Introduction to the New Annexure-B Reporting Mechanism
As of May 18th, 2026, the GST Network (GSTN) has introduced a significant shift in the refund filing process for taxpayers claiming accumulated Input Tax Credit (ITC). Previously, taxpayers were permitted to upload Annexure-B in PDF format under certain guidelines. However, to enhance transparency and enable system-based verification of invoices, a standardized Annexure-B Offline Utility has been deployed. This change ensures that refund processing is automated and aligned with GSTR-2B data, reducing manual intervention and processing delays.
Applicability of Annexure-B Offline Utility
Taxpayers must use this prescribed Excel-based utility when filing refund applications (Form RFD-01) under the following specific categories:
- Exports of Goods or Services: Claims made without payment of tax (accumulated ITC), excluding electricity.
- Supplies to SEZ: Supplies made to SEZ Units or SEZ Developers without payment of tax.
- Inverted Tax Structure: Claims filed under Clause (ii) of the first proviso to Section 54(3) of the CGST Act.
- Electricity Exports: Export of electricity without payment of tax involving accumulated ITC.
Key Features and Structure of the Utility
The Annexure-B Offline Utility is designed to capture granular details of inward supplies. It consists of two primary tables that form the foundation of the refund claim:
- Table 1 – Reversal Details: Used to report ITC reversals.
- Table 2 – HSN/SAC-wise Inward Invoice Details: Used to report invoice-level data for which ITC was claimed in GSTR-3B.
Expert Advice from Compliance Katta: Reporting is no longer just invoice-wise; it is now HSN/SAC-wise. If one invoice contains three different HSN codes, it must be split into three separate line items in the utility.
Technical Specifications and Limits
To manage high volumes of data, the GST portal allows for multiple file uploads. Each individual utility file can accommodate up to 10,000 entries. Taxpayers can upload up to 25 such JSON files per refund application, allowing for a total of 2,50,000 line items. Any data exceeding this limit must be converted into a PDF and uploaded as a supporting document.
| Feature | Description / Limit |
|---|---|
| File Format | Excel-based Utility (.xlsx to .json) |
| Maximum Entries per File | 10,000 Line Items |
| Maximum Files per Application | 25 Files |
| Total Capacity | 2,50,000 Line Items |
| Validation Source | GSTR-2B (For periods from Nov 2024 onwards) |
Critical Reporting Guidelines for Taxpayers
1. Handling Multiple Categories and HSN Codes
If a single invoice contains different categories of supplies (Inputs, Input Services, or Capital Goods) or different HSN/SAC codes, it must be proportionately distributed. Taxpayers must ensure that the sum of the tax and taxable value across these line items matches the original invoice value exactly to avoid validation errors.
2. Duplicate Document Validation
The system performs a multi-layered check to prevent duplicate claims. Validation is applied based on a combination of the Supplier GSTIN, Invoice Number, Invoice Date, Category of Input Supply, and HSN/SAC. Identical parameters across multiple lines will result in rejection.
3. Reporting ITC Reversals
Compliance with Rules 38, 42, and 43 is mandatory. When using multiple offline utility files, the total reversal amount should only be entered in the final utility file. All preceding files should show zero in the reversal columns. The system will automatically consolidate the Net ITC during the final submission on the portal.
Validation with GSTR-2B
The portal now validates uploaded invoices against the taxpayer's GSTR-2B. However, there is a distinction based on the period of the claim:
- Pre-October 2024 Periods: System validation is not mandatory. While the system may show a generic message stating invoices are not validated, they will still be treated as 'Valid Documents' for refund processing.
- November 2024 Onwards: Strict validation applies. Mismatches will be highlighted in an 'Invalid Documents Report,' which the taxpayer must rectify before proceeding.
Compliance Katta Note: Do not attempt to modify the JSON file manually after generation. Any changes must be made within the Excel utility followed by a fresh JSON generation to maintain data integrity.
Compliance Checklist for Refund Filing
- Ensure you are using the latest version of the Annexure-B Offline Utility from the GST portal.
- Verify that no previous versions of the utility are open on your desktop to prevent copy-paste errors.
- Segregate all inward invoices based on HSN/SAC and Input Category (Inputs/Services/Capital Goods).
- Cross-check ITC reversal amounts with Table 4(B) of your GSTR-3B for the corresponding month.
- Validate that there are no leading or trailing spaces in the Supplier Name or GSTIN fields.
- Check the 'Read Me' section (specifically Point 6) of the utility for updated mapping instructions.
- Ensure the JSON file name remains unchanged after generation from the utility.
Conclusion
The introduction of the Annexure-B Offline Utility is a major step toward a paperless and automated GST refund regime. While it requires a higher degree of data precision—specifically regarding HSN-wise segregation—it significantly reduces the risk of litigation by ensuring alignment with GSTR-2B. Taxpayers must adapt their accounting workflows to capture these details at the entry level to facilitate smooth refund processing.
For expert assistance in navigating these complex GST refund filings, Compliance Katta is your dedicated partner in ensuring seamless compliance and timely credit realization.
Common Questions
Q.What happens if my refund application contains more than 2,50,000 line items?
The current system limit for the Annexure-B Offline Utility is 2,50,000 line items (distributed across 25 JSON files). For any invoices exceeding this limit, you must convert the additional data into a PDF format and upload it as a supporting document under the 'Additional Attachments' section of Form RFD-01.
Q.How should I report an invoice that contains both 'Inputs' and 'Input Services'?
You must split such an invoice into two separate line items in the utility. One line will represent the 'Inputs' portion with its respective HSN/SAC and tax value, while the other will represent the 'Input Services' portion. The total taxable value and tax must be distributed proportionately between the two lines.
Q.Is GSTR-2B validation applicable for refund claims pertaining to 2023 or early 2024?
No, the system does not perform mandatory validation against GSTR-2B for periods up to October 2024. In such cases, the portal will display a generic message indicating that invoices are not validated, but it will still allow those invoices to be part of the 'Valid Documents' list for the refund claim.
Q.Where do I enter ITC reversal details if I am using five different JSON files for one application?
If you are using multiple offline utility files, you must enter the total ITC reversal amount (as per Rules 38, 42, 43, etc.) only in the very last (final) utility file. In all the previous four files, the reversal amounts should be kept as zero to avoid double counting during system consolidation.
Q.Can I copy and paste data into the Annexure-B Offline Utility?
Yes, copy-paste functionality is enabled, including for dropdown values. However, you must ensure that the pasted text matches the dropdown options exactly, without any extra spaces. Also, avoid pasting data into frozen or protected cells, as this can corrupt the utility's validation logic.