Start from the original paid-tax export and the later increase
Rule 89(1B) provides a separate refund application for additional IGST paid on a post-export increase in the price of goods when the original export IGST refund has already been sanctioned under Rule 96. The proviso to Rule 96(1) refers to original tax already refunded under Rule 96(3). Verify the original refund evidence before proceeding. File the incremental claim in FORM GST RFD-01, subject to Rule 10B. The jurisdictional GST officer handles this claim; the original shipping-bill workflow does not by itself submit it.
Read the applicable text: ICAI statutory compendium: CGST Act section 54 and Rules 89 and 96 CBIC Circular 226/20/2024-GST: incremental export tax refund Finance Act, 2026: section 155 CBIC Notification 03/2026–Central Tax: commencement (notification copy).
Build the bridge before preparing Statements 9A and 9B
Link the original invoice and shipping bill or bill of export to the original refund, the price-revision clause or agreement, supplementary invoice or debit note, return declarations, additional IGST payment and applicable interest. Rule 89(2)(bb) requires the number, date and a copy of the additional foreign inward remittance certificate issued by an Authorised Dealer-I bank. Include the certificate from a practising chartered accountant or cost accountant linking that remittance to the price revision. Include the prescribed original BRC or FIRC evidence. Under Rule 89(2)(bc), reconcile values in the supplementary invoices, debit notes or credit notes with the relevant bank evidence. Circular 226/20/2024-GST identifies Statements 9A and 9B. Check the current portal category; the circular’s Any other route was an interim instruction until a dedicated category became available.
Keep additional tax, interest and original refunds apart
The refund route addresses the additional IGST, while the payment file evidences tax and applicable interest. Do not claim the original refunded amount again or add interest to the incremental tax claim. Match relevant GSTR-1 declarations and GSTR-3B payment details, as described in the circular. If an increase was only partially paid or remittance cannot yet be matched, isolate the unsupported amounts and resolve them before certifying the claim. A downward revision raises its own repayment question under paragraph 9 of the circular; do not hide it by netting unrelated documents into the upward claim.
Use the export relevant date for limitation
Rule 89(1B) refers to two years from the relevant date under section 54, Explanation (2)(a), For a relevant date before the rule came into force, the proviso instead measures the two years from its commencement on 10 July 2024, subject to any legally applicable relief. For goods exported by sea or air, identify when the ship or aircraft leaves India; for land, when the goods pass the frontier; for post, when the post office dispatches them outside India. The date of the later debit note or bank receipt does not ordinarily restart this clock. From 1 November 2026, the amended section 54(14) excludes refund of tax claimed on account of goods exported with payment of tax from that subsection’s bar on payment of refunds below ₹1,000. Section 155(b) of the Finance Act, 2026 and Notification 03/2026–Central Tax, S.O. 5791(E), dated 26 October 2026, govern this change. Paragraph 4 of the 2024 circular reflects the earlier law. Check the operative law on transition facts and all other eligibility requirements; the threshold change does not extend Rule 89(1B) limitation.
Six worked illustrations
All facts and amounts are fictional. Calculations illustrate the stated assumptions, not a predetermined legal outcome.
Illustrative example 1: Reconcile original and additional tax
Original export IGST of ₹1,20,000 was refunded. Additional IGST of ₹18,000 is paid on the supported price increase. The total tax trail is ₹1,38,000, of which this route examines only the ₹18,000 increment.
Illustrative example 2: Separate interest from principal
An exporter has ₹24,000 additional IGST and ₹1,200 applicable interest established on its facts. The payment trail totals ₹25,200; the incremental tax refund working is ₹24,000, subject to eligibility.
Illustrative example 3: Two remittances against one debit note
A price revision of 12,000 foreign currency units is supported by additional bank remittances of 7,000 and 5,000 units. The two equal the revision and the unreconciled foreign currency amount is zero, before any separate exchange-rate bridge.
