FIRCs need not match Transaction-wise if Periodic remittance is proven and quashes demand, denial of ITC

Last updated: 28 October 2025

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The Delhi High Court has ruled that exporters do not need to provide invoice-by-invoice Foreign Exchange Realisation Certificates (FIRCs) for GST refunds. The court found that periodic remittance, supported by total benefit claimed, is sufficient proof of foreign exchange realisation. This decision quashes a demand and denial of Input Tax Credit made by CGST authorities against an exporter, stating that the rejection order was vague and failed to properly consider submitted documents.

Court :
Delhi High Court

Brief :
The Hon'ble Delhi High Court in the case of Transformative Learning Solutions Pvt. Ltd. v. Commissioner, CGST Delhi East &Anr. [W.P.(C) 4987/2025 &CM APPL. 22937/2025, order dated September 24, 2025] held that foreign exchange realization certificates (FIRCs) submitted by exporters need not match invoice-wise or transaction-wise, and that periodic remittance supported by total benefit claimed is sufficient for GST refund.

Citation :
W.P.(C) 4987/2025 &CM APPL. 22937/2025, order dated September 24, 2025]

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Attached File : 671907_5889_transformative_learning_solutions_pvt_ltd.pdf

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Judgement posted by

Bimal Jain

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FCA, FCS LLB with21 Yrs of Experience inTaxation Indirect and Direct: Education Qualification: B.Com (Hons) Chartered Accountants Company Secretary LLB Qualified SAP FI/CO Consultants Professional Membership: Chairmanof Indirect Tax Committee of PHD Chamber of Commerce Member of Indirec ... Read more

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