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Your refund application was acknowledged, you waited, and then a new document appeared on the portal: an RFD-08 notice. Nothing has been rejected yet. The RFD-08 notice is a show-cause notice issued under rule 92(3) of the CGST Rules, 2017, in which the refund officer lists the deficiencies he has found and asks why your claim should not be rejected. The claim is still alive. What you file in the next fifteen days, through the RFD-09 reply, usually decides whether the money is sanctioned or the file moves towards rejection.
Three forms decide the fate of a refund application, and applicants routinely confuse them. After you file FORM GST RFD-01, the officer issues an acknowledgement in FORM GST RFD-02, ordinarily within fifteen days. If the application itself is incomplete, rule 90(2) of the CGST Rules, 2017 allows him to issue a deficiency memo in FORM GST RFD-03. A deficiency memo is not a rejection. It means the papers were short, and you file a fresh application after fixing them.
The RFD-08 notice is a different instrument altogether. Once a complete application has been examined and the officer is not satisfied that the refund is admissible, rule 92(3) requires him to issue a notice in FORM GST RFD-08, calling upon you to show cause why the claim should not be rejected. The reply goes in FORM GST RFD-09. Only after considering that reply, and giving you an opportunity of being heard, can he pass an order. If the claim is allowed, the order is in FORM GST RFD-06. If it is rejected, the order is in FORM GST RFD-07.
That sequence matters. An RFD-08 puts the department's case on record so that you can meet it point by point. Treat it as a pleading step, not a post-mortem. The single biggest reason exporters lose at this stage is silence, or a one-line portal reply with no annexures.
Read the notice twice: once for the grounds, once for the documents the officer says are missing. Most RFD-08 notices for export and inverted duty claims fall into three families.
The commonest allegation is a mismatch between what you claimed and what the returns show. Export invoices are reported in Table 6A of GSTR-1, and the officer will compare that figure with the refund statement in FORM GST RFD-01 and with GSTR-3B. If two invoices were reported in the following month because the shipping bills were generated late, the totals will not tie, and the notice will say so. This is a reconciliation problem, not necessarily a false claim, and it is answered with a working sheet, not an argument.
Here the officer questions whether the credit was available at all. Input tax credit on motor vehicles, food and beverages, club memberships and works contract services for immovable property is blocked under section 17(5) of the CGST Act, 2017. Credit on invoices where the supplier never filed GSTR-1 is equally vulnerable, since it will not appear in the auto-generated statement. For inverted duty claims, the attack is usually on the computation itself: net ITC, adjusted total turnover and the exclusion of ineligible credits from the formula under rule 89(5).
Some notices are purely formal: no shipping bill reconciliation, no copy of the letter of undertaking, no evidence of receipt of foreign exchange for services, or a claim that the application is time-barred. A refund application under section 54(1) of the CGST Act, 2017 must be filed within two years of the relevant date, and the relevant date differs for goods, services and inverted duty claims. Check the date before you write a word of reply.
The reply is due within fifteen days of receipt of the notice. Do not treat that as elastic. If you need records from a supplier or a bank, apply in writing for a short adjournment before the period expires, and record the request on the portal. Reply in the refund module on the GST portal, upload the annexures, and keep the acknowledgement along with the attachment list.
Structure the reply para-wise. Quote the deficiency, state your answer, cite the rule, and point to the annexure that proves it. Where a ground is correct, concede it expressly and quantify the reduction. Officers respond well to arithmetic they can verify and poorly to adjectives.
Download the RFD-08 and diarise the fifteenth day from its receipt.
Draft a para-wise reply that answers every ground and cites the relevant rule.
Attach an invoice-wise reconciliation of GSTR-1 Table 6A, shipping bills and the refund statement.
Concede and quantify the portion of credit you cannot defend, instead of arguing all of it.
Upload the reply in FORM GST RFD-09 and save the acknowledgement with the annexure list.
Ask for a personal hearing in the reply itself, and attend it with the original documents.
Filing a covering letter instead of a reply, with the actual explanation buried in a PDF annexure. Remaining silent on a ground you intend to contest later, which reads as acceptance. Re-claiming credit that is blocked under section 17(5) to protect the claim amount. And skipping the personal hearing, when the rules require the officer to give you that opportunity before rejection.
