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CSD GST Refunds

CSD GST Refunds: Rule 95B, RFD-10A and the 50% Invoice-Validation Working

CSD refund claims require qualifying goods, supplier-return checks and invoice-level duplicate controls. Reconcile the 50% ceiling separately for each applicable tax head.

Reviewed by CA Manoj Mittal · Chartered Accountant | 30+ years in GST & Indirect Taxation

Digital tax invoice and QR coded receipt printer

The claimant and qualifying goods matter before the percentage

The Canteen Stores Department under the Ministry of Defence has a specific refund framework for qualifying inward goods intended for subsequent supply to its Unit Run Canteens or authorised customers. Rule 95B and Circular 227/21/2024-GST provide the RFD-10A electronic process. This is not a general 50% refund for every defence purchaser, canteen operator, service invoice or retail customer. This guide checks the framework on 26 October 2026. ICAI April 2026 GST bare law: Rule 95B.

Use the current electronic route and the actual circular date

Notification 12/2024-Central Tax dated 10 July 2024 inserted Rule 95B and RFD-10A. The actual CBIC circular is dated 11 July 2024; a webpage listing date should not replace the signed document date. It supersedes Circular 60/34/2018 for the revised electronic process, while preserving manual processing for the older manual applications described in paragraph 8. Read the actual circular, rather than applying the earlier manual method to a new electronic claim.

Build an eligible invoice population

The goods must be received from registered suppliers against tax invoices, with the supplier GSTIN and the applicant CSD’s name and GSTIN. Verify that suppliers furnished the invoice details in GSTR-1 and furnished GSTR-3B for the concerned period. The circular describes validation against the applicant’s GSTR-2B and flags already-refunded invoices. An invoice present in the purchase ledger is therefore a starting point, not proof of claim eligibility. Keep goods-receipt and intended onward-supply evidence. Under paragraph 7.1 of the circular, the proper officer also checks that CSD has filed all GSTR-1 and GSTR-3B returns due on or before the refund application date.

Separate tax heads and prevent double benefit

The circular addresses central, integrated and Union territory tax under the identified notifications and discusses the respective tax-head limits in processing. State-tax entitlement must be grounded in the applicable State framework. The illustrations below deliberately calculate central tax only. Do not take half the purchase value or half a combined GST total and label it CGST. Verify reversal of ITC on the relevant inward goods as required by the circular’s processing checks, and do not claim a refund again for invoices already used.

Quarterly filing does not remove invoice-level time limits

Rule 95B refers to filing once every quarter. The circular permits applications for multiple quarters, including across financial years, but states a two-year window from the last day of the quarter in which the supply was received. Track each invoice’s received quarter before clubbing periods. File comfortably within the applicable limit; clubbing an older quarter with a newer one does not refresh the older quarter’s clock.

Close the claim against the validated ceiling

Attach the undertaking about receipt for qualifying onward supply and the declaration that no refund was previously claimed against the invoices. The circular describes a 50% auto-populated tax-head amount editable downwards, not upwards, and sanction through RFD-06 with a speaking order. Reconcile requested, sanctioned and paid amounts separately. A downward request does not create automatic entitlement to recover the balance later without examining the applicable rules and prior claim history.

Applicable primary references

ICAI April 2026 GST bare law: Rule 95B GST Council: Notification 12/2024-Central Tax, clause 18 CBIC Circular 227/21/2024-GST dated 11 July 2024

Six worked illustrations

All facts and amounts below are fictional. Assumptions describe the model, not additional statutory rules.

Illustrative example 1: Start with qualifying central tax

Assume supported eligible goods invoices contain CGST of ₹18,000, ₹12,000 and ₹10,000. Eligible CGST totals ₹40,000, so the 50% ceiling is ₹20,000. The purchase values themselves are not the refund base.

Illustrative example 2: Exclude a service invoice

A ledger has CGST ₹36,000 on qualifying received goods and ₹9,000 on services outside this goods-refund model. The relevant base is ₹36,000 and the ceiling ₹18,000. Taking half of the entire ₹45,000 would overstate this claim by ₹4,500.

Illustrative example 3: Avoid a previously refunded invoice

Candidate goods invoices have CGST ₹60,000, including ₹10,000 on an invoice already refunded. After removing that invoice, the remaining base is ₹50,000 and the 50% ceiling ₹25,000. Reusing all candidate invoices would overstate the claim by ₹5,000.

