The Goods and Services Tax Network (GSTN) has introduced a significant procedural shift in the GST refund filing mechanism. Effective May 18, 2026, taxpayers claiming refunds involving accumulated Input Tax Credit (ITC) can no longer upload Annexure-B in PDF format.
Going forward, the prescribed Excel-based Annexure-B Offline Utility has become the only permitted mode for submission.
This marks a decisive move by GSTN toward invoice-level validation, HSN-wise transparency, and automated reconciliation with GSTR-2B data.
Until now, many taxpayers were attaching Annexure-B as a PDF while filing refund applications. That option has now been permanently discontinued on the GST portal.
Under the revised process:
In practical terms, refund filing has shifted from a document-upload model to a structured data-validation model.
The revised Annexure-B procedure applies to refund claims filed under the following categories:
| Sl. No. | Refund Category |
|---|---|
| 1 | Export of goods or services without payment of tax (Accumulated ITC) |
| 2 | Supplies made to SEZ units or SEZ developers without payment of tax |
| 3 | Refund arising due to inverted duty structure under Section 54(3) of the CGST Act |
| 4 | Export of electricity without payment of tax |
Taxpayers filing refund claims under these categories must mandatorily adopt the Offline Utility mechanism.
One of the most impactful changes is the requirement for detailed HSN/SAC-wise reporting.
Every invoice uploaded through Annexure-B must now be classified separately under:
Where a single invoice contains multiple HSN/SAC codes or covers different categories, taxpayers must split the invoice into separate line items and proportionately allocate taxable values and tax amounts.
Practical Implication
Businesses that do not maintain HSN-wise purchase registers may face serious challenges during refund preparation.
The filing process now demands:
The era of summary-based refund preparation is effectively over.
GSTN has introduced strict duplication controls within the utility.
The system will reject any repeated combination of the following fields:
Only one unique combination is permitted.
Even accidental duplication will trigger a hard validation error, and there is no manual override available on the portal.
Taxpayers must ensure:
Data hygiene is now a critical compliance requirement.
Refund applicants must ensure that ITC reversals reported under:
match precisely with the figures disclosed in the corresponding GSTR-3B returns.
Approximation, estimation, or inconsistent reporting may lead to system mismatches and possible refund objections.
Important Rule for Multiple Utility Files
If multiple Annexure-B utility files are uploaded for one refund application:
Repeating reversal amounts across multiple files can create reconciliation discrepancies.
The uploaded invoices are now validated against GSTR-2B records.
However, the validation approach differs based on invoice periods.
| Invoice Period | Validation Treatment |
|---|---|
| November 2024 onwards | Strict validation against GSTR-2B |
| October 2024 or earlier | No automated system validation |
For invoices from November 2024 onward:
For older invoices:
GSTN has also prescribed technical upload limits for Annexure-B submissions.
| Parameter | Limit |
|---|---|
| Maximum line items per utility file | 10,000 |
| Maximum utility files per refund application | 25 |
| Total line items allowed per application | 2,50,000 |
Invoices exceeding these limits may be furnished separately as supporting PDF documents.
Large taxpayers must therefore strategically divide invoice data across multiple utility files before upload.
Taxpayers should carefully review the following before generating the JSON file:
1. Avoid Spaces in Data Fields
Leading or trailing spaces can trigger validation failures.
2. Use the Latest Utility Version
Always close earlier versions before opening a newly downloaded utility.
3. Never Edit the JSON File Manually
Corrections must be made only within the utility, followed by fresh JSON generation.
4. Verify Consolidated ITC Summary
Cross-check invoice totals, tax values, and ITC summaries before final upload.
5. Follow Dropdown Values Strictly
Only prescribed dropdown values are accepted by the system.
6. Read the “Read Me” Instructions Carefully
Particular attention should be given to Point 6 in the utility documentation.
Before filing the next GST refund application, taxpayers and consultants should complete the following steps:
GSTN is gradually creating a fully traceable refund ecosystem where every refund claim is linked to:
This significantly reduces the scope for generalized or unsupported refund claims.
While the compliance burden has increased initially, the long-term objective appears clear:
Businesses and tax professionals who adapt early by strengthening their reconciliation and documentation systems will likely experience smoother refund processing and fewer disputes.
The mandatory Annexure-B Offline Utility is not merely a procedural update — it represents a structural shift in GST refund compliance.
Going forward, refund filing will depend heavily on:
Taxpayers who continue relying on fragmented purchase records or manual compilations may face delays, validation failures, and working capital blockages.
In the current business environment, delayed refunds directly impact liquidity. Early preparation and disciplined compliance will therefore become essential for efficient refund management.
GSTN has indicated that a detailed user manual containing portal screenshots and step-by-step guidance for the Annexure-B Offline Utility will be released shortly.
Taxpayers and practitioners should closely monitor the official GST portal for further updates before filing upcoming refund claims under the revised mechanism.
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