• Gst refund pre application and Date of issue of IEC.

Scenario: The present case is a refund of (a) RCM paid by the payer and (b) ITC on purchases.

-Is it a precondition that the tax payer (exporting the services without payment of IGST under LUT, but paying RCM and claiming the ITC) to have IEC code, though not claiming any benefits under Foreign Trade Policy?

-Can the PAN be treated as IEC where the tax payer does not claim any benefit under Foreign Trade policy?

(Referring above image)

In this online Form, one field is to disclose the Income Tax paid during FY 2018-19. Without asking either latest figures or first year figures, why the system is asking for in between year’s figures?
In the same field mentioned above, one need to fill in the 2018-19 FY related Income tax figures or its income tax figures based on the year of filing, irrespective of the year to which the income tax is related?

As the said Refund Pre Application (once submitted) can not be modified/resubmitted, what will be the consequences, in case by oversight or different interpretation of the above doubts, if the said, application gets rejected? In other words, Can the tax payer make a fresh application OR totally his eligibility to claim GST Refund itself gets cancelled?

Request to help with above queries.
Asked 19 days ago in GST



  1. IEC Code for Taxpayer Exporting Services under LUT: The Import Export Code (IEC) is a key business identification number that is mandatory for exports from and imports to India. Even if a service exporter is exporting services under a Letter of Undertaking (LUT) without payment of IGST and is paying Reverse Charge Mechanism (RCM) while claiming the Input Tax Credit (ITC), it is generally required to have an IEC code.

  2. Using PAN in Place of IEC: PAN (Permanent Account Number) cannot be typically used as a substitute for IEC because they serve different purposes. PAN is used for all tax-related identification in India, while IEC is specifically used for tracking and managing exports and imports. However, as of my last update in April 2023, the government had merged the PAN with the IEC to reduce the number of compliances. Therefore, the PAN is equivalent to the IEC, provided it is registered as such with the DGFT.

  3. Why the System is Asking for FY 2018-19 Income Tax Figures: Systems are often programmed to ask for historical data for various reasons including verification, consistency of financial data over time, or due to the fiscal policies at that moment. It's possible that the system is designed to cross-verify the information with data available from the specified year.

  4. Income Tax Figures to Fill: You would need to fill in the income tax figures for the financial year 2018-2019, as specified. The requirement to input the figures from a specific past fiscal year is likely to do with how the system cross-references and verifies the data with already existing records from that period.

For detailed, personalized advice, consider a phone consultancy.

Hope you find the information helpful. You are free to contact me for further discussion.If you could spare two minutes of your time to write a review, It would be really grateful and very happy to read it.

Thank you.

Shubham Goyal

Shubham Goyal
CA, Delhi
212 Answers
4 Consultations

5.0 on 5.0

- If you are exporting services and not claiming benefit of FTP then no need to apply for IEC

- PAN by default can not be treated as IEC without filing application for IEC

- Purpose is to obtain business information. Provide data only for the year asked 

- Fill the correct information and subsequently file GST refund application


For detailed discussion you may opt for phone consultation

Vivek Kumar Arora
CA, Delhi
4840 Answers
1037 Consultations

5.0 on 5.0

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