Toll Plaza Records Are Not a Condition for Your Export Refund: GST Appellate Tribunal

The Kolkata bench of the GST Appellate Tribunal has upheld refunds of accumulated input tax credit to an exporter, holding that toll plaza records are not a statutory requirement for proving movement of goods and that a supplier's later cancellation does not defeat the claim.

The Goods and Services Tax Appellate Tribunal has begun deciding appeals, and one of its early decisions is good news for exporters. The Kolkata bench, in an order dated 20 August 2026, dismissed the department's appeals against refunds of accumulated input tax credit granted to an exporter and held that toll plaza records are not a statutory requirement for proving that goods moved.

The department had resisted the refunds on two grounds: that toll plaza data did not show the consignments travelling from the supplier's registered State, and that some upstream suppliers had since had their registrations cancelled. The Tribunal rejected both. There is no provision in the GST law requiring goods to start from the supplier's registered place of business, and where movement is established by e-way bills, shipping bills, export general manifests, transporter certificates and bank statements, the absence of a toll receipt proves nothing. The Tribunal also refused to entertain allegations the department had never put in the show cause notice.

What this means for you

If your refund claim is stuck over a document nobody asked for at the outset, the point is worth pressing. CBIC's own master refund circular tells officers not to demand paperwork beyond what is prescribed: Circular No. 125/44/2019-GST dated 18 November 2019, at https://cbic-gst.gov.in/pdf/circular-cgst-125.pdf, expressly says the proper officer shall not insist on invoices whose details are already in GSTR-2A. Tamil Nadu exporters now have a bench of their own at Chennai to take such a refusal to.

Topics:GST Appellate TribunalGSTAT Kolkataexport refund GSTaccumulated ITC refundsection 54(3)toll plaza receiptse-way bill proof of movementsupplier registration cancelledCircular 125/44/2019GSTAT Chennai benchTamil Nadu exportersChennai GST

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