GST refund deficiency memo: RFD-03, RFD-08 and your next step

Read the form number before taking action. An RFD-03 deficiency memo requires a corrected, fresh refund application. An RFD-08 show-cause notice requires a reply in RFD-09. An RFD-06 is the sanction/rejection order. These are different stages, with different next steps.

This guide covers the procedural choices for a service-export refund under LUT. The example below is wholly fictional.

For the full journey, including saved drafts, processing deadlines and our experience of a delayed RFD-03, see refund stages and timelines.

1. Download the communication and identify the stage

On the GST portal, open Services → User Services → View Notices and Orders. Find the relevant notice, select View and open its case details. Save the form and every attachment. The current dashboard manual notes that additional notices have been merged into this view. GST portal: viewing notices and orders.

Record the ARN, form number, issue/receipt dates, claim period, disputed amount, stated deadline and any hearing details.

Form received	What it means	Next action
RFD-03	Deficiencies identified in the application	Rectify them and file a fresh RFD-01 for the same period
RFD-08	The officer proposes to disallow all or part of the claim	Answer the reasons through RFD-09 within the applicable reply period
RFD-06	The officer has made the sanction/rejection decision	Read the reasons and amounts; a rejected portion needs an order-stage review

The electronic workflow distinguishes these forms. An RFD-08 heading mentioning “rejection” does not mean a final rejection order has already been made. GSTN: refund-processing forms.

2. RFD-03: correct the pack, then file afresh

The original application stops being processed after RFD-03. Correct its deficiencies and submit a fresh RFD-01; the replacement receives a new ARN. Keep both applications and the memo together. RFD-09 is not the correction route for a deficiency memo. Circular 125/44/2019-GST, paragraph 10.

The completeness check ordinarily has a 15-day window from filing. CBIC also says a deficiency memo should not be issued after RFD-02 acknowledgement. If that sequence has occurred, retain both forms and have the procedural issue reviewed; do not simply ignore the new communication. Circular 125, paragraph 9.

Example: turn three deficiencies into a correction list

Assume an invented claim seeks ₹18,000, supported by ₹45,000 of completed, realised service exports. The memo identifies an unreadable certificate, missing invoice-to-receipt allocation and an unexplained ITC difference.

Deficiency	Evidence and correction	Check before refiling
Bank certificate cannot be read	Replace the attachment with a legible copy of the genuine certificate	Reference, date, currency and amount are readable
One ₹45,000 receipt supports two invoices without an allocation	Add a working showing ₹30,000 against one invoice and ₹15,000 against the other	Allocations total ₹45,000; the receipt is counted once
Annexure B shows ₹21,000 eligible ITC but the computation uses ₹18,000	Attach the credit bridge: ₹21,000 less ₹3,000 of otherwise eligible capital-goods credit	Asset classification, returns and refund Net ITC agree

The last row explains a correct difference under the example’s assumptions. If review finds an actual error, correct the affected statement and computation instead. Do not alter an invoice or certificate to make totals agree.

Number the corrected attachments and add their filenames/pages to the list. Use the Statement 3 example for the receipt allocation and the refund calculation guide for the computation bridge. Then compare the fresh application’s preview with the complete claim pack, including every correction.

3. Check the refiling deadline separately

A fresh ARN does not restart the two-year limitation period. Rule 90(3)’s proviso excludes the interval from filing the original RFD-01 to communication of RFD-03 when determining limitation for the corrected fresh claim. It was inserted by Notification 15/2021–Central Tax, clause 2(ii)(a).

For example, if filing was on 10 July and the memo was communicated on 22 July, record that interval in the limitation working. Time spent correcting the pack after communication is not covered by this exclusion. Establish the relevant date and remaining filing time before delaying the fresh application. The officer’s 15-day completeness-check period is not a universal taxpayer refiling deadline.

Use the claim-period guide to organise the period and prior-claim records.

4. RFD-08: reply to the stated reasons

Rule 92(3) requires RFD-09 within 15 days of receipt of the notice and requires an opportunity to be heard before rejection. Record the actual receipt date and the deadline/hearing shown; resolve any discrepancy promptly with your preparer. CGST Rule 92(3).

Build the reply around each numbered allegation: the fact being questioned, your explanation, the supporting document/page and any correction or amount accepted. A general statement that the claim is valid does not answer a specific missing-evidence or calculation issue.

Open the refund case’s RFD-09 reply facility, attach the evidence, preview and complete electronic filing. Save the filed reply and confirmation. GSTN requires the reply through RFD-09; sending documents informally is not a substitute. GSTN: electronic RFD-09 replies.

5. Check what happened to the debited credit

For RFD-03, the amount debited for the deficient claim is recredited automatically; a PMT-03 order is not required. Compare the original debit and recredit by tax head in the Electronic Credit Ledger. If missing, retain the ARN, memo and ledger extract for the officer/GSTN support query. Circular 125, paragraph 10.

For an amount rejected by an order under Rule 92, Rule 93 provides recredit through PMT-03, with its appeal-related condition: final rejection of the appeal or a written undertaking that no appeal will be filed. Have that choice reviewed before signing an undertaking. Recredit itself does not establish that the underlying ITC is eligible. CGST Rule 93.