GST
Common reasons for a refund deficiency memo
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Facts
Typical reasons are missing statements such as Statement 3 or 5, missing invoices or FIRCs, no undertaking or declaration, missing CA certificate where required, and bank account not validated. Wrong refund category is also common.
Provisions and law
- Rule 89, CGST Rules 2017Refund application in RFD-01 with the documents and statements prescribed for each refund type
- Rule 90, CGST Rules 2017Acknowledgement in RFD-02 or deficiency memo in RFD-03 within 15 days; after a deficiency memo a fresh application is filed
Analysis
Each refund type has its own document list in Rule 89 and CBIC circulars. Example: for an export of services refund, you need the export invoices, FIRCs or BRCs, Statement 3, the LUT and an undertaking. For refunds above Rs 2 lakh in some categories, a CA certificate on unjust enrichment is needed. A checklist before filing avoids RFD-03.
Conclusion
- Pick the correct refund category
- Use the document checklist for that category
- Upload statements in the portal format
- Validate the bank account before filing
- Review the application once before submission
A Savvy can do this for you
Reply to refund deficiency memo RFD-03 and notice RFD-08
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