In the Circular No. 125/44/2019, it has been clarified that the refund shall be granted even for those invoices which are not being reflected in the GSTR 2A. Thus, a taxpayer can file the refund application by uploading the missing invoices in the refund application in order to claim the refund. On 31st March 2020, a circular no. 135/05/2020 has been issued where it has been clarified that the refund shall be granted only for those invoices which are being reflected in the GSTR 2A.
However, representations have been received that the Refund sanctioning authorities have been rejecting the refund of acculumated ITC in respect of ITC availed on Imports, ISD invoices, RCM, etc. citing the circular no. 135/05/2020 that the refund shall be sanctioned on account of invoices which are being reflected in GSTR2A.
Thus, in the circular no. 139/09/2020 dated 10th June 2020, it has been clarified that the refund on account of accumulated ITC in respect of ITC availed on imports, ISD invoices, RCM,etc. shall continue to be processed in the manner as it has been processed before the issuance of the circular no. 135/05/2020.
To view and download the circular, click here Circular_Refund_139_9_2020
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