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Start with the form number. FORM GST RFD-03 is a deficiency memo issued when an application is incomplete; you normally correct the listed defects and file a fresh application. FORM GST RFD-08 is a proposed-rejection notice that calls for a FORM GST RFD-09 reply within 15 days of receipt. FORM GST RFD-06 is the decision order, which may sanction the refund in full or in part or reject it. Treating RFD-03 as a rejection, or answering it as though it were RFD-08, can send the claim into the wrong procedural track.
This guide follows the central CGST refund procedure. State GST procedures are generally aligned, but the actual notice or order, applicable State rules and current amendments control your case.
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Identify the document and stage first
The same refund application can generate different forms at different stages. The form number tells you whether the officer is asking for a corrected filing, proposing to disallow the claim, or issuing a final decision.
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One free scan finds every outdated or missing driver and matches the right update for your exact hardware.Free scan · exact hardware match| Form | Procedural stage | Meaning | Immediate response |
|---|---|---|---|
| RFD-03 Deficiency Memo |
Completeness scrutiny under rule 90 | The application or its supporting material has listed deficiencies that must be rectified. | Correct every listed issue and submit a fresh refund application. Preserve the original ARN and the new filing proof. |
| RFD-08 Notice |
Examination of admissibility or amount | The officer believes all or part of the claim may be inadmissible or not payable and has recorded proposed grounds. | Answer each ground in FORM GST RFD-09 within 15 days after receiving the notice, with indexed evidence. |
| RFD-06 Order |
Decision after examination and, where applicable, the reply | The refund is sanctioned in full or in part, or rejected. | Read the findings, amount and communication date. If adverse, assess appeal rights and the filing deadline immediately. |
The prescribed RFD-03 form itself advises the claimant to file a fresh application after rectifying the deficiencies. You can see the form in the CBIC-published CGST Rules PDF.
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What an RFD-03 deficiency memo means
Rule 90 deals with scrutiny for completeness. When the officer finds deficiencies at that stage, the officer communicates them electronically in RFD-03 rather than deciding the underlying eligibility question. The memo is therefore a repair list, not a final adjudication that the refund is legally unavailable.
How the memo changes your filing task
An RFD-03 does not invite a conventional defence reply. It tells you to fix the application and supporting record and then file afresh. A fresh application is a new submission after correction; it is not merely an email or explanation attached to the old ARN.
Read every line of the memo and map it to the item it concerns. A deficiency may relate to the refund category, a return period, an invoice, an export document, a calculation, a declaration or another attachment. The correct fix depends on the category and on the wording of the memo, so do not substitute a generic document bundle for the specific correction requested.
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- Download and preserve the memo. Save the electronic RFD-03, its date and the ARN of the original application. Record the portal download or communication details.
- Create a deficiency register. Copy each stated defect into a working list. Add the document, schedule, figure or declaration that will cure it. Keep the memo language unchanged in your internal index so the corrected filing can be checked against it.
- Reconcile the underlying data. Check the refund calculation against the relevant returns, electronic ledgers, invoices, shipping or export records, bank evidence and declarations required for that refund category. Correct the source data, not only the attachment label.
- Prepare replacement schedules and evidence. Use the period, invoice numbers, taxable values, tax amounts and other identifiers consistently across the application and supporting records. If a figure has changed, retain a reconciliation showing the old and corrected amount.
- File a fresh application. Submit the corrected claim through the prescribed electronic process and obtain the new ARN or acknowledgment. Confirm that every attachment uploaded successfully and is readable.
- Keep a linked case file. Store the original RFD-01 materials, RFD-03, corrected schedules, evidence, fresh application, new ARN and portal acknowledgment together. This preserves the chronology if the officer later asks how a figure changed.
Limitation-period treatment after a deficiency memo
The amended rules provide that the interval from filing the original RFD-01 claim until communication of RFD-03 is excluded when applying the two-year period in section 54 to a fresh claim filed after rectification. That exclusion has statutory conditions. It does not automatically cure an unrelated late filing, an ineligible refund category or a defect that remains uncorrected. Keep proof of both the original filing and the RFD-03 communication so the dates can be demonstrated.
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What should not happen after RFD-03
- Do not label the memo a rejection order in correspondence or accounts.
