A GST refund application in Form RFD-01 is the start of a process, not the end. The proper officer may issue a deficiency memo in RFD-03, seek further documents, or sanction the refund in RFD-06. The Calcutta High Court has held that refund denials cannot be sustained unless deficiencies are effectively communicated electronically via the GST portal, and that the two-year limitation under Section 54(1) is suspended between the RFD-01 filing and a valid RFD-03. The Bombay High Court has held that interest at 6% is payable if the refund is not granted within 60 days from the original application.
The RFD-01 Document Set
The document set varies by category. For export of services with LUT, the documents include the export invoices, FIRC/bank realisation, LUT, GSTR-1, GSTR-3B and Statement 3A. For accumulated ITC on export, the documents include the shipping bills or export invoices, e-BRC, GSTR-2B and the ITC ledger. The taxpayer should prepare the checklist against Rule 89(2) before filing.
The Deficiency Memo and Refiling
A deficiency memo requires a fresh application after cure. The taxpayer should cure each defect and refile with the complete set. The Calcutta High Court has permitted refiling where the deficiency memo was not properly communicated. The taxpayer should retain proof of the filing and the communication.
The 60-Day Interest Clock
The 60-day period for interest runs from the original refund application. A delayed processing that crosses the 60-day mark attracts interest. The taxpayer should track the application date and should claim interest where the refund is delayed.
What the Consultant Does
The consultant prepares the document set, files the application, follows up on the deficiency memo and claims interest. The value is in the complete first filing and the persistent follow-up that converts a pending application into a sanctioned refund.
Call to Action: We advise businesses on GST refund applications, deficiency memo responses and interest claims. For a refund-specific engagement, contact office@anujdesaiassociates.com, Ph No. 9619456656, Website https://anujdesaiassociates.com, LinkedIn linkedin.com/in/ca-anuj-desai-122547230.