GST Advisory on New Offline Utility for Annexure-B for Filing GST Refunds

19May 2026 by admin

GST Advisory on New Offline Utility for Annexure-B for Filing GST Refunds

Date: 18th May, 2026

1. Background

The Goods and Services Tax Network (GSTN) has, vide its advisory dated 18th May, 2026, introduced a significant procedural change in the manner of filing refund applications involving accumulated Input Tax Credit (ITC). Hitherto, taxpayers were required to upload Annexure-B in PDF format along with the refund application in Form RFD-01 as per the extant guidelines. With the objective of automating the refund filing process and enabling system-based verification of invoices and supporting documents, GSTN has now deployed a standardized Annexure-B Offline Utility on the common portal.

Consequently, going forward, taxpayers shall be required to furnish Annexure-B exclusively through this prescribed offline utility, thereby replacing the existing practice of uploading PDF statements. This advisory captures the salient features of the new utility and the precautions to be observed by taxpayers while filing refund applications under the prescribed categories.

2. Refund Categories Covered

The mandatory use of the Annexure-B Offline Utility shall apply in respect of the following refund categories where refund is claimed on account of accumulated ITC:

  • Exports of Goods or Services made without payment of tax (claim of accumulated ITC), excluding electricity;
  • Supplies made to Special Economic Zone (SEZ) Unit or SEZ Developer without payment of tax;
  • ITC accumulated on account of Inverted Tax Structure, in terms of clause (ii) of the first proviso to Section 54(3) of the CGST Act, 2017;
  • Export of Electricity made without payment of tax (claim of accumulated ITC).

3. Salient Features of the Offline Utility

The offline utility has been made available in Microsoft Excel format and enables taxpayers to enter invoice-wise details of inward supplies in respect of which refund is being claimed. The principal features of the utility are summarised hereunder:

  • Invoice-wise reporting: All details are required to be furnished invoice-wise, on an HSN/SAC-wise basis.
  • Categorisation of input supplies: Invoices must be segregated into separate line items based on distinct HSN/SAC codes and the category of input supply, viz., Inputs, Input Services or Capital Goods, as the case may be.
  • Mapping of values: All other columns of the utility (taxable value, tax components, and indication of whether the ITC is blocked under Section 17(5) of the CGST Act or otherwise) must be filled specifically with reference to the HSN/SAC code and category of input supply reported in that line item.
  • Entry limit per file: A maximum of 10,000 line entries are permitted in a single offline utility file. Where the number of entries exceeds this threshold, taxpayers must use multiple utility files.

4. Structure of the Utility

The Annexure-B Offline Utility is structured into two tables, which must be filled by the taxpayer as follows:

  • Table 1 – Reversal Details: Capturing details of ITC reversals made by the taxpayer.
  • Table 2 – HSN/SAC-wise Inward Invoice Details: Capturing invoice-wise details of inward supplies in respect of which ITC has been claimed in the corresponding GSTR-3B and for which refund is being claimed.

5. Treatment of Invoices with Multiple HSN/SAC or Categories

Where a single tax invoice contains multiple categories of input supplies (such as Inputs, Input Services and Capital Goods) and/or multiple HSN/SAC codes, taxpayers shall observe the following discipline:

  • The invoice must be split into separate line items in the offline utility;
  • Each line item shall represent only one category of input supply mapped to one HSN/SAC code;
  • The invoice value and tax amounts must be proportionately distributed across such line items.

Note: A specific note in this regard has been incorporated in the Read Me section (Point 6) of the utility, which must be perused before commencing data entry to avoid validation errors.

6. Duplicate Document Validation

The utility shall apply validation against duplication of entries. The validation is applied separately for each type of inward supply and each document type, based on the following parameters:

  • Supplier GSTIN;
  • Invoice Number;
  • Invoice Date;
  • Category of Input Supply;
  • HSN/SAC Code.

Where, in respect of the same invoice, the category of input supply and HSN/SAC are identical, only one line item is to be reported. Multiple entries with identical parameters shall not be accepted by the utility.

