GST
Provisional refund of 90 percent not given
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Facts
From 1 October 2025, provisional refund of 90 percent is given within 7 days of acknowledgement based on system risk assessment, for zero-rated and certain other claims. High-risk claims can be withheld with reasons. Some persons, such as those without Aadhaar authentication, are not eligible.
Provisions and law
- Rule 91(2), CGST Rules 2017Provisional refund of 90 percent for eligible claims, from 1 October 2025 based on system risk assessment
- Sec 54(6), CGST Act 2017Provisional refund of 90 percent on zero-rated supply claims
Analysis
Example: an exporter files a Rs 20 lakh refund and gets RFD-02, but no RFD-04 after 7 days. Possible reasons are high risk rating, pending proceedings, or Aadhaar authentication not done. Ask the officer in writing for the reason. Withholding provisional refund does not mean final rejection; the final order should still come within 60 days.
Conclusion
- Check whether RFD-02 was issued
- Check Aadhaar authentication status in your profile
- Ask the officer in writing why provisional refund was withheld
- Prepare for any RFD-08 queries
- Track the 60-day final order date
A Savvy can do this for you
Reply to refund deficiency memo RFD-03 and notice RFD-08
₹3,999
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