GSTAT Ernakulam Allows Singapore Airlines' ₹45.92 Lakh GST Refund Claims For Cancelled COVID-Era Flights

The Goods and Services Tax Appellate Tribunal (GSTAT), Ernakulam Bench, has recently allowed Singapore Airlines' claims for a ₹45.92 lakh GST refund on tickets for flights cancelled during the COVID-19 pandemic.

The tribunal found that the airline had refunded passengers the full ticket fare, including GST.

“The appellant-airline is eligible for the refund of GST collected from the passengers and paid by them to the GST Department, but subsequently refunded entire amount of fare including GST to the passengers, on account of cancellation of the flights due to the COVID-19 pandemic in terms of Hon'ble Supreme Court's order,” the tribunal observed.

The bench comprising Vice President Subramanya Rayaprol and Technical Member Ramamoorthi Sriram found that the airline had provided sufficient evidence to establish that the refunds had reached the passengers directly.

The dispute arose after COVID-19-related flight cancellations led Singapore Airlines to refund passengers the full ticket amount, including GST. The airline issued credit notes for the cancelled tickets but could not fully adjust them against its GST liability because refunds exceeded sales during the relevant period. Its GST returns did not permit it to report a negative balance.

The airline then sought a refund of the GST it had already paid to the government. The GST authorities rejected the claims, holding that the airline had not provided sufficient documents to establish excess tax payment or prove that passengers had received the full refunds.

The appellate authority also held that the credit notes were time-barred and that the airline had failed to establish a link between the cancelled tickets, passengers, and refunds.

Singapore Airlines relied on sample air tickets, tax invoices, refund vouchers, credit notes and corresponding Billing Settlement Plan records to establish the refunds. The tribunal found that passenger names and ticket numbers connected the documents, allowing the cancelled tickets to be traced to the refunds.

It criticised the authorities for failing to properly examine the records and rejecting the claims on “flimsy grounds”.

The tribunal also relied on a clarification issued by the Central Board of Indirect Taxes and Customs (CBIC) in April 2020. The clarification allows registered businesses to claim a refund under the category of excess tax payment when they have no output tax liability against which to adjust credit notes. The tribunal held that Singapore Airlines had followed the prescribed procedure.

The tribunal also rejected the objection concerning the reversal of input tax credit (ITC). It found that the tickets were issued to individual passengers in business-to-consumer transactions, so the question of ITC reversal did not arise. It noted one business-to-business transaction involving Balmer Lawrie & Co Ltd.

The tribunal further held that the requirement to reverse ITC attributable to credit notes, introduced from October 1, 2025, did not apply to the airline's refund claims for the earlier periods.

It set aside the order rejecting the claims and allowed all eight appeals filed by Singapore Airlines. The tribunal directed the GST authorities to process the refunds within two weeks and pay applicable interest from the dates of the original applications until payment. The claims totalled ₹45.92 lakh.

For Singapore Airlines:  Rajiv Pal Puri, Chartered Accountant,

For Revenue: Baiju Daniel, Authorised Representative