New Annexure-B JSON Utility Tightens GST Refund Claims for Unused ITC

1. Background: Push Towards Automated GST Refunds

The GST administration is steadily shifting from paper-based and officer-driven verification to a fully digital, rule-based environment. A key development in this direction is the overhaul of the refund process for unutilised Input Tax Credit (“ITC”).

For refund applications filed in Form GST RFD-01 on account of accumulated ITC (such as by exporters and assessees facing inverted duty structures), the Government has now replaced the earlier PDF-based Annexure-B with a structured Annexure-B Offline Utility built on JSON format.

This change is intended to:

  • Enable automated checks by the GST portal
  • Minimise officer discretion in sanctioning refunds
  • Introduce standardised, invoice-level data reporting

While this is expected to speed up and streamline refund processing, it also demands tighter reconciliations and greater data accuracy from assessees before filing their refund claims.

2. From Static PDF to Structured JSON: What Has Changed?

2.1 Earlier Process: Manual Reliance on PDF Annexure-B

Previously, when filing Form GST RFD-01, the assessee had to:

  • Prepare Annexure-B in a PDF format
  • Upload this PDF along with the refund application

Because the data was presented as a non-editable document, the GST system could not automatically read or validate the invoice-level information. Consequently:

  • Jurisdictional officers relied mainly on manual scrutiny
  • Any reconciliation between the refund claim and source documents (such as GSTR-2B, purchase registers, electronic credit ledger) was largely done at the departmental end
  • The outcome and speed of refunds were heavily influenced by individual officer interpretation and workload

2.2 New Mechanism: JSON-Based Offline Utility

The new regime mandates the use of a JSON-based Annexure-B Offline Utility, where:

  • The assessee prepares Annexure-B in a structured template
  • The file is generated in JSON (a machine-readable digital format)
  • This JSON file is uploaded along with Form GST RFD-01

Because JSON is system-readable, the GST portal can now:

  • Automatically parse invoice-wise data
  • Run pre-defined validation rules
  • Compare refund data with the assessee’s other GST returns and records

Note: The switch to JSON is aligned with the Government’s broader strategy of embedding automated, system-based controls into routine GST compliance.

3. Expanded Invoice-Level Reporting under New Annexure-B

3.1 Granular Data Requirements

Under the modified Annexure-B Offline Utility, refund claims have moved from a high-level summary format to detailed invoice-wise reporting. For every invoice forming part of the ITC refund, the assessee will now have to provide:

  • Nature of inward supply
  • Type of document (such as invoice, debit note, etc.)
  • Total ITC amount available as per the document
  • Portion of credit that is blocked under Section 17(5) of the CGST Act
  • Clear bifurcation between eligible ITC and ineligible ITC
  • Specific GSTR-2B period in which that invoice appears
  • Other invoice attributes required for automated checks and system validation

This level of detailing transforms the refund process into a line-by-line ITC verification exercise, directly linked to the data in GSTR-2B.

3.2 Shift from Summary to Validation-Ready Data

Earlier, officers would often rely on:

  • Summary ITC figures
  • Consolidated statements
  • Manual cross-verification with returns and supporting documents

Now, however: