Finance Bill, 2026 relaxes GST refund provisions under Section 54. Provisional refund extended to inverted duty cases and ₹1,000 minimum limit removed for export with payment of tax. Explained simply.
📌 Why GST Refunds Were a Pain Point
GST refunds have historically been one of the most delayed and litigated areas, especially for:
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Exporters paying GST and claiming refund
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Businesses under inverted duty structure
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Small exporters with frequent low-value refunds
Two major issues existed:
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No provisional refund for inverted duty cases
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Refund below ₹1,000 blocked, even for exports
The Finance Bill, 2026 finally addresses both.
🔁 What Has Changed in Finance Bill 2026?
Finance Bill, 2026 amends Section 54 of the CGST Act, 2017 through Clause 139, covering:
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Section 54(6) – Provisional refund
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Section 54(14) – Minimum refund threshold
🟢 Change 1: Provisional Refund Extended to Inverted Duty ITC
(Section 54(6) Amendment)
🔴 Position Before 2026
Category Provisional Refund Zero-rated supplies (exports) ✅ Allowed (90%) Inverted duty structure ❌ Not allowed
| Category | Provisional Refund |
|---|---|
| Zero-rated supplies (exports) | ✅ Allowed (90%) |
| Inverted duty structure | ❌ Not allowed |
Inverted duty taxpayers had to wait for full scrutiny, causing cash-flow blockage.
🟢 Position After Finance Bill 2026
Category Provisional Refund Zero-rated supplies ✅ Continues Inverted duty ITC (Section 54(3)(ii)) ✅ Now allowed
| Category | Provisional Refund |
|---|---|
| Zero-rated supplies | ✅ Continues |
| Inverted duty ITC (Section 54(3)(ii)) | ✅ Now allowed |
👉 90% provisional refund can now be granted even for inverted duty cases.
🟢 Change 2: ₹1,000 Refund Limit Removed for Export with Payment of Tax
(Section 54(14) Amendment)
🔴 Earlier Rule
Refund not paid if amount < ₹1,000
✔ Applied even to exporters
This resulted in loss of legitimate refunds, especially for small exporters.
🟢 New Rule After Finance Bill 2026
Scenario Refund Allowed if < ₹1,000? Export of goods with payment of tax ✅ Yes Other refunds ❌ Still restricted
| Scenario | Refund Allowed if < ₹1,000? |
|---|---|
| Export of goods with payment of tax | ✅ Yes |
| Other refunds | ❌ Still restricted |
👉 Exporters paying IGST will no longer lose refunds merely due to low value.
🧠 Who Is Impacted the Most?
This amendment is highly beneficial for:
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Exporters under payment of IGST route
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MSMEs with frequent small exports
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Manufacturers under inverted duty structure
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Textile, pharma, chemicals & FMCG sectors
If GST refunds affect your working capital, this change matters.
⚠️ What Has NOT Changed
❌ Refund scrutiny is not eliminated
❌ Documentation requirements remain
❌ Time limits under Section 54 still apply
This is a cash-flow relief, not an automatic refund.
📋 What Should Businesses Do Now? (Action Checklist)
✔ Identify inverted duty refund eligibility
✔ Re-evaluate refund filing strategy
✔ Improve documentation for provisional refund
✔ Track low-value export refunds
✔ Align cash-flow planning with faster refunds
Early action = better liquidity.
❌ Common Mistakes to Avoid
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Assuming 100% refund will be provisional
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Ignoring documentation quality
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Missing refund timelines
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Filing incorrect refund category
Assuming 100% refund will be provisional
Ignoring documentation quality
Missing refund timelines
Filing incorrect refund category
Mistakes can still delay refunds.
⚖️ Legal References
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Finance Bill, 2026 – Clause 139
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Section 54(6), CGST Act (Amended)
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Section 54(14), CGST Act (Amended)
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Section 54(3)(ii), CGST Act
Finance Bill, 2026 – Clause 139
Section 54(6), CGST Act (Amended)
Section 54(14), CGST Act (Amended)
Section 54(3)(ii), CGST Act
🏁 Conclusion
The Finance Bill, 2026 introduces long-awaited relief in GST refund provisions by:
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Extending provisional refunds to inverted duty cases, and
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Removing the ₹1,000 barrier for export refunds.
These changes significantly improve working capital efficiency, especially for exporters and MSMEs — provided refunds are filed correctly.
If your business regularly files GST refund claims or faces cash-flow blockage due to delayed refunds, it is advisable to re-evaluate your refund strategy in light of these amendments.