Government of India Ministry of Finance Department of Revenue
(Central Board of Excise & Customs)
Circular No. 05/2018-Customs
Room No. 227B, North Block, New Delhi. Dated the 23rd February, 2018
To
All Principal Chief Commissioners/Chief Commissioners of
Customs/Customs(Preventive) All Principal Chief Commissioners/Chief
Commissioners of Central Tax and Central Excise All Principal
Commissioners/Commissioners of Customs/Customs (Preventive) All Principal
Commissioners/Commissioners of Central Tax and Central Excise
Madam/ Sir
Subject: Refund of IGST on Export– Invoice mis-match Cases –Alternative
Mechanism with Officer Interface - reg
1. Numerous representations have been received from exporters / trade
associations seeking resolution of various problems which have hindered the
sanction of refund of IGST paid on exports. CBEC has issued Circular No 42 /
2017 dated 07-11-2017 which highlighted the common errors that hindered the
sanction and disbursal of refund of IGST paid against exports. Subsequent to the
said Circular, outreach programmes have been undertaken and advisories,
advertisements and FAQs have been issued to create awareness amongst the
exporter community regarding the common mistakes and errors which hold up the
refund process. Information is being made available to exporters on a real-time
basis with regard to the errors status on ICEGATE website for registered users.
Details of refund sanctioned is being sent through SMS on registered mobile
phones. A positive gain of these efforts has been that errors are steadily
decreasing, which has enabled CBEC to sanction more than Rs. 4000 crores of
refund, so far. The matter is being closely coordinated with GSTN, which has
also been tasked to provide feedback to the exporter about any failed
validations to enable corrective action on their part.
2. The analysis of data post October 2017 indicates that while the quantum of
errors is decreasing significantly, exporters are still committing mistakes in
the information furnished to (i) GSTN while filing GSTR 1 / Table 6A or GSTR 3B
and (ii) Customs EDI system while filing Shipping Bill. The pre-requisites and
precautions that need to be taken for successful processing of refund claims are
as follows:
(i) Exporters have to file GSTR 3B with taxable value for export and IGST
paid against exports indicated in appropriate fields
(ii) Exporters have to file GSTR 1 or Table 6A for the exports made with
correct details such as Invoice number, Taxable value, IGST paid, Shipping Bill
number, Shipping Date and Port Code. Large number of exporters have filed
incomplete GSTR 1 or Table 6A where shipping bill number or date or port code
are missing. These records are not processed / forwarded to Customs by GSTN.
E-mails have been sent to exporters asking them to correct their records through
amendment process of GSTR 1 i.e through Table 9 of GSTR 1 of the following month
(iii) The aggregate IGST paid amount claimed in GSTR 1 or Table 6A should not
be greater than the IGST paid amount indicated in Table 3.1(b) of GSTR 3B of the
corresponding month. This check is put in the GSTN system to ensure that the
refund claimed is not more than the IGST paid by the exporter. Analysis of GSTN
return data indicates that this condition has failed in a large number of cases,
consequently, the information filed by exporters is not forwarded to Customs by
GSTN. In these cases also, e-mails have been sent to exporters asking them to
correct their records through amendment process of GSTR 1 i.e. through Table 9
of GSTR 1 of the following month.
(iv) The analysis of data further indicates that only about 32% records of
GSTR 1 / Table 6A have been transmitted from GSTN to Customs. In other words, a
majority of refund claims are held up either due to insufficient information or
lack of due diligence on the part of exporter while filing GST returns.
(v) Exporters may be advised to use Table 9 of GSTR 1 of the following month
to amend the records of previous month so as to take care of issues mentioned in
paras (ii) and (iii) above. In cases where exporters have already filed
information through Table 9 of GSTR 1, the said information is being validated
by GSTN. The validated information is expected to be forwarded by GSTN to
Customs by mid-March 2018 for further processing.
(vi) The records (i.e GSTR 1 or Table 6A) which have been forwarded by GSTN
to Customs after validations mentioned at (ii) and (iii) above are processed by
the Customs EDI system. In cases where the information forwarded by GSTN tallies
with the information furnished in Shipping bills, refunds are automatically
sanctioned by Customs EDI system. As mentioned earlier, till date about Rs. 4000
Crore has been sanctioned as refund of IGST paid.
(vii) However, there are many instances where refunds are held up on Customs
EDI system due to certain errors which have been clearly brought out in the
Circular No 42/2017- Customs. The major errors that are committed by the
exporters are (a) incorrect Shipping bill numbers in GSTR 1 (b) GSTIN declared
in the shipping bill does not match with the GSTIN used to file the
corresponding GST Returns (c) the most common error hampering refund is due to
mismatch of invoice number, taxable value and IGST paid in the Shipping Bill
vis-à-vis the same details mentioned in GSTR 1 / Table 6A which is the most
common error hampering refund. Another reason attributable to carriers is the
non-filing or incorrect filing of electronic Export General Manifest (EGM).