Illustrative example 4: Bank amount covers more than one purpose
A bank certificate is for 20,000 foreign currency units. The evidence allocates 13,000 to the original export balance and 7,000 to the upward revision. Only 35% of that bank amount is attributable to the revision on these facts; trace both portions before certification.
Illustrative example 5: Limitations follow the export date
Goods leave India by sea on 8 December 2025. A debit note is raised on 15 July 2026. The two-year anniversary of the relevant date is 8 December 2027, not 15 July 2028. The rule requires filing before expiry; plan a buffer.
Illustrative example 6: Payment and support gap
The debit-note tax working is ₹34,000, but payment evidence supports only ₹29,000 of additional IGST. The ₹5,000 difference remains unresolved. The ₹29,000 is a payment tie-out, not a conclusion that this amount is refundable.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Confirm the paid-tax export | Original invoice and shipping bill or bill of export. |
| 2 | Verify the original refund | Rule 96(3) sanction and refund evidence. |
| 3 | Prove the contractual revision | Agreement, calculation and price-revision approval. |
| 4 | Match the supplementary document | Debit note or supplementary invoice to original invoice. |
| 5 | Check return disclosures | Relevant GSTR-1 and GSTR-3B records. |
| 6 | Separate tax and interest | Amounts, payment proof and ledger bridge. |
| 7 | Trace bank remittances | Original and additional receipts with prescribed certificates. |
| 8 | Complete statements and certification | Statements 9A and 9B and practising CA or cost accountant certificate. |
| 9 | Verify date and eligibility | Section 54 relevant date, Rule 10B and applicable statutory conditions. |
| 10 | Reconcile the filed claim | RFD-01 acknowledgement, sanctioned amount and outstanding differences. |
Sixteen practitioner FAQs
1. Is this a second claim for the original IGST?
No. It concerns the additional IGST attributable to a qualifying later price increase.
2. Does the route apply to export services?
Rule 89(1B) concerns goods.
3. Does it apply to an original LUT export with no original paid-tax refund?
The route requires the original Rule 96 refund history specified in the rules.
4. Which authority processes the additional claim?
The jurisdictional GST officer under the circular’s procedure.
5. Does Customs process the second claim merely because the original shipping bill remains valid?
No. Prepare the separate RFD-01 application.
6. Which two statements are relevant?
Statements 9A and 9B identified by Circular 226/20/2024-GST.
7. Can the certificate be issued without tracing the bank receipt?
The certification connects the additional foreign exchange remittance to the post-export increase.
8. What if remittance covers multiple export invoices?
Allocate by evidence and reconcile the allocation to the relevant invoice and revision.
9. Can interest be added to the refund claim?
This mechanism refunds additional integrated tax; keep interest evidence separate.
10. Does the debit-note date restart the two years?
The rule instead refers to the statutory relevant date for the export.
11. Is the circular’s Any other category a permanent requirement?
No. It is framed as an interim route pending a dedicated category.
12. Should I use a shipping bill filing date as the relevant date for sea exports?
Use the statutory departure event under section 54, Explanation (2)(a).
13. Does a downward revision belong in the same incremental claim?
Assess the excess original refund and related treatment separately.
14. What if the original refund is still pending?
Resolve the original refund condition and monitor limitation before attempting this route.
15. Can I copy the original refund amount into the incremental claim?
No. Reconcile the original, the revised total and the additional tax separately.
16. What is the most useful cross-check for the officer’s queries?
A transaction-level bridge connecting the export, revision, returns, tax payment, refund history and remittance.
Official sources
ICAI statutory compendium: CGST Act section 54 and Rules 89 and 96 CBIC Circular 226/20/2024-GST: incremental export tax refund Finance Act, 2026: section 155 CBIC Notification 03/2026–Central Tax: commencement (notification copy); Published Gazette: S.O. 5791(E), Notification 03/2026–Central Tax