Illustrative example 4: Keep a supplier-return exception outside the validated working

Assume goods invoices show CGST ₹80,000, but invoices containing ₹20,000 cannot presently satisfy the supplier-return and validation checks. The currently supported base is ₹60,000 and its ceiling ₹30,000. Maintain the ₹20,000 exception separately; this does not extend its filing deadline or guarantee later eligibility.

Illustrative example 5: Reconcile a downward request

Validated eligible CGST is ₹1,00,000, giving a ₹50,000 ceiling. CSD requests ₹47,000 after a documented downward adjustment. The request is ₹3,000 below the ceiling. Do not increase the request above ₹50,000 or treat the unrequested ₹3,000 as already sanctioned.

Illustrative example 6: Combine quarters without losing the original bases

Assume three timely, non-overlapping quarters contain eligible CGST ₹24,000, ₹30,000 and ₹46,000. The respective 50% figures are ₹12,000, ₹15,000 and ₹23,000, totalling ₹50,000 on a ₹1,00,000 base. Preserve quarter-wise receipts and limitation checks even in a permitted combined application.

Ten-step verification table

StepActionEvidence
1Confirm claimant eligibilityCSD identity and the applicable section 55 notification framework.
2Identify received goodsReceipt documents and qualifying intended onward supplies.
3Check invoice particularsRegistered supplier, supplier GSTIN, and applicant CSD name and GSTIN.
4Verify supplier and CSD return complianceSupplier GSTR-1 details and GSTR-3B for the concerned period; CSD’s own GSTR-1 and GSTR-3B returns due on or before application.
5Match portal populationInvoice validation against GSTR-2B and unresolved mismatches.
6Remove duplicate claimsEarlier refund history at invoice level.
7Assign receipt quartersQuarter-end and two-year limitation working for each period.
8Calculate by tax headEligible tax, 50% ceiling and any downward revision.
9Complete application evidenceRFD-10A, undertaking, declaration and relevant ITC-reversal evidence.
10Reconcile sanction and receiptRFD-06, speaking order, sanctioned heads and actual payment.

Sixteen practitioner FAQs

1. Can an ordinary retailer claim this CSD refund?

No. The claimant and notified purpose are specific.

2. Does this model cover all service purchases?

No. Rule 95B concerns qualifying inward goods for the stated onward supplies.

3. What is the new electronic form?

FORM GST RFD-10A.

4. Which notification inserted Rule 95B?

Notification 12/2024-Central Tax dated 10 July 2024.

5. What is the date of Circular 227/21/2024-GST?

The actual circular is dated 11 July 2024.

6. Is half the invoice’s taxable value refundable?

No. Apply the percentage to eligible tax under the applicable framework.

7. Must supplier return compliance be checked?

Yes. Check supplier invoice reporting in GSTR-1 and furnishing of GSTR-3B for the relevant period. Processing also checks CSD’s own GSTR-1 and GSTR-3B returns due on or before the refund application date.

8. Does a purchase-ledger entry alone validate the claim?

No. Receipt, qualifying purpose, the supplier GSTIN, applicant CSD name and GSTIN on the invoice, and the required validation remain necessary.

9. Can an already-refunded invoice be used again?

No. Maintain invoice-level prior-claim controls.

10. Can quarters be clubbed?

The circular permits multiple quarters, including across financial years, subject to the applicable requirements.

11. Does clubbing renew an old quarter’s limitation period?

No. Preserve the original receipt-quarter clock.

12. What time limit does the circular explain?

Before expiry of two years from the last day of the quarter in which the supply was received.

13. Can the portal’s 50% amount be increased manually?

The circular describes downward editing, not enhancement above the auto-populated amount.

14. Does the CGST example establish SGST entitlement?

No. Verify the applicable State framework and maintain separate tax-head workings.

15. Why check ITC reversal?

The circular expressly includes verification of reversal for the relevant inward goods in claim processing.

16. What happens to qualifying older manual applications?

Paragraph 8 preserves manual processing under the earlier circular for the applications it describes.

Conclusion

CSD refund claims require qualifying goods, supplier-return checks and invoice-level duplicate controls. Reconcile the 50% ceiling separately for each applicable tax head.

Sources and primary references