above ₹2 lakh, a CA or CMA certificate on unjust enrichment — unless the claim falls in s.54(8)(a) to (f).
• SEZ claims need the specified officer's endorsement and a declaration that the SEZ entity took no credit.
• Deemed export claims need a declaration that the goods were received and no credit availed.
• Rule 89(3): the credit ledger is debited when the claim is filed.
• The claim is judged on the annexures, not the form.

Read next

• Section 54(8): Unjust Enrichment and the Exceptions
• Rule 89(4): The Zero-Rated Refund Formula
• GST Refund Checklist: Documents Required for Each Type
• Re-Credit of a Rejected Refund: PMT-03

Disclaimer: Positions stated as on 5 September 2026, based on the CGST Rules as amended to 31 March 2026 (ICAI Bare Law, 12th edition) and the ICAI Handbook on Refunds under GST (January 2026).