Provisional Sanction of Refund Claims Based on System-Identified Risk

Notification/Circular No.: Instruction No. 06/2025-GST dated October 03, 2025

Applicable Act/Rule: Central Goods and Services Tax (CGST) Act, 2017 & CGST Rules, 2017

Effective Date – October 01, 2025

The GST Council, in its 56th meeting held on September 3, 2025, recommended an amendment to Rule 91(2) of the CGST Rules, 2017. The amendment enables sanction of 90% of refund claims on a provisional basis through a system-driven risk evaluation mechanism. Notification No. 13/2025-Central Tax and Notification No. 14/2025-Central Tax, both dated September 17, 2025, operationalised this change with effect from October 1, 2025.

Refund applications filed on or after October 1, 2025, will be processed based on system-generated risk categorisation. Applications marked as “low-risk” will receive 90% of the claimed refund provisionally, while high-risk applications will undergo detailed scrutiny. Officers may withhold provisional refunds only with written justification under the proviso to Rule 91(2).

Statutory conditions under Section 54(6) and Rule 91(1)—such as non-prosecution and exclusion of notified categories—continue to apply. Provisional refunds cannot be adjusted or withheld under Sections 54(10) and (11).

As an interim facilitation, refund claims on account of Inverted Duty Structure (IDS) filed on or after October 1, 2025, will also be eligible for provisional sanction of 90% of the claimed amount, pending formal amendment to Section 54(6). The GSTN has enabled functionality for these provisional refunds in line with zero-rated supply refunds.

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