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Dear Members,
As you are aware, IGST refunds in many cases have been delayed due to matching errors and limitations on corrective action to be taken.
The major errors that are committed by the exporters are-
(a) incorrect Shipping bill numbers in GSTR 1
(b) GSTIN declared in the shipping bill does not match with the GSTIN used to file the corresponding GST Returns
(c) the most common error hampering refund is due to mismatch of invoice number, taxable value and IGST paid in the Shipping Bill vis-à-vis the same details mentioned in GSTR 1 / Table 6A which is the most common error hampering refund.
(d) Another reason attributable to carriers is the non-filing or incorrect filing of electronic Export General Manifest (EGM).
In this regard CBEC has issued circular no Circular No. 05/2018-Customs dated 23/02/2018 with alternative mechanism to rectify various errors including the most common error (SBS005).
Alternative Mechanism for rectification of Invoice Mis-match error (SBS005)
Recognizing that invoice mis-match has been the major reason why the refunds have been held, it has been decided to provide an alternative mechanism to give exporters an opportunity to rectify such errors committed in the initial stages.
This envisages an officer interface on the Customs EDI System through which a Customs officer can verify the information furnished in GSTN and Customs EDI system and sanction refund in those cases where invoice details provided in GSTR 1/ Table 6A are correct though the said details provided in the shipping bill were at variance.
It is pertinent to note that refund claims would be processed in only those cases where the error code is mentioned as SB005. Further, it may also be noted that all refunds shall continue to be credited electronically through the PFMS system, and no manual payment / cheque should be issued. The procedure for processing of IGST refund claims in these cases would be as follows:
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The exporter shall provide a concordance table indicating mapping between GST invoices and corresponding Shipping Bill invoices, as annexed in support of the refund claim to the designated officer in the Custom house. A scanned copy of concordance table may also be sent to dedicated email address of Customs location from where exports took place. The format of concordance table is annexed with this circular.
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Customs EDI system shall display list of all the invoices pertaining to such SBs vis-a-vis the invoice data received from GSTN. The officer shall verify the following:
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i. Duly certified concordance table submitted by the exporter as per Annexure A indicating mapping between GST invoice and corresponding Shipping Bill invoice;
ii. IGST taxable value and IGST amount declared in the Shipping Bill.
iii. IGST details declared in the Shipping Bill should be in proportion to the goods actually exported.
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After determining the correct refund amount, the officer need to enter the same into the Customs EDI system. The officer has the facility to edit the IGST paid details in case of short shipment or incorrect calculation by the exporter. The officer shall complete the verification by accepting or rejecting or amending the same.
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Once all the invoices pertaining to Shipping Bill are verified by the officer, the system shall calculate the scroll amount against a shipping bill, after subtracting the drawback amount for each invoice where applicable, and display the refund amount to the officer for approval.
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Invoices in any particular GSTR 1 where refund is sanctioned shall be disabled in the system to prevent refund against same invoice in future.
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Once refund is sanctioned by the officer, the shipping bills would be available for generating scroll as per normal process.
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This procedure is available only for Shipping Bills filed till 31st December 2017.
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All Chief Commissioners are requested to issue Public Notice and Standing Orders, in this regard.
Members are requested to take note of the same and do the needful through your relevant Port/ customs house, if your refunds are stuck due to Invoice mismatch error. The original circular no Circular No. 05/2018-Customs dated 23/02/2018 is available for download using below link-
http://www.cbec.gov.in/resources//htdocs-cbec/customs/cs-circulars/cs-circulars-2018/circ05-2018cs.pdf;jsessionid=4354E3AF1AAA006EEE337B833BA26A03
Issues if any may be highlighted to the council on ed@chemexcil.gov.in & deepak.gupta@chemexcil.gov.in .
Thanking You,
Yours faithfully,
(S.G. BHARADI)
Executive Director
CHEMEXCIL
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