GST
Only one deficiency memo per application
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Facts
CBIC circulars say deficiencies should be listed in one go, and a fresh application filed after a memo should not get a new memo for issues not raised earlier, except where there is a new problem. Repeated memos have been held improper by courts.
Provisions and law
- 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
- Circular 125/44/2019-GSTGuidance on refund processing, including deficiency memos and the bar on new grounds after acknowledgement
Analysis
Example: the first memo asked for FIRCs; after refiling, a second memo asks for a purchase register that was attached the first time too. Write to the officer citing the circular and the earlier filing, and ask for acknowledgement. The Karnataka High Court in 2025 held repeated deficiency memos beyond the statutory period to be illegal.
Conclusion
- Compare the new memo with the earlier one
- Check if the new point is genuinely new
- If not, reply in writing citing the circular
- If genuine, fix it and refile
- Escalate to a senior officer if memos keep repeating
A Savvy can do this for you
Reply to refund deficiency memo RFD-03 and notice RFD-08
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