GST
Time limit for the officer to issue RFD-03
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Facts
Rule 90 requires the officer to check completeness and issue either an acknowledgement in RFD-02 or a deficiency memo in RFD-03 within 15 days of filing. A memo issued much later can be challenged.
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
- Sec 54(7), CGST Act 2017Refund order to be issued within 60 days of receipt of a complete application
Analysis
High Courts have criticised repeated or late deficiency memos that hold up refunds. Example: a refund of Rs 5 lakh filed on 1 June gets RFD-03 on 26 June for a document already attached. You can write to the officer pointing out the delay and that the application was complete, and ask for acknowledgement. If needed, a High Court writ is possible, but first try the written route.
Conclusion
- Note the filing date and the RFD-03 date
- Check whether the deficiency is real
- If real, fix and refile quickly
- If not real or late, write to the officer with proof and ask for acknowledgement
A Savvy can do this for you
Reply to refund deficiency memo RFD-03 and notice RFD-08
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