Answer

1. F

   Facts

   The time between filing the original application and receiving RFD-03 is excluded when computing the two-year limit for the fresh application. Courts have also held that a rectified application continues the original claim.

2. P

   Provisions and law

   • Sec 54(1), CGST Act 2017Refund application must be made within two years from the relevant date
   • Rule 90(3), Explanation, CGST Rules 2017Time from filing the original application to the deficiency memo is excluded from the two-year limit for the fresh application
3. A

   Analysis

   Example: relevant date 1 November 2024, two years end 31 October 2026. You filed on 1 October 2026 and got RFD-03 on 14 October 2026. The 13 days are excluded, so the fresh application can be filed up to about 13 November 2026. The Gujarat High Court in 2025 held that a rectified application is a continuation of the original timely claim. Still, refile quickly.

4. C

   Conclusion

   1. 1Note the relevant date and the original filing date
   2. 2Compute the period excluded until RFD-03
   3. 3File the fresh RFD-01 within the extended date
   4. 4Mention the original ARN and RFD-03 in the new application

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