Refund Filing Checklist for CAs: Documents, Statements, Declarations and CA/CMA Certificates in RFD-01

GST refund work fails more due to missing documents than due to eligibility. Form GST RFD-01 is not only a form. It is a complete package of statements, declarations, undertakings, certificates, and supporting documents. The GSTportal accepts the application online, but the refund officer decides the claim based on attachments and system checks. If the file pack is incomplete, the refund gets delayed through a deficiency memo or rejection.

1) First step: Select the correct refund category in RFD-01

Every refund category has a different document set. If the wrong category is selected, the portal may accept the application, but the refund will not pass scrutiny.

The main refund categories include export refunds, SEZ refunds, deemed export refunds, inverted duty refunds, excess cash ledger refunds, excess payment refunds, and order-based refunds.

Once the category is locked, the checklist becomes clear.

2) Core requirement: Evidence to prove refund is due

The refund application must be supported by documents to prove that refund is due. These documents depend on the type of refund.

Examples of mandatory evidence:

• Export invoice and shipping bill details for export of goods
• Foreign inward remittance proof for export of services
• Endorsement from SEZ officer for supplies to SEZ
• Statement of inward and outward invoices for inverted duty refund
• Copy of assessment order or appeal order for order-based refunds
• Proof of tax payment for excess payment refunds
• Agreement and termination proof for refunds claimed by unregistered persons in contract cancellation cases

A refund file must be treated as an evidence bundle. If one key evidence document is missing, the refund claim will not survive scrutiny.

3) RFD-01 statements: Refund is a statement-driven process

Most GST refunds require specific statements. These statements are not optional. They form the base of refund computation.

Some common statements are:

• Statement of export invoices and shipping bill details
• Statement of export of services invoices and receipt details
• Statement of supplies made to SEZ and endorsements
• Statement of inward supplies and outward supplies for inverted duty refund
• Statement of tax paid in excess or wrong head payment
• Statement of invoices for deemed export claims

The portal format must be followed. Wrong format leads to deficiency memo.

4) Declarations and undertakings: Most ignored, most important

Refund applications require declarations and undertakings. Many refund applications fail because these are missing or incorrectly selected.

Common declarations and undertakings include:

• Declaration that refund is not claimed for restricted categories
• Undertaking regarding non-passing of tax burden (unjust enrichment)
• Undertaking relating to compliance of inputtax credit conditions
• Undertaking that no double benefit has been taken
• Undertaking linked to export refund conditions

These are legal statements by the taxpayer and must be checked before filing.

5) Unjust enrichment: Self-declaration vs CA/CMA certificate

This is the most important compliance point in many refund cases.

If the refund amount is within the prescribed threshold, the applicant must file a self-declaration that the incidence of tax, interest, or any other amount has not been passed on to any other person.

If the refund amount exceeds the prescribed threshold, a certificate from a Chartered Accountant or Cost Accountant is compulsory in the prescribed format. This certificate confirms that the tax incidence has not been passed on.

This is not a formality. If the certificate is missing or not in the correct format, the refund will not be sanctioned.

It is also important to maintain a working paper file for this certificate, such as:

• sales invoices
• credit notes
• contract terms
• pricing documents
• ledger extracts
• cost sheet where relevant

6) Category-wise practical checklist for common refund types

A) Export of goods without payment (LUT)

Minimum documents and statements:

• Export invoice statement
• Shipping bill details
• LUT copy
• GSTR-2B of the relevant period
• Self-certified invoice copies where portal mismatch exists
• If non-EDI export, supporting shipping documents

Key check:

• Export invoice must match GSTR-1
• Shipping bill must match ICEGATE
• ITC should match with 2B

B) Export of services without payment (LUT)

Minimum documents and statements:

• Export of services invoice statement
• Proof of receipt of foreign exchange (BRC/FIRC)
• GSTR-2B of the relevant period
• LUT copy
• Self-certified invoice copies where mismatch exists

Key check:

• Place of supply and recipient details must satisfy export definition
• Foreign remittance must match invoice value

C) Supplies to SEZ without payment

Minimum documents and statements:

• Statement of invoices for SEZ supplies
• SEZ endorsement for authorised operations
• Proof of receipt of goods/services by SEZ unit
• GSTR-2B
• Self-certified invoice copies where mismatch exists

Key check:

• Endorsement is mandatory, without it refund fails

D) Inverted duty refund

Minimum documents and statements:

• Statement of inward supplies and outward supplies
• Working of refund as per formula
• GSTR-2B
• Self-certified invoices not reflected in 2B
• Declaration and undertakings as required

Key check:

• ITC should be eligible and not blocked
• Refund working must match formula
• Ineligible ITC must be removed

E) Refund arising from order or appeal

Minimum documents:

• Copy of order
• Proof of payment (pre-deposit, tax payment)
• Computation of refund amount
• Bank account proof

Key check:

• Verify that the order permits refund and covers the amount claimed

7) How to build a refund file

A clean file should contain:

1. RFD-01 and ARN trail
2. Statements (all refund statements in portal format)
3. Upload documents (BRC/FIRC, SEZ endorsement, 2B, invoice sets, shipping bills)
4. Unjust enrichment file (self-declaration or CA/CMA certificate + working papers)
5. Return reconciliation (GSTR-1, GSTR-3B, 2B, refund statement matching)

This structure helps in deficiency memo reply, audit queries, and client reporting.

8) Final checklist before clicking “Submit”

Before filing RFD-01, confirm:

• Refund category selected is correct
• Statement formats match portal requirements
• GSTR-1, GSTR-3B, and 2B are consistent
• Export or SEZ documents are complete
• Unjust enrichment compliance is correct
• Bank details are correct and validated
• All declarations and undertakings are selected correctly
• Invoice-level mismatches are addressed through self-certified copies

Conclusion

GST refund filing is a compliance-heavy process. A refund claim succeeds when the application is supported with correct statements, proper documents, and complete declarations. A complete RFD-01 file prevents deficiency memos, reduces processing time and improves the chance of refund sanction without litigation.

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