What you attach depends on which refund you claimed. A zero-rated exporter under a letter of undertaking is claiming unutilised credit under section 54(3); an inverted duty claimant is asking for accumulation to be released under the same sub-section on a different basis. The officer's file must show both the export and the credit.
| Claim | What the officer looks for | Where claims usually fail |
|---|---|---|
| Zero-rated goods under LUT | GSTR-1 Table 6A, shipping bill and invoice reconciliation, GSTR-3B, letter of undertaking | Invoice totals that do not tie to the refund statement |
| Zero-rated services | Export invoices, FIRC or bank realisation certificate, statement of foreign exchange received | Payment received in a later period than the one claimed |
| Inverted duty structure | Rule 89(5) computation, net ITC workings, adjusted total turnover | Blocked credits pulled into the formula |
| Excess balance in cash ledger | Ledger extracts, return-wise workings | Claim filed before the return for the period was filed |
A knitwear exporter shipped garments worth ₹82.40 lakh in July 2025 under a letter of undertaking, paying no integrated tax, and filed a refund claim of ₹6,42,180 as unutilised credit on 12 August 2025. On 20 September an RFD-08 raised three grounds: Table 6A of GSTR-1 showed only ₹79.90 lakh; credit of ₹1,86,000 from one supplier did not appear in the auto-generated statement; and no shipping bill reconciliation had been furnished.
The reply, filed on 3 October, attached an invoice-wise sheet explaining that two invoices worth ₹2.50 lakh were reported in August's GSTR-1 because their shipping bills were generated in the first week of August, with extracts from both months. It conceded ₹41,200 of credit relating to the supplier who had not filed his return, and undertook to claim it in a later period once the supplier complied. A shipping bill to invoice mapping for all 46 consignments was annexed. After a hearing on 5 November, the officer sanctioned ₹6,00,980 in FORM GST RFD-06 on 18 November and rejected ₹41,200 by order in FORM GST RFD-07. Because the sanction came after sixty days from the application, the exporter also claimed interest under section 56, where the notified rate is six per cent per annum.
If an RFD-03 deficiency memo was issued, there is nothing to appeal. You correct the defect and file a fresh application, provided the two-year window under section 54(1) is still open. Keep in mind that a fresh application is a fresh queue: the sixty-day clock under section 54(7) starts again.
If an order in FORM GST RFD-07 rejects the claim or part of it, the route is an appeal under section 107 of the CGST Act, 2017, to the appellate authority, ordinarily within three months of communication of the order. The appellate authority may condone a further delay of one month on sufficient cause. Section 107(6) requires a pre-deposit on the tax, interest, fine, fee and penalty arising from the impugned order; on a pure refund rejection, where no demand has been confirmed, the position is contested, so read the operative portion of your order carefully before deciding. A fresh claim on the same facts after a merits rejection is not a substitute for appeal.
The practical choice is commercial. Where the rejected amount is small and the defect is documentary, a fresh claim within limitation is cheaper than litigation. Where the rejection turns on a legal question, such as the treatment of a particular credit in the rule 89(5) formula, the appeal is the only forum that will settle it.
Section 54(7) requires the officer to pass the order within sixty days from the date of receipt of a complete application. Section 56 provides for interest where the refund is not paid within that period. Exporters with a clean compliance record can also seek ninety per cent of the claim as provisional refund within seven days of acknowledgement under section 54(6), though a pending deficiency usually blocks that route.
Follow-up should be documented, not verbal. Track the application by its acknowledgement reference, send written reminders to the jurisdictional refund cell, and keep a dated record of every submission and hearing. If the sixty-day period lapses without an order, a written representation to the jurisdictional Principal Commissioner, enclosing the file, is the standard first step before considering anything stronger.
Your next action is simple: open the RFD-08 today, list each ground on a separate line, and match every line to a document you already hold or can obtain within a week. That gap analysis is the reply.
This article is for general information only and is not legal advice. Consult a qualified professional for your specific facts.
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