Date: June 10, 2025
Issued by: Goods and Services Tax Network (GSTN)
Introduction
To improve compliance and ensure adherence to refund-related legal provisions, the GST Portal has been updated with system-level validations for refund applications. This change aligns with Para 6 of Circular No. 125/44/2019-GST dated 18.11.2019, which mandates that refund claims be filed only after the relevant GST returns have been submitted.
While the validation aims to streamline processing and avoid incomplete filings, taxpayers under the Quarterly Return Monthly Payment (QRMP) Scheme encountered technical difficulties post-deployment in May 2025.
This article outlines the issue, the corrective action taken, and current filing guidelines.
Background: Legal Provision Under Circular No. 125/44/2019-GST
As per Para 6 of the said circular:
“Any refund claim for a tax period may be filed only after furnishing all the returns in FORM GSTR-1 and FORM GSTR-3B which were due to be furnished on or before the date on which the refund application is being filed. However, in the case of composition taxpayers, non-resident taxable persons, or Input Service Distributors (ISDs), the requirement changes to filing FORM GSTR-4 (with CMP-08), GSTR-5, or GSTR-6, respectively.”
System Update on GST Portal – May 2025
To ensure the above provision is enforced effectively:
- A system-level validation was deployed in May 2025.
- The portal now checks if all relevant returns (GSTR-1 and GSTR-3B) have been furnished up to the date of refund application submission.
- Refund filing is blocked if returns are missing or pending.
Issues Faced by QRMP Taxpayers
After implementation, QRMP taxpayers encountered the following problems:
- Invoice Furnishing Facility (IFF) Not Recognized
The system failed to recognize invoices submitted through IFF for the first two months (M1 and M2) of a quarter. As a result, taxpayers were unable to file refunds even if returns were correctly furnished via IFF. - Incorrect System Prompting
In cases where GSTR-1 for the previous quarter had already been filed, the portal was erroneously asking taxpayers to file GSTR-1 for M1 and M2 of the new quarter, even when the period was not yet due.
This particularly impacted refund filings made during the transition between two quarters.
Resolution of Technical Issues
GSTN has now resolved the aforementioned technical glitches. The updated system:
- Correctly recognizes invoices filed via IFF for M1 and M2.
- Does not demand premature return filing for months where the return is not yet due.
✅ Current Rule for QRMP Refund Filing
Taxpayers under the QRMP scheme can file refund applications only for invoices where GSTR-3B has already been filed.
Invoices reported in IFF but pending GSTR-3B filing must not be included in the refund application.
Compliance Reminder for Taxpayers
- Refund applications must strictly follow filing sequence:
- First, ensure all relevant GSTR-1 and GSTR-3B are submitted.
- Only then initiate the refund application.
- For QRMP taxpayers:
- IFF invoices can only be claimed after GSTR-3B is filed.
- Refunds cannot be processed if return cycle is incomplete.
Support and Assistance
If taxpayers continue to face any challenges or system errors:
🔧 Contact GST Helpdesk:
👉 https://selfservice.gstsystem.in
Raise a ticket with:
- GSTIN
- Relevant screenshots
- Filing period and refund type
- Description of the issue
Conclusion
This validation measure ensures that refund claims are filed only when all due compliances are met, reducing errors and processing delays. QRMP taxpayers must stay informed of these changes to avoid filing obstacles.
Timely filing of returns and proper understanding of refund eligibility are essential to benefit from the GST framework efficiently.
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