GST Refund in Case of Temporary GST Registration

GST Refund in Case of Temporary GST Registration

Table of Contents:-

GST Refund in Case of Temporary GST Registration can arise in different situations under the GST framework. The expression “temporary registration” is commonly used for more than one GST Portal process, so taxpayers should first identify the exact type of temporary registration or Temporary ID involved before filing a refund claim.

One important category relates to an unregistered person who needs to claim refund of GST borne on a cancelled transaction. CBIC Circular No. 188/20/2022-GST introduced a mechanism enabling eligible unregistered persons to obtain temporary registration on the GST Portal and file FORM GST RFD-01 under the category “Refund for unregistered person”.

Temporary registration should not be confused with a Temporary Reference Number (TRN) generated during the ordinary registration process, the advance-tax mechanism applicable to casual or non-resident taxable persons, or a temporary registration created by the GST authorities in a suo motu registration proceeding.

EzyBiz India assists businesses and individuals in identifying the correct GST refund category, reviewing eligibility, preparing FORM GST RFD-01, compiling supporting documents and responding to refund-related departmental queries.

For comprehensive assistance with GST refunds, visit our GST Refund Services in India.

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GST Refund in Case of Temporary GST Registration – Quick Overview

Can a Person with Temporary Registration Claim GST Refund?

Yes, GST law and the GST Portal provide refund mechanisms in specified situations involving temporary registration or Temporary IDs.

However, the procedure depends upon why the temporary registration or Temporary ID exists.

A temporary registration created specifically for an unregistered refund applicant is different from a temporary registration assigned by a GST officer or a TRN generated during an ordinary GST registration application.

Most Common Refund Situations

Temporary-registration-related refund issues may arise in situations such as:

  • refund claims by eligible unregistered persons;
  • cancelled agreements where GST was borne by the recipient;
  • termination of specified long-term contracts;
  • excess advance tax deposited by casual taxable persons;
  • excess advance tax deposited by non-resident taxable persons;
  • amounts available in electronic cash ledger; and
  • other refund situations depending upon the taxpayer status and facts.

What Does Temporary GST Registration Mean?

Temporary Registration for an Unregistered Refund Applicant

CBIC Circular No. 188/20/2022-GST provides a mechanism under which an eligible unregistered person may obtain temporary registration on the GST Portal for the purpose of filing a refund claim.

The temporary registration allows the person to access the refund functionality and submit FORM GST RFD-01 under the prescribed refund category.

Temporary Reference Number during GST Registration

A Temporary Reference Number (TRN) is generated during the GST registration process after initial verification of specified registration details.

A TRN enables the applicant to access and complete the registration application. It should not automatically be treated as a GSTIN or as the temporary registration used for every refund situation.

For general registration assistance, visit our GST Registration Services in India.

Temporary ID on the GST Portal

The GST Portal also uses Temporary IDs for certain categories of unregistered applicants, including refund applicants.

Accordingly, taxpayers should identify whether they hold:

  • a GSTIN;
  • a TRN;
  • a Temporary ID as an unregistered refund applicant;
  • a casual taxable person registration;
  • a non-resident taxable person registration; or
  • a temporary registration generated through departmental proceedings.

Important 2026 Update on Temporary Registration Terminology

Older Articles May Use Different Rule or Form References

GST registration rules and GST Portal functionality have undergone amendments and procedural changes over time.

Older GST material may therefore refer to previous rule numbers, form numbers or processes for temporary and suo motu registration.

Businesses should rely on the current registration rules and GST Portal functionality applicable when the action is being taken.

Temporary Registration and TRN Are Not the Same

A TRN is generally a portal reference generated as part of a registration application process.

A Temporary ID or temporary registration may instead be created for a specific statutory or portal purpose, including specified refund applications by unregistered persons.

Using these expressions interchangeably can result in selecting the wrong GST process.

Refund for Unregistered Persons Using Temporary Registration

CBIC Circular No. 188/20/2022-GST

CBIC issued Circular No. 188/20/2022-GST to prescribe a mechanism for filing refund applications by eligible unregistered persons.

The circular explains that an unregistered person can obtain temporary registration on the GST Portal and file the refund application electronically where the prescribed conditions are satisfied.

Refund Category on GST Portal

The refund application is filed in FORM GST RFD-01 under the category:

“Refund for unregistered person”

The applicant must comply with the documentary and procedural requirements applicable to this refund category.

When Can an Unregistered Person Claim GST Refund?

Cancellation of Construction Agreement

The mechanism under Circular No. 188/20/2022-GST specifically addresses cases where an unregistered buyer had entered into an agreement for construction of a flat, building or similar service, paid consideration together with GST and subsequently cancelled the agreement.

Where the supplier cannot return the GST through the normal credit-note mechanism because the applicable time limit has already expired, the eligible unregistered recipient may examine the refund mechanism.

Termination of Long-Term Insurance Policy

The circular also addresses situations involving premature termination of specified long-term insurance arrangements where tax had been paid upfront and the supplier is unable to issue an effective credit note within the applicable statutory period.

Refund Is Not Automatic in Every Cancellation

A cancelled contract does not automatically create a direct GST refund entitlement for every unregistered recipient.

The taxpayer should examine:

  • nature of transaction;
  • amount originally paid;
  • GST charged by supplier;
  • amount refunded by supplier;
  • whether supplier can still issue a credit note;
  • whether the applicant has borne the incidence of tax;
  • relevant date;
  • limitation period; and
  • supporting documents.

How to Obtain Temporary Registration for Refund

Use PAN and Select the Correct State or Union Territory

For refund claims covered by Circular No. 188/20/2022-GST, the unregistered person is required to obtain temporary registration on the GST Portal using PAN.

The applicant should select the State or Union Territory where the supplier relating to the invoice on which refund is claimed is registered.

Aadhaar Authentication

The temporary-registration process may require Aadhaar authentication according to the applicable GST Portal and statutory requirements.

The applicant should ensure that PAN, Aadhaar and contact information are consistent before starting the process.

Bank Account Details

The applicant must provide the bank account into which the refund is sought.

The bank account should satisfy the applicable portal-validation requirements and should generally correspond with the applicant’s PAN and name.

Incorrect bank information can delay refund processing.

How to File FORM GST RFD-01 Using Temporary Registration

Select Refund for Unregistered Person

After obtaining the required temporary registration or Temporary ID, the applicant should access the GST refund functionality and select the appropriate refund category for an unregistered person.

Prepare FORM GST RFD-01

The applicant should prepare FORM GST RFD-01 using the transaction details and refund amount supported by the relevant documents.

The refund amount should be reconciled with:

  • original tax invoice;
  • GST charged;
  • payment made to supplier;
  • cancellation or termination documents;
  • amount returned by supplier; and
  • amount of GST actually borne by the applicant.

Upload Statement and Supporting Documents

Where applicable, the applicant must upload the prescribed statement and documents required under the GST refund rules.

Supporting documents should be clear, complete and internally consistent before the refund application is submitted.

Official GST refund guidance is available through the GST Portal Refund Manual.

Documents Required for GST Refund by Unregistered Person

Transaction Documents

Depending upon the case, relevant documents may include:

  • original tax invoice;
  • agreement or contract;
  • proof of payment;
  • cancellation agreement;
  • termination letter;
  • refund communication from supplier;
  • bank statement; and
  • correspondence with supplier.

Supplier Certificate

The applicable refund rules and Circular No. 188/20/2022-GST contemplate a certificate from the supplier in the prescribed circumstances.

The certificate and related information should be reviewed against the invoice, cancellation details and amount returned by the supplier.

Statement 8 and Other Supporting Evidence

For refund claims covered by the circular, the applicant may be required to upload Statement 8 along with FORM GST RFD-01 and other prescribed documents.

The taxpayer should also retain evidence demonstrating that the incidence of GST was borne by the applicant and has not been passed on to another person.

GST Refund Time Limit and Relevant Date

General Two-Year Limitation under Section 54

Section 54 generally provides a limitation period of two years from the relevant date for filing specified GST refund applications.

Therefore, the relevant date should be identified before preparing the refund application.

Relevant Date in Cancelled Long-Term Contracts

Circular No. 188/20/2022-GST clarifies the relevant-date approach for the specific unregistered-person refund situations covered by the circular.

For specified cancelled or terminated long-term arrangements where the relevant service had not been completed, the date of the supplier’s cancellation letter may become relevant for determining the limitation period in accordance with the circular.

Businesses should not assume that the two-year period always starts from the invoice date or date of payment.

Minimum Refund Amount and Refund Computation

Minimum ₹1,000 Threshold

For the unregistered-person refund mechanism discussed in Circular No. 188/20/2022-GST, the circular clarifies that no refund should be claimed where the refundable amount is below ₹1,000.

Refund Cannot Exceed Eligible GST

The amount claimed should not exceed the eligible tax supported by the invoices and refund computation.

Where the supplier refunds only part of the amount originally paid by the recipient, the GST refund may also need to be restricted proportionately according to the applicable facts and circular.

Multiple Suppliers and Multiple States

Separate Applications for Different Suppliers

Where refund relates to invoices issued by different suppliers, separate refund applications may be required according to the procedure prescribed in Circular No. 188/20/2022-GST.

Suppliers Registered in Different States

If the relevant suppliers are registered in different States or Union Territories, the applicant may need separate temporary registrations or Temporary IDs for the respective jurisdictions as required under the applicable procedure.

Accordingly, applicants should organise invoices supplier-wise and State-wise before beginning the refund process.

When Supplier Should Issue Credit Note Instead

Credit Note Period Still Available

If the supplier is still legally able to issue a GST credit note for the cancelled transaction within the applicable statutory time limit, the supplier may generally address the GST adjustment through the normal credit-note mechanism.

In such a situation, a direct refund application by the unregistered recipient under the temporary-registration mechanism may not be required.

Refund Route When Credit Note Time Has Expired

The unregistered-person refund mechanism is particularly relevant where the transaction has been cancelled but the supplier can no longer make the GST adjustment through the normal credit-note route because the applicable statutory time limit has expired.

The actual facts and timing should therefore be verified before selecting the refund category.

Casual Taxable Person and Temporary Reference Number

Advance Deposit of Tax

A person applying for registration as a casual taxable person may be required to make an advance deposit of tax equivalent to the estimated tax liability for the period for which registration is sought.

The GST Portal may generate a Temporary Reference Number to facilitate the advance deposit and registration process.

Refund of Excess Advance Tax

Where the actual liability is lower than the advance tax deposited, the eligible balance may become refundable after compliance with the applicable return-filing and refund requirements.

The GST refund rules specifically provide for refund of eligible balance remaining after adjustment of the tax payable against advance tax deposited under Section 27.

For related return compliance, refer to our GST Return Filing Services in India.

Non-Resident Taxable Person and Advance Tax Refund

TRN and Advance Tax Deposit for NRTP

A non-resident taxable person is subject to a specialised GST registration process and may receive a Temporary Reference Number for making the required advance tax deposit.

The temporary reference number in this context should not be confused with temporary registration obtained by an unregistered person solely for filing a refund claim.

Refund of Eligible Excess Balance

After the applicable tax liability has been discharged and required returns have been furnished, an eligible excess balance may become refundable according to the GST refund rules and GST Portal procedure.

Businesses involving foreign entities may also refer to our GST and Indirect Tax Advisory Services in India.

Suo Moto Temporary Registration by GST Officer

Temporary Registration for Failure to Obtain Required GST Registration

GST registration rules also contain a mechanism under which a proper officer may temporarily register a person where the officer finds during survey, enquiry, inspection, search or another proceeding that the person was liable for GST registration but had failed to obtain registration.

This form of temporary registration is fundamentally different from temporary registration voluntarily obtained by an unregistered applicant for a refund claim.

Do Not Use the Wrong Refund Procedure

A person who has been temporarily registered by the department should first determine:

  • the nature of the temporary registration;
  • whether a regular registration application is required;
  • tax liabilities arising from the effective date;
  • return-filing obligations;
  • electronic ledger balances; and
  • the statutory basis of any proposed refund.

Where the matter has arisen from departmental action, refer to our GST Assessment & Litigation Services in India.

Common Errors and How EzyBiz India Assists

Common Errors in Temporary Registration Refund Claims

Common issues may include:

  • confusing TRN with Temporary ID;
  • selecting the wrong refund category;
  • obtaining temporary registration in the wrong State;
  • using incorrect bank account details;
  • missing Aadhaar authentication;
  • incorrect relevant date;
  • filing beyond limitation;
  • incorrect refund computation;
  • missing supplier certificate;
  • missing cancellation documents;
  • incorrect Statement 8 details; and
  • claiming refund where a supplier credit note remains the appropriate mechanism.

GST Refund Preparation and Filing Support

EzyBiz India can assist with:

  • refund eligibility review;
  • identification of correct GST refund category;
  • temporary-registration process review;
  • limitation analysis;
  • refund computation;
  • invoice reconciliation;
  • document checklist;
  • RFD-01 preparation;
  • Statement 8 review;
  • bank-account verification review;
  • refund-status monitoring; and
  • coordination with the applicant and supplier.

Refund Notice and Rejection Support

Where a refund application results in a deficiency memo, show cause notice, partial rejection or adverse refund order, our team can assist with reconciliation, factual submissions and available remedial proceedings.

For complete assistance, visit our GST Refund Services in India.

Frequently Asked Questions on Temporary GST Registration Refund

Can an unregistered person claim GST refund?

Yes, in specified circumstances an unregistered person can claim GST refund through the prescribed GST Portal mechanism. Circular No. 188/20/2022-GST specifically prescribes the process for certain refund claims by unregistered persons.

Do I need a regular GST registration only to claim refund?

Not necessarily. For specified unregistered-person refund situations, the GST Portal provides a temporary-registration or Temporary ID mechanism so that the applicant can file the prescribed refund application.

Which form is used to claim GST refund by an unregistered person?

The refund application is filed in FORM GST RFD-01 under the applicable category for refund to an unregistered person.

What is the time limit for filing the refund claim?

Specified GST refund claims are generally subject to the two-year limitation under Section 54, calculated from the relevant date applicable to the particular refund category.

Can I claim refund if my builder cancelled the agreement?

Refund may be available in the circumstances contemplated by Circular No. 188/20/2022-GST, particularly where GST was borne by the unregistered recipient and the normal credit-note mechanism is no longer available to the supplier because the applicable statutory period has expired.

Is a TRN the same as Temporary GST Registration?

No. A TRN is a Temporary Reference Number generated for specified GST Portal processes. A Temporary ID or temporary registration may be created for a different purpose, including an unregistered-person refund application.

Can EzyBiz India assist if my GST refund is rejected?

Yes. We can review the refund application, deficiency memo or rejection order and assist with reconciliation, supporting documents, response preparation and the appropriate further remedy.

Related Services, Official References and Professional Information

Related Services

Official References

Prepared By

EzyBiz India Consulting LLP

EzyBiz India Consulting LLP is an integrated business, tax and regulatory consulting firm providing assistance in GST, income tax, international tax, transfer pricing, FEMA, corporate compliance, audit support, accounting and India market-entry matters.

Reviewed By

Anil Agrawal, Chartered Accountant
Founder, EzyBiz India Consulting LLP

Chartered Accountant with more than 20 years of professional experience in taxation, GST, regulatory compliance, refunds, assessments, appeals, accounting, audit support and business advisory matters for Indian and international businesses.

Last Updated: September 2026

Disclaimer

The information provided on this page is for general informational and educational purposes only and should not be considered legal, tax, accounting or regulatory advice.

GST refund eligibility, temporary-registration procedures, Temporary ID functionality, documentation, limitation, relevant date, refund computation and portal processes depend upon the facts of the transaction and the statutory provisions, rules, notifications, circulars and GST Portal functionality applicable at the relevant time.

The terminology and form numbers relating to temporary registration, TRN, Temporary IDs and other GST registration processes may change through amendments or portal updates. Applicants should verify the current GST Portal and CBIC requirements before filing.

Professional advice should be obtained after considering the specific invoice, agreement, cancellation documents, refund amount, supplier details and procedural status of each case.