7. Reporting of ITC Reversals

Taxpayers are required to correctly report ITC reversals in the utility, in the following manner:

  • Reversals effected under Rules 38, 42, 43 of the CGST Rules, 2017 and Section 17(5) of the CGST Act shall be reported as per the corresponding month’s GSTR-3B;
  • Other ITC reversals reflected in Table 4(B)(2) of GSTR-3B shall also be reported accordingly;
  • Where multiple offline utility files are used for a single refund application, reversal amounts shall be entered only in the final utility file. All preceding utility files shall reflect reversal amounts as zero.

Upon upload of all the JSON files, the system shall recalculate the consolidated Net ITC. Taxpayers are advised to scrutinise the consolidated summary carefully before final submission of the refund application.

8. Uploading of the JSON File

Upon successful generation of the Annexure-B JSON file from the offline utility, the taxpayer shall upload the same on the RFD-01 application screen by clicking on the hyperlink “Click to upload the Statement of invoices (Unutilized ITC)” and proceed further for validation.

9. Post-Upload Validation and Reports

Once uploaded, the invoices furnished through the utility shall be validated by the system against GSTR-2B. The validation results shall be displayed as under:

  • Valid documents sheet: Reflects whether the uploaded invoices are present in GSTR-2B or otherwise.
  • GSTR-2B periods up to October 2024: For invoices pertaining to GSTR-2B periods up to October 2024 or earlier, the system shall not undertake validation against GSTR-2B. However, taxpayers will be permitted to furnish such invoice details in the utility and upload the same on the portal. The system shall display a generic message indicating that the invoices have not been validated, although such invoices shall continue to form part of the validated documents. This is an expected system behaviour and shall not be construed as an error.
  • GSTR-2B periods from November 2024 onwards: Any mismatches or validation failures in respect of invoices pertaining to November 2024 or later periods shall be reflected in an Invalid Documents Report.

10. Operational Precautions

GSTN has set out certain operational precautions, which are critical for error-free generation and upload of the JSON file. These are reproduced below for ready reference:

  • Copy-paste of dropdown values: Copy-paste functionality has been enabled for dropdown values. While exercising this option, taxpayers must ensure that the pasted value exactly matches the prescribed dropdown value. Any deviation, including leading or trailing spaces, may result in validation errors. Further, data should not be pasted into frozen or protected fields.
  • Closing of older versions: Before using the newly downloaded utility, taxpayers must ensure that any previous version of the Annexure-B Offline Utility is completely closed. Keeping an older version simultaneously open may cause issues with the enhanced copy-paste functionality.
  • Avoidance of unnecessary spaces: Care must be taken to avoid unnecessary spaces while entering or copy-pasting data (such as extra spaces after the supplier name or in other fields), as such inconsistencies may lead to errors during JSON generation or upload.
  • No direct modification of JSON: The generated JSON file should not be modified directly. Any required modifications must be made in the offline utility itself, followed by revalidation and generation of a fresh JSON file. The name of the JSON file should not be altered after creation, as this may lead to upload issues.

11. Line-Item Upload Limits

The present system functionality permits the following limits in respect of a single refund application:

  • Up to 10,000 line items in one offline utility file;
  • Up to 25 such utility files per refund application;
  • Aggregate ceiling of 2,50,000 line items per refund application.

Where the number of line items exceeds the aforesaid ceiling of 2,50,000, taxpayers are advised to upload 2,50,000 line items through the offline utility, and to submit the balance invoices as supporting documents in PDF format. GSTN has indicated that approaches to support higher-volume data ingestion are being evaluated and will be implemented in due course.

12. Our Observations and Practical Implications

The transition from PDF-based Annexure-B to a structured offline utility marks a significant shift in the GST refund filing ecosystem. While the initiative is intended to bring uniformity and enable automated invoice-level verification, it casts an enhanced compliance responsibility on taxpayers. From a practical standpoint, the following implications merit particular attention:

  • Invoice-level rigour: Taxpayers must maintain robust internal records segregating each inward invoice by HSN/SAC code and category of input supply (Inputs, Input Services or Capital Goods). The earlier flexibility of consolidated reporting in PDF format is no longer available.
  • Section 17(5) tagging: The requirement to indicate, for each invoice, whether the ITC is blocked under Section 17(5) calls for accurate identification at the time of accounting itself. This data point will directly influence the Net ITC computation and consequently the quantum of refund sanctioned.
  • GSTR-2B reconciliation: Given the automated matching with GSTR-2B for periods from November 2024 onwards, any invoices not appearing in GSTR-2B will be flagged in the Invalid Documents Report. Taxpayers must therefore ensure that suppliers have correctly reported the invoices in their respective GSTR-1, failing which the refund may be jeopardised or delayed.
  • Handling of large-volume refunds: Exporters and inverted duty structure claimants with substantial invoice volumes (particularly in sectors such as logistics, manufacturing and pharmaceuticals) should evaluate whether refund applications can be filed for shorter periods to remain within the 2,50,000 line-item ceiling, rather than aggregating multiple periods.
  • Split-invoice methodology: Where a single invoice contains multiple HSN/SAC or categories, the proportionate distribution of invoice value and tax amounts must be done with care. Inconsistent allocations are likely to invite scrutiny from the proper officer during processing of the refund claim.
  • Reversal reporting in multi-file scenarios: The instruction to populate reversal figures only in the last utility file (with preceding files reflecting zero) is a critical point. Inadvertent duplication of reversals across files may distort the consolidated Net ITC and lead to short refund.

13. Recommended Action Points for Taxpayers

Clients are advised to undertake the following preparatory steps to ensure smooth transition to the new utility:

  • Download the latest version of the Annexure-B Offline Utility from the GST portal and discontinue use of any earlier version;
  • Read the “Read Me” section of the utility carefully, with particular attention to Point 6 on invoices with multiple categories or HSN/SAC codes;
  • Sensitise the accounts and indirect tax teams on the requirement of HSN/SAC-wise and category-wise segregation of invoices;
  • Re-verify the master data of suppliers (GSTIN, supplier name) to eliminate trailing spaces and other inconsistencies that may trigger validation errors;
  • Reconcile inward invoices with GSTR-2B before commencing data entry, so that mismatches are identified and addressed at the supplier end prior to filing;
  • Maintain a separate working file for ITC reversals attributable to Rules 38, 42, 43 and Section 17(5), and ensure that the same is captured only in the final utility file in multi-file scenarios;
  • Where line items are likely to exceed 2,50,000 for a single refund period, consider segregating the refund period or maintaining ready PDF support for the balance;
  • Preserve a back-up of the offline utility file used for each refund application, as the same will serve as a vital working paper in the event of subsequent verification, deficiency memo or audit by the Department.

14. Conclusion

The introduction of the Annexure-B Offline Utility is a welcome step towards process standardisation and reduction of manual verification at the field level. At the same time, it raises the bar for taxpayer-side data discipline, given that the system will now match invoice-level data with GSTR-2B in real time. Adherence to the prescribed format, accurate categorisation of input supplies and disciplined treatment of reversals will be the key determinants of timely sanction of refund.

GSTN has indicated that a detailed user manual with screenshots will be shared shortly. Clients are requested to revisit their refund-filing standard operating procedures in light of this advisory. Our firm will continue to monitor further developments and will issue supplementary advisories as and when warranted.

For any clarification or assistance in relation to refund filings under the new utility, clients are welcome to reach out to our office.

For Mohan & Chandrasekhar

Chartered Accountants

Hosur | Bengaluru | Chennai

Disclaimer: This advisory has been prepared on the basis of the GSTN advisory dated 18th May, 2026. It is intended for general guidance and information purposes only and should not be construed as professional advice. Readers are advised to take specific advice in respect of their facts and circumstances before acting upon the contents herein.