GST

Two-year limit after an RFD-03

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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.

Provisions

Sec 54(1), CGST Act 2017; Rule 90(3), Explanation, CGST Rules 2017

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.

Close

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

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