Major Change in GST Refund Filing Process | Annexure-B Now Mandatory via Offline Utility GSTN Advisory | Effective May 18, 2026
WHAT HAS CHANGED?
The GST Network (GSTN) has officially discontinued the PDF-based submission of Annexure-B. With effect from May 18, 2026, all taxpayers claiming refunds on account of accumulated Input Tax Credit (ITC) are required to mandatorily use the prescribed Excel-based Offline Utility for furnishing Annexure-B.
| In simple words: If you were attaching a PDF file for Annexure-B, that option is now permanently removed from the GST portal. There is no alternative — the Offline Utility is the only permitted route. |
WHO IS AFFECTED?
This procedural change applies to refund applications filed under the following categories:
| # | Refund Category |
| 1 | Export of Goods / Services — without payment of tax (Accumulated ITC) |
| 2 | Supplies to SEZ Unit / SEZ Developer — without payment of tax |
| 3 | ITC accumulated due to Inverted Tax Structure — Section 54(3), CGST Act |
| 4 | Export of Electricity — without payment of tax (Accumulated ITC) |
KEY REQUIREMENTS UNDER THE NEW PROCESS
1. HSN/SAC-wise Invoice Reporting — No Shortcuts
Every invoice must now be reported separately under three supply categories:
- Inputs
- Input Services
- Capital Goods
Where a single invoice covers multiple HSN/SAC codes or different supply categories, it must be split into separate line items with proportionate tax values assigned to each.
Practical Impact: Businesses not maintaining HSN-wise purchase registers will face significant difficulty at the filing stage itself. Data cleanup must happen before — not during — the filing process.
2. Duplicate Entry Restriction — Hard Rejection by System
The system will automatically and irrevocably reject any entry where the following combination appears more than once:
| Supplier GSTIN + Invoice Number + Invoice Date + Supply Category + HSN/SAC One combination. One entry. The system will hard-reject any duplication — no exceptions, no override. |
This makes clean, deduplicated purchase data a non-negotiable prerequisite before filing.
ITC Reversal Reporting Must Match GSTR-3B — Exactly
Reversals under Rules 38, 42, and 43 of the CGST Rules, and under Section 17(5) of the CGST Act, must align precisely with the figures declared in GSTR-3B for the relevant tax period. There is no room for approximation or rounding.
| Important — Multiple Utility Files: If you are submitting more than one utility file for a single refund application, enter the reversal figures only in the last file. All preceding files must reflect zero. Duplication of reversal figures across files will cause discrepancies. |
GSTR-2B Validation — Understand How It Works
Once uploaded, every invoice is validated against GSTR-2B data. The validation rules differ based on the invoice period:
| Invoice Period | Validation Behaviour |
| November 2024 onwards | Strict system validation against GSTR-2B. Mismatches are moved to the Invalid Documents Report and will not be processed. |
| October 2024 or earlier | No system-level validation is performed. However, invoices are accepted and treated as valid documents for refund purposes. |
Note: The generic message displayed by the portal for pre-October 2024 invoices is expected system behaviour — it is not an error and does not indicate rejection.
Upload Volume Limits — Plan Before You File
| Parameter | Permissible Limit |
| Line items per utility file | 10,000 |
| Maximum utility files per application | 25 |
| Total line items per refund application | 2,50,000 |
| Invoices beyond the prescribed limit | Submit as a PDF supporting documents |
Taxpayers with large volumes of invoices must plan the distribution of line items across utility files in advance to stay within these limits.
CRITICAL COMPLIANCE CHECKPOINTS
Before submitting the refund application, ensure the following without exception:
- No leading or trailing spaces in any data field — these trigger validation errors and cause rejection
- Always close the previous version of the utility before opening a new one
- Do not manually edit or rename the system-generated JSON file; all corrections must be made within the utility, followed by fresh JSON generation
- Review the consolidated ITC summary carefully and cross-verify totals before final submission
- Dropdown field values must match the prescribed options in the utility exactly — any deviation will result in an error
- Read the ‘Read Me’ section in the utility — particularly Point 6 — before entering any data
ACTION POINTS — PRE-FILING CHECKLIST
Before filing your next refund application, complete the following steps:
1. Reconcile your ITC ledger with GSTR-2B data — invoice by invoice, for each relevant tax period
2. Ensure your purchase register is maintained HSN/SAC-wise and category-wise (Inputs / Input Services / Capital Goods)
3. Download the latest version of the Annexure-B Offline Utility directly from the GST portal
4.Read the ‘Read Me’ section of the utility — especially Point 6 — before entering any data
5. Prepare ITC reversal figures in advance and verify them against the corresponding GSTR-3B filing
6. Do not file under time pressure — review the consolidated summary thoroughly before final submission
WHY THIS MATTERS
GSTN is systematically building an end-to-end traceable refund ecosystem — one where every rupee of refund claimed is linked to a specific invoice, a specific HSN code, and a specific GSTR-2B entry. The era of bulk PDF uploads with minimal verification is over.
For businesses: Your purchase register, GSTR-2B reconciliation, and HSN-wise ITC tracking must be audit-ready before you open the utility — not after.
For practitioners: Pre-filing data audits are no longer optional. They are the foundational requirement for a clean, defensible refund claim.
The positive outcome of this shift: fewer departmental queries, faster processing timelines, and significantly stronger documentation in the event of a scrutiny or challenge.
| A refund delayed is working capital blocked — and in the current business environment, that has a real cost. Taxpayers and advisors who adapt early will file cleaner applications, get processed faster, and face far fewer objections. |
IMPORTANT NOTE
GSTN has confirmed that a detailed user manual, complete with portal screenshots and step-by-step guidance for the Offline Utility, will be released shortly. Practitioners are advised to keep a close watch on the GST portal for this update before undertaking their next refund filing.
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Author’s Note: The views expressed in this article are personal and based on current GSTN functionalities and legal interpretations. Readers are encouraged to refer to the specific facts of their case and the latest notification, circulars before proceeding. While due care has been taken in preparing this article, certain mistakes and omissions may creep in. The author does not accept any liability for any loss or damage of any kind arising out of any inaccurate or incomplete information in this document, nor for any actions taken in reliance thereon.
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