Telangana High Court Waives CA Certificate Requirement for Claiming Statutory Interest on Delayed GST Refunds

The mechanism of claiming refunds under the Goods and Services Tax (GST) framework often involves navigating a labyrinth of procedural prerequisites. While the principal refund process is rigorously structured to prevent revenue leakage and unjust enrichment, disputes frequently arise when an assessee claims statutory interest on delayed disbursements. In a significant judicial development, the Telangana High Court, in the matter of Synchron Intelnational Service Private limited and another Vs Assistant Commissioner (ST), has clarified the procedural boundaries for claiming such interest.

The Court ruled that when a principal GST refund has already been sanctioned and disbursed, the tax authorities cannot mechanically insist on a Chartered Accountant (CA) or Cost and Management Accountant (CMA) certificate under Rule 89(2)(m) of the Central Goods and Services Tax Rules, 2017 (CGST Rules) for processing the consequential interest claim. This summary analyzes the factual matrix, the legal arguments advanced by both sides, and the ultimate directives issued by the High Court.

Background of the Dispute

The batch of writ petitions was filed before the Telangana High Court by the assessee, seeking the release of interest on delayed GST refunds for the tax periods spanning from July 2018 to March 2021.

According to the facts on record, the principal refund amounts for these respective tax periods had already been successfully processed and paid to the assessee. These disbursements were executed either directly by the Refund Sanctioning Authority or following favorable directives from the appellate authority. However, because the release of these principal amounts was significantly delayed, the assessee became legally entitled to claim interest under Section 56 of the Central Goods and Services Tax Act, 2017 (CGST Act).

The assessee accordingly filed applications to claim this statutory interest, which remained pending before the Proper Officer since June 3, 2025. Instead of processing the interest payout, the tax department issued multiple Deficiency Memos against the refund applications. The assessee was ultimately forced to seek judicial intervention when the department issued a third Deficiency Memo that allegedly lacked specific particulars and merely stalled the disbursement process.