Answer

GST

Deficiency memo RFD-03 on an export refund

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  1. Facts

    A deficiency memo in RFD-03 under Rule 90(3) means the application is treated as incomplete. You correct the deficiency and file a fresh application. Circular 37/11/2018-GST says only one deficiency memo should be issued per application.

  2. Provisions and law

    • Rule 90, CGST Rules 2017Acknowledgement RFD-02 or deficiency memo RFD-03 for refund applications
    • Circular 37/11/2018-GSTClarifications on export refunds: BRC or FIRC for services, lower of invoice and shipping bill value, one deficiency memo
  3. Analysis

    The credit debited for the first claim is re-credited when the memo issues, so the fresh claim can debit it again. Read every point in the memo and fix all of them at once, because a second memo is a further delay. Check that the fresh claim is still inside the two-year window for the earliest invoice.

  4. Conclusion

    1. Download RFD-03 and list every deficiency
    2. Check the ledger shows the re-credit
    3. Fix documents and figures for every point
    4. File a fresh RFD-01 for the same period
    5. Keep the earlier ARN and memo on record

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