- Do not send an RFD-09-style defence as a substitute for the fresh application the memo requests.
- Do not assume the old ARN will continue through the decision stage after a deficiency memo.
- Do not discard the original submission; its date and documents may be relevant to the statutory period and to explaining the correction.
CBIC Circular No. 59/33/2018-GST explains that, after an RFD-03, the claim is to be filed afresh after rectification. It also states that an application not resubmitted after the memo should not proceed to an RFD-04 or RFD-06 order.
What an RFD-08 notice means
RFD-08 is issued at a later stage, after the officer has examined the claim and believes that some or all of the refund may be inadmissible or not payable. The officer must record reasons and give you a chance to answer before deciding the claim. The prescribed rules require the reply in FORM GST RFD-09 within 15 days from receipt of the notice.
Build the RFD-09 reply around the notice
A useful reply mirrors the notice so that each proposed ground has a visible answer. Use the notice number and date, the ARN, the refund category and the relevant period in the opening identification. Then deal with the grounds separately rather than filing a general narrative.
- Identify the proceeding. State the legal name of the claimant, GSTIN, ARN, notice number and date, refund category and tax period. Use the receipt date shown on the portal or other reliable delivery record when calculating the 15-day period.
- Reproduce or accurately summarize ground one. Quote the material wording or identify the paragraph and amount. Avoid answering a broader allegation than the one actually made.
- Give the factual answer. Explain what occurred, which return, invoice, shipping record, ledger entry or bank document establishes it, and why the notice’s figure or assumption is incorrect.
- State the legal basis. Cite the applicable rule, section, notification or category condition that makes the amount refundable. Distinguish a documentary mismatch from a substantive eligibility issue.
- Attach a focused reconciliation. Index each supporting record to the paragraph and amount it proves. A table that ties the claim to returns, invoices, export documents, ledger debits and bank evidence is easier to verify than an unlabelled file bundle.
- Explain every variance. If the notice identifies differences between the claim, returns, ledger, invoices, shipping bills, bank evidence or earlier correspondence, show the amount before and after reconciliation and the reason for the difference.
- Separate admitted and disputed points. If one arithmetic error is accepted but the legal ground is disputed, say so and show the corrected figure. This prevents an avoidable concession from being read as acceptance of the whole notice.
- Request a hearing when useful. Ask for a personal hearing if the facts are complex, a calculation requires explanation or an adverse decision could rest on an issue not fully addressed in writing. Check the notice for any stated hearing date or submission instruction.
- Submit and preserve proof. File RFD-09 through the prescribed portal route before the deadline, download the acknowledgment and retain the complete submitted version with its attachments.
Evidence choices that make a reply usable
- Use one index with continuous page or file numbers.
- Match the description in the index to the language used in the notice.
- Show calculations in the same units and period labels as the refund application.
- Mark documents that replace or correct an earlier document and explain the change.
- Keep portal acknowledgments, upload timestamps and any communication about a hearing with the substantive evidence.
These are organization practices, not additional statutory forms. The notice itself remains the controlling source for the grounds, mode of filing and any hearing particulars.
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How RFD-06 differs from both earlier forms
RFD-06 is the officer’s order after considering the application and, where issued, the RFD-09 reply. It can sanction the entire amount, sanction only part, or reject the claim. Unlike RFD-03, it is not an instruction to repair and refile. Unlike RFD-08, it is not merely a proposal awaiting your response.
Read the order in four passes
- Outcome. Identify whether the order sanctions the full claim, sanctions a reduced amount or rejects it, and record the exact amount in each category.
- Reasoning. Match each rejected or reduced component to the finding, evidence considered and legal provision relied on. Check whether the order dealt with every material point raised in RFD-09.
- Adjustments and withholding. Note any adjustment, withholding or other treatment that changes the amount actually released, not just the amount discussed in the reasoning.
- Communication date. Save the date on which the order was communicated. Appeal periods generally run from communication, so the portal record and order download should be retained.
If the order is adverse
Assess appeal rights promptly with a qualified GST professional. The general section 107 period is three months from communication of the decision or order. An appellate authority may admit an appeal during a further one-month period if it is satisfied that sufficient cause prevented filing within the ordinary period; that extension is discretionary, not automatic.
