GST Refund Claims Enter a New Era of Invoice-Level Validation :Annexure-B Now Mandatory in JSON Format

The GST Portal has recently introduced an important procedural change for taxpayers filing refund claims of unutilised Input Tax Credit (ITC) under FORM GST RFD-01. As per the updated refund filing utility, Annexure-B is now required to be prepared using the prescribed offline utility and uploaded in JSON format.

While Annexure-B was already being used as part of the refund documentation process pursuant to Circular No. 135/05/2020-GST dated 31.03.2020, the latest system update significantly expands the level of invoice-wise reporting and system validation required from taxpayers.

The revised mechanism reflects a clear shift from document-based verification towards technology-driven, reconciliation-based validation of refund claims. This change is expected to impact exporters, SEZ suppliers, inverted duty refund claimants and all taxpayers seeking refund of accumulated ITC.

Earlier, taxpayers filing refund claims for accumulated ITC were generally required to furnish invoice-wise details of inward supplies through Annexure-B. The format prescribed under Circular No. 135/05/2020-GST dated 31.03.2020 was relatively simpler and primarily focused on basic invoice particulars.

Subsequently, Circular No. 170/02/2022-GST dated 06.07.2022 further strengthened the concept of invoice-level verification and linkage with GSTR-2B for refund processing.

Over the last few years, the GST ecosystem has progressively moved toward auto-population of ITC data, GSTR-2B-based validation, system-driven scrutiny, risk-based verification and minimisation of manual intervention by tax authorities.

In continuation of this digital transformation, the GST Portal has now operationalised a revised Annexure-B utility requiring taxpayers to generate and upload invoice data in JSON format through the offline utility.

The substantive legal framework governing refund claims continues to be prescribed under Section 54 of the CGST Act, 2017 and Rule 89 of the CGST Rules, 2017.

Under the updated utility, Annexure-B can no longer be uploaded merely as a simple invoice statement. Instead, taxpayers are now required to prepare the annexure using the GST offline utility and generate a JSON file for upload.

More importantly, the revised utility now seeks several additional invoice-level particulars beyond the earlier Annexure-B format, including:

• Type of inward supply

• Type of document

• Total ITC involved in the invoice

• ITC blocked under Section 17(5)

• Eligible ITC

• Ineligible ITC

• GSTR-2B return period and

This clearly indicates that the GST Portal is now moving toward system-based validation of refund invoices with GSTR-2B and other return data.

The revised process broadly requires taxpayers to:

• Download the updated offline utility

• Enter invoice-wise ITC details

• Validate the data

• Generate JSON file; and

• Upload the JSON file along with refund application in FORM GST RFD-01.

 Key Differences between the Earlier and Revised System

Additional Features Introduced Under the New Utility

The revised Annexure-B utility introduces several additional compliance and technological features compared to the earlier system:

(a) Invoice-Level System Validation

The portal can now validate refund invoices directly with GSTR-2B data, thereby improving accuracy of refund claims.

(b) Classification of ITC

The utility separately captures total ITC, eligible ITC, blocked ITC under Section 17(5), and ineligible ITC.

(c) GSTR-2B Period Mapping

Taxpayers are now required to identify the relevant GSTR-2B return period against each invoice, strengthening system reconciliation.

(d) Reduction in Manual Scrutiny

The updated structure may reduce dependency on manual officer verification and facilitate automated processing.

(e) Enhanced Risk Identification

The system can identify duplicate invoices, excess ITC claims, mismatches with GSTR-2B, incorrect ITC eligibility claims, and abnormal refund patterns.

(f) Structured Data Analytics

JSON-based filing creates a standardised digital architecture enabling improved analytics and faster processing.

The revised Annexure-B mechanism marks a significant shift in GST refund processing from a document-based approach to a reconciliation-driven digital compliance framework. Refund applicants can no longer treat Annexure-B as a simple invoice annexure. It is now evolving into a comprehensive invoice mapping and ITC validation exercise where each invoice may effectively require linkage between books of accounts, GSTR-2B, ITC eligibility, blocked or ineligible credits, reversals and the final refund claim amount.

While the update is expected to improve transparency, invoice-level verification and automated scrutiny, it will also substantially increase the reconciliation and documentation responsibilities of taxpayers.

Reference: Circular No. 135/05/2020-GST dated 31.03.2020; Circular No. 170/02/2022-GST dated 06.07.2022; Section 54 of the CGST Act, 2017; Rule 89 of the CGST Rules, 2017.

135/05/2020-GST: https://cbic-gst.gov.in/pdf/Circular_Refund_135_5_2020.pdf

170/02/2022-GST: https://cbic-gst.gov.in/pdf/Circular-170-02-2022-GST.pdf

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