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Freedom251 › Blog › GST Appeal

What to Do When a GST Refund Claim Is Rejected or Delayed

By Freedom251 Team · · 9 min read

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Start by identifying the claim’s procedural stage on the GST Portal. A claim still marked pending needs status and communication checks; an RFD-08 is a proposed rejection that requires an RFD-09 reply within 15 days of receipt; and an RFD-06 is the officer’s order, which may be challenged through the applicable appeal process. Save every notice, order, acknowledgment, amount and communication date before taking the next step.

First identify where the refund claim stands

The correct response depends on whether the application is being processed, a deficiency or clarification has been communicated, a proposed rejection notice has been issued, or a final order has been made. Treating a notice as a final rejection can cause you to miss the response window; treating an order as an ordinary delay can cause an appeal deadline to expire.

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Portal stage or document What it means Immediate action
Pending or processing The application has not yet reached a communicated final decision. Check the application status, acknowledgment, latest communication and bank-account details. Follow up through the official GST channel if the status remains unchanged.
Deficiency or clarification communication The officer has identified an issue that may require correction or additional information. The exact communication controls what you must do. Read every instruction, note the stated date, and respond or correct the application using the route and time limit shown on the portal.
FORM GST RFD-08 A notice proposing that all or part of the refund is inadmissible or not payable. Prepare and submit FORM GST RFD-09 within 15 days of receiving the notice, answering each ground with supporting records.
FORM GST RFD-06 The order allowing all, allowing part, or rejecting the refund after the response and hearing opportunity. Read the findings and amount, preserve the communication date, and promptly verify the applicable appeal forum, procedure and limitation period.

Check the GST Portal and build a complete case file

Use the GST Portal’s refund area to open the submitted application, acknowledgment and all electronic communications. The portal help material explains how to view a saved or submitted application; the labels can change, so rely on the current screen rather than an old screenshot or a third-party guide.

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  1. Open the refund application. Record the ARN or other acknowledgment reference, filing date, refund category, tax period and amount claimed.
  2. Check the status history. Capture the current status and each dated event. A screenshot or downloaded PDF is useful if the status later changes.
  3. Open every notice and order. Do not rely only on an email alert. Download the RFD-08, RFD-06, payment order or other communication and note the date it was made available and the date you actually received it.
  4. Write down the next deadline. For an RFD-08, calculate the 15-day RFD-09 period from receipt. For an adverse order, preserve the communication date because appeal limitation normally runs from communication of the decision or order.
  5. Check payment information. If a payment order has issued, verify the validated bank-account details associated with the refund. An incorrect, closed or unvalidated account can prevent a sanctioned amount from reaching you even when the claim itself is allowed.
  6. Assemble evidence by issue. Keep the filed application, invoices, shipping or export records where relevant to the category, tax-payment records, declarations, reconciliations, ledger extracts, correspondence and proof of receipt in one indexed folder. Submit only records that address the stated refund grounds.

If you received an RFD-08 notice

The 15-day RFD-09 deadline

Under the refund rules, when the proper officer considers all or part of a claim inadmissible or not payable, the officer issues FORM GST RFD-08 and requires a FORM GST RFD-09 reply within 15 days of receipt. Count from the date the notice was received or made available to you as evidenced by the portal and your records. If the deadline is close, submit a complete, readable response rather than waiting for a perfect narrative, and keep the filing acknowledgment.

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Answer every proposed ground separately

Use the notice as an issue list. For each paragraph or reason, state whether you accept or dispute it, identify the exact document that supports your position, and explain the calculation. If the officer questions eligibility, connect the legal requirement to the transaction records. If the issue is a mismatch, reconcile the figures line by line and identify the return, invoice or ledger entry that resolves it. If only part of the claim is affected, show the amount you say remains admissible instead of replying only with a general objection.

Make the evidence easy to verify

  • Use a contents page and numbered annexures that match references in the reply.
  • Provide legible invoices, returns, payment evidence and reconciliations for the disputed period.
  • Explain differences between the refund application and accounting or return figures; unexplained variances can make an otherwise relevant document unpersuasive.
  • State assumptions, calculation dates and currency or tax amounts clearly.
  • Keep the original files and proof of upload after filing the RFD-09.

A reply does not guarantee that the refund will be sanctioned. The officer may accept all, accept part, or reject the claim after considering the response.

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Use the hearing opportunity

The rules state: “Provided that no application for refund shall be rejected without giving the applicant a reasonable opportunity of being heard.” If the notice or subsequent communication offers a hearing, attend through the authorised representative or responsible finance officer, carry the indexed evidence, and ask that the submissions and documents be taken on record. Record the hearing date, attendees and any additional document requested. If no reasonable opportunity appears to have been provided before an adverse order, preserve that fact for professional advice and any challenge.

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If an RFD-06 rejects all or part of the claim

Read the order, not just the status label

FORM GST RFD-06 is the decision after the officer considers the reply. It can allow the entire claim, allow only part, or reject it. Read the findings, the amount allowed and rejected, the reasoning for each issue, adjustments to the calculation and the date and method of communication. Compare the order with your RFD-09 and its annexures; an order that ignores a material submission or misstates the figures should be identified precisely, not described only as “wrong.”