Confirm the current appellate forum, prescribed appeal form, pre-deposit, calculation of the deadline and filing mechanics for your case. Central and State administration, the type of order and amendments in force can affect those details. Do not wait for an informal clarification before protecting the statutory deadline.
Where the rejected amount goes in the electronic ledger
The rules distinguish a deficiency-stage re-credit from a re-credit after an amount is rejected. Check the actual electronic credit ledger and any PMT-03 order rather than assuming that a credit has appeared.
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| Event | Rule treatment | Record to check |
|---|---|---|
| Deficiencies communicated under rule 90(3) | The amount debited for the claim is re-credited to the electronic credit ledger under rule 93(1). | Electronic credit ledger entry after the RFD-03 process. |
| Amount rejected under rule 92 | The rejected portion is re-credited through FORM GST PMT-03 under rule 93(2). | PMT-03 order and corresponding ledger entry. |
A ledger re-credit does not, by itself, establish that the refund claim was eligible or that every amount has been restored. Reconcile the credited figure to the amount debited, the portion rejected and any other adjustment shown in the order.
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You received RFD-03
Stop preparing a rejection defence. Build the deficiency register, correct the application and records, file afresh and preserve both ARNs and the communication dates. Check the two-year section 54 calculation using the rule’s exclusion for the interval from the original filing to the RFD-03 communication, while testing all other limitation conditions separately.
You received RFD-08
Calendar the 15-day period from receipt, then prepare RFD-09 in the same order as the notice. A complete reply addresses every ground, reconciles every challenged amount and includes an indexed record set. Keep the submission acknowledgment and request a hearing if a written record alone may not resolve the issue.
You received RFD-06
Classify the result as full sanction, partial sanction or rejection; record the communication date; inspect the ledger and PMT-03 treatment where relevant; and obtain advice on an appeal before the three-month section 107 period expires. If seeking the possible additional month, prepare evidence of the sufficient cause rather than assuming it will be granted.
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Records to retain for the entire matter
- Original RFD-01 application, ARN and every uploaded attachment.
- RFD-03 memo, its communication date and the deficiency register.
- Fresh application after rectification, its ARN and portal acknowledgment.
- RFD-08 notice, receipt evidence and the complete RFD-09 reply.
- RFD-06 order, hearing requests, hearing records and subsequent correspondence.
- Return extracts, invoices, export or shipping records, bank evidence, declarations, calculation workpapers and reconciliation schedules used to support the claim.
- Electronic credit ledger entries and any FORM GST PMT-03 order.
Use consistent file names and preserve the original downloaded files. A later appeal or departmental review may turn on what was actually filed, when it was filed and which document supported a particular figure.
Common mistakes and the correction for each
| Mistake | Why it causes trouble | Better approach |
|---|---|---|
| Calling RFD-03 a rejection | It confuses a completeness defect with an adjudicated decision. | Correct the listed defects and submit the fresh application required by the memo. |
| Sending RFD-09 for an RFD-03 | The deficiency memo calls for refiling, not a proposed-rejection defence. | Use the memo as a repair checklist and retain proof of the new filing. |
| Replying to RFD-08 with a general denial | The officer may be unable to connect the response to a particular ground or amount. | Mirror each notice paragraph, provide the legal and factual answer, and index the evidence. |
| Missing the RFD-08 deadline | The rules provide 15 days from receipt for the RFD-09 reply. | Record the receipt date immediately and submit before the deadline shown by that calculation. |
| Ignoring the order’s communication date | The section 107 appeal period is measured from communication of the decision or order. | Preserve the portal communication record and calculate the three-month period at once. |
| Assuming a ledger credit posted | Re-credit treatment differs by stage and may require a PMT-03 order. | Inspect the electronic ledger and PMT-03 record and reconcile the amount. |
Checking the governing material before you act
Refund procedures and deadlines can change through amendments, and State administration may apply additional instructions. Compare the current applicable rules with the actual portal notice or order. The CBIC refund rules page is available at https://cbic-gst.gov.in/gst-refund-rules.html; the prescribed forms and rule text are also published in the CBIC CGST Rules PDF.
The refund rules state that an application should not be rejected without a reasonable opportunity of being heard. If RFD-06 rejects the claim without addressing a material response or without the required opportunity, raise that procedural issue promptly with professional advice and preserve the notice, reply and hearing record.
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