(viii) Exporters may be advised to track the refund status and errors
pertaining to their shipping bills on the ICEGATE website. The registration
process demo, advisory and the needed IT configurations are hosted on the
ICEGATE website under the following links
Registration Demo link:
https://www.icegate.gov.in/download/new_registration_demo_updated_approved.pdf
Registration Advisory link:
https://www.icegate.gov.in/Download/v1.2_Advisory_Registration_APPROVED.pdf
Java set up for the DSC upload:
https://www.icegate.gov.in/Download/JavaSetupForDSC.pdf
Once the registration is obtained, the exporters can check the status of IGST
refunds associated with their exports and the corresponding error message, if
any. This enquiry takes GSTIN Number, Port-code and Return Month as inputs and
based on the input, Shipping Bill Number, Shipping Bill Date, Return Month,
Invoice Number, Invoice Date, Response Code and Processed date is displayed as a
result of the enquiry. The records displayed are those that have been received
from GSTN and processed by the Customs Automated System
(ix) The analysis of Customs data indicates that while most of the errors
mentioned in para (vi) above are decreasing, the error mentioned at (c) in para
(vii) is most prevalent. The error mentioned at (c) in para (vii) is about
invoice mis-match. This error is because of the fact that exporters are using
two sets of invoices, one invoice for GST and another invoice for Customs which
is resulting in mismatch of invoice numbers, including mis-match in taxable
value and IGST paid in those invoices. It is once again reiterated that
exporters may be advised to take due care to ensure that the details of invoice
such as invoice number, taxable value and IGST paid mentioned in GSTR 1 and
shipping bill match with each other and the invoice issued is compliant with the
GST Invoice Rules, 2017.
3. Recognizing that invoice mis-match has been the major reason why the
refunds have been held, it has been decided to provide an alternative mechanism
to give exporters an opportunity to rectify such errors committed in the initial
stages. This envisages an officer interface on the Customs EDI System through
which a Customs officer can verify the information furnished in GSTN and Customs
EDI system and sanction refund in those cases where invoice details provided in
GSTR 1/ Table 6A are correct though the said details provided in the shipping
bill were at variance. It is pertinent to note that refund claims would be
processed in only those cases where the error code is mentioned as SB005.
Further, it may also be noted that all refunds shall continue to be credited
electronically through the PFMS system, and no manual payment / cheque should be
issued. The procedure for processing of IGST refund claims in these cases would
be as follows:
a. The exporter shall provide a concordance table indicating mapping between
GST invoices and corresponding Shipping Bill invoices, as annexed in support of
the refund claim to the designated officer in the Custom house. A scanned copy
of concordance table may also be sent to dedicated email address of Customs
location from where exports took place.
b. Customs EDI system shall display list of all the invoices pertaining to
such SBs vis-a-vis the invoice data received from GSTN. The officer shall verify
the following:
i. Duly certified concordance table submitted by the exporter as per Annexure
A indicating mapping between GST invoice and corresponding Shipping Bill
invoice; ii. IGST taxable value and IGST amount declared in the Shipping
Bill. iii. IGST details declared in the Shipping Bill should be in proportion
to the goods actually exported.
c. After determining the correct refund amount, the officer need to enter the
same into the Customs EDI system. The officer has the facility to edit the IGST
paid details in case of short shipment or incorrect calculation by the exporter.
The officer shall complete the verification by accepting or rejecting or
amending the same.
d. Once all the invoices pertaining to Shipping Bill are verified by the
officer, the system shall calculate the scroll amount against a shipping bill,
after subtracting the drawback amount for each invoice where applicable, and
display the refund amount to the officer for approval.
e. Invoices in any particular GSTR 1 where refund is sanctioned shall be
disabled in the system to prevent refund against same invoice in future.
f. Once refund is sanctioned by the officer, the shipping bills would be
available for generating scroll as per normal process.
4. In order to ensure smooth operation of the prescribed procedure, Custom
Houses may open a dedicated cell and e-mail address for the purpose of IGST
refund and give wide publicity.
5. This procedure is available only for Shipping Bills filed till 31st
December 2017. All Chief Commissioners are requested to issue Public Notice and
Standing Orders, in this regard. Difficulties, if any, may be brought to the
notice of the Board. It is again emphasized that Board is taking all possible
steps to alleviate the difficulties associated with IGST refunds. However,
ultimately it is the responsibility of the exporters to ensure careful and
correct filing of returns for hassle free sanction of IGST refunds.
6. Hindi version will follow.
Yours faithfully, (Zubair Riaz) Director (Customs)
F.No.450/119/2017-Cus.IV
Annexure A
The Concordance between GST Invoice and Export Invoice declared in Shipping
Bill is as follows:
Name of the Exporter: -
GSTIN:-
Port Code : |
|
SB No |
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SB Date: |
|
Concordance Table
SI No. |
GST Invoice No / Date |
Taxable Value as per GST |
IGST Amount as per GST |
SI No. |
Corresponding SB Invoice No. /Date |
Taxable Value as per SB |
IGST Amount as declared per SB |
Final (corrected) IGST Amount as per actual exports* |
1 |
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1 |
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2 |
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3 |
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4 |
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2 |
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5 |
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3 |
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* after reducing amount pertaining to Short shipment etc.
I declare that all the details declared here are true to my knowledge and all
items contained in the invoices have been exported out of India.
I further declare that all the GST invoices pertaining to this Shipping Bill
have been filed as part of GSTR1/ 6A in Common portal and is available for
verification and refund
Place: Date
Authorised Signatory
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