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Protect the appeal limitation period

The general CGST Act appeal route provides three months from communication of the decision or order, with a possible further one month where sufficient cause prevented timely filing. This is a general statutory framework, not a promise that every refund dispute follows the same forum or form. Verify the live Act, rules, applicable notifications and the correct appellate authority for the particular order. Obtain advice promptly where the issue involves classification, export evidence, unjust-enrichment analysis, limitation, documentary authenticity or a substantial amount.

Do not wait for an informal email exchange to decide whether the limitation clock has started. Save the communication record, calculate the last ordinary filing date, and allow time for preparing grounds, compiling exhibits, paying any required amount or fee and correcting portal validation errors.

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Prepare an appeal file

  • RFD-06 and proof of its communication.
  • The original refund application, acknowledgment and statement of claim.
  • RFD-08, RFD-09, hearing notices and proof of submissions.
  • A ground-by-ground schedule showing the amount disputed and the evidence supporting it.
  • Relevant returns, invoices, contracts, shipping or payment records and reconciliations.
  • A chronology of filings, portal events and officer communications.

A qualified GST practitioner or chartered accountant can help assess the evidence, frame grounds and select the correct procedure, particularly where the order is partly adverse or the facts are disputed. Professional assistance does not replace checking the current statutory text and portal requirements.

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Understand re-credit after rejection

The refund rules provide for an amount rejected from a refund claim to be re-credited to the electronic credit ledger through FORM GST PMT-03, subject to the conditions in the rule and the order becoming final where required. Re-credit restores eligible credit to the ledger; it is not the same as a cash refund to your bank account. Check the electronic credit ledger and the PMT-03 record, and reconcile the re-credited amount with the rejected portion. If the credit does not appear as expected, keep the order and ledger extracts when raising the issue through the official channel.

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If the GST refund is delayed

Use the published 90-day standard carefully

CBIC’s citizen charter search result states a 90-day disposal period for GST refund claims. This is a published service standard, not an individual guarantee that every claim will be paid within 90 days. It also does not by itself prove that a claim is legally payable or that an appealable order has been made. Use the standard as a trigger to check the file, not as a substitute for reading the portal record and applicable rule.

Follow a documented escalation sequence

  1. Confirm that the application was successfully submitted and acknowledged, rather than left saved or technically incomplete.
  2. Check for an RFD-08, deficiency communication, hearing notice or RFD-06 that may have been overlooked.
  3. Verify that the bank account is the account associated with the claim and is capable of receiving the payment.
  4. Raise the issue through the official GST help or grievance route, attaching the ARN, status history, dates and concise description of the missing action.
  5. Keep ticket numbers and replies. If the matter remains unresolved or an adverse order is issued, obtain advice on the next statutory or administrative step.

Assess interest under section 56 without assuming entitlement

Interest under section 56 can be due on a delayed refund when the legal conditions are satisfied. The rules contemplate an order specifying the delayed amount, the period of delay and the interest payable where interest is due. Do not calculate or promise interest merely because the 90-day charter period has passed. Check the refund category, statutory trigger, exclusions, dates attributable to the taxpayer or department, and the wording of the eventual order. Preserve evidence of filing, deficiencies, replies and any period for which information was outstanding.

When the refund is sanctioned

For an allowed claim, the rules provide for an RFD-06 sanction order and an RFD-05 payment order or advice. Read both documents and reconcile the sanctioned amount with the application. Confirm that the bank details are correct and that the payment has actually credited. If the order sanctions only part of the claim, treat the rejected balance separately: check the stated reason, any PMT-03 re-credit and the appeal option. A sanctioned order and a bank credit are related but distinct events, so keep the payment advice and bank statement together.

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Common mistakes that make a refund problem harder

  • Missing the notice. Checking only email and not the portal can cause the RFD-09 period to run unnoticed.
  • Sending a generic denial. A paragraph saying “all documents attached” does not answer the officer’s individual grounds or calculations.
  • Ignoring partial rejection. Separate the allowed, rejected and disputed amounts; an appeal may concern only one component.
  • Losing the communication date. The date an order was communicated is central to limitation analysis.
  • Confusing ledger credit with cash. PMT-03 re-credit increases the electronic credit ledger subject to the rule; it is not a bank payment.
  • Relying on an old form or deadline. Portal labels, rules and procedures can be amended. Verify the current official text before filing.
  • Overlooking bank validation. Payment can fail after sanction if the account details are wrong or unusable.
  • Destroying the audit trail. Keep submission receipts, downloaded notices, hearing records, ticket numbers and ledger statements in a dated folder.

A practical decision checklist

Use this sequence whenever a GST refund appears stuck or rejected:

  1. Identify the exact portal stage and download the latest communication.
  2. Record the ARN, filing date, receipt or communication date, claim category and amount.
  3. Determine whether the next action is a clarification, RFD-09 reply, payment follow-up or appeal.
  4. Meet the stated deadline first; then improve the file with a clear chronology and indexed evidence.
  5. For an RFD-06, calculate the general three-month appeal period from communication and verify the current forum and procedure, including whether a further one-month condonation request may be available for sufficient cause.
  6. Check whether a rejected amount has been re-credited through PMT-03 and distinguish that credit from a cash refund.
  7. Escalate to a qualified GST professional when the facts, evidence, limitation or amount make a procedural error costly.

The safest approach is procedural discipline: read the document actually issued, answer the stated issue within its deadline, preserve proof of every communication, and verify the current law before relying on a time limit or interest calculation.

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