RFD-08 is a proposed rejection requiring a substantive reply
Rule 92(3) requires an RFD-08 notice where the proper officer is satisfied, for recorded reasons, that all or part of a refund is inadmissible or not payable to the applicant. The applicant must furnish RFD-09 within fifteen days of receipt. After considering the reply, the officer makes RFD-06 allowing all or part or rejecting the claim. The proviso requires an opportunity of hearing before rejection. This guide uses the Central GST rules checked on 26 October 2026 and does not assume that acknowledgment established final entitlement. ICAI statutory compilation: Rules 90, 92(3), 93 and 94(2).
Distinguish the notice from a deficiency memo
RFD-03 under Rule 90 addresses deficiencies and a corrected fresh application. RFD-08 under Rule 92(3) raises proposed inadmissibility or non-payability. Do not automatically abandon an acknowledged claim and file a duplicate fresh claim instead of answering its rejection notice. Read the actual document and grounds; a generic portal status description cannot replace the notice text.
Map the disputed amount to each legal ground
Separate an arithmetic discrepancy, missing proof, time-limit objection, category eligibility and a contention that the amount is not payable to the applicant. For each, identify the specific statutory condition, facts, evidence and relief sought. Reconcile the refund formula or tax amount to the filed claim and avoid asserting eligibility solely because invoices exist. Where grounds overlap, do not add the same disputed amount twice.
Control receipt, reply and hearing separately
Save the received notice, portal timestamp and service evidence. Diary the fifteen-day requirement from the legally relevant receipt event, applying the governing counting rules. Submit a reasoned RFD-09 with indexed attachments and preserve filing proof. A hearing request and evidence of the offered/held hearing should be retained separately; filing a reply is not proof that every hearing issue was dealt with. If time is insufficient, make a supported request promptly without assuming that an extension is automatic.
Reconcile the order without treating sanction as bank cash
RFD-06 may allow all or part or reject the claim. Compare the decision with the notice grounds, filed reply and final amount. Separate amounts sanctioned, adjusted, provisionally refunded and actually disbursed. For relevant electronic-credit-ledger debits, Rule 93(2) provides recredit to the extent of rejection through PMT-03, with its explanation concerning final rejection of appeal or a written undertaking not to appeal. Do not give such an undertaking as a routine administrative step before deciding the remedy.
Keep the next remedy and interest working distinct
A final rejection, a withholding order and a deficiency memo have different consequences. Preserve the operative order and receipt evidence for any separately applicable appeal. Rule 94(2) separately excludes specified applicant-delay periods beyond fifteen days after RFD-08 receipt, including late reply/additional documents, from the delayed-refund interest period. A timely reply is therefore an important control, but this article does not compute automatic interest or waive appeal conditions. The illustrations use simple calendar/elapsed-day controls, not a universal service-law determination.
Applicable primary references
ICAI statutory compilation: Rules 90, 92(3), 93 and 94(2)
Six worked illustrations
All facts and amounts below are fictional. Assumptions describe the model, not additional statutory rules.
Illustrative example 1: Response-date control
Notice receipt is assumed to occur on 1 October 2026. Adding fifteen calendar days gives 16 October 2026 as the illustrative diary date. Confirm actual service, date-counting and any applicable holiday rules before using it as a legal last date; an internal reminder is not a filed reply.
Illustrative example 2: Part of the claim is contested
A claim is ₹5,00,000 and the notice disputes ₹1,20,000. The arithmetically undisputed portion is ₹3,80,000. That split organises the reply; it is not proof that ₹3,80,000 has already been sanctioned or paid.
Illustrative example 3: Overlapping objections
A notice lists a ₹70,000 eligibility objection and a ₹50,000 document objection, but ₹20,000 of the same claim appears in both. The unique disputed amount is ₹1,00,000, not ₹1,20,000. The reply must answer both grounds without duplicating the monetary exposure.
Illustrative example 4: Evidence closes part of a ground
A ₹90,000 objection is reconciled to ₹60,000 supported by existing records and ₹30,000 still unresolved. The reply should identify both portions and their evidence status. A two-thirds document success does not justify describing the whole ₹90,000 as established.
Illustrative example 5: Order-to-receipt bridge
Assume the final valid order sanctions ₹2,80,000, of which ₹50,000 was provisionally refunded and ₹20,000 is validly adjusted against dues. Remaining payable cash is ₹2,10,000. Reconcile the actual bank receipt rather than booking another ₹2,80,000 receipt.
Illustrative example 6: Late-response interval
An RFD-08 is received on 1 June 2026 and RFD-09 is filed on 21 June 2026: twenty elapsed days later. The interval exceeds fifteen days by five days. Review Rule 94(2)’s applicable exclusion with actual service/counting facts rather than assuming all twenty days qualify for refund interest.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Read the complete RFD-08 | Notice grounds, amount, period and authority. |
| 2 | Establish receipt and response control | Service evidence and fifteen-day diary. |
| 3 | Link the filed claim | ARN, category, computation and attachments. |
| 4 | Separate and deduplicate grounds | Ground-wise unique disputed amounts. |
| 5 | Identify the applicable legal condition | Actual Act/rule/notification supporting each response. |
| 6 | Prepare the evidence index | Invoice, payment, return and eligibility cross-references. |
| 7 | File RFD-09 and preserve proof | Submitted reply and attachment copies. |
| 8 | Preserve the hearing record | Request, opportunity, submissions and minutes/evidence. |
| 9 | Reconcile RFD-06 and any ledger action | Sanction, rejection, PMT-03 conditions and remedy decision. |
| 10 | Close disbursement and next steps | Bank receipt, valid adjustments, appeal and separate interest review. |
Sixteen practitioner FAQs
1. Is RFD-08 already a final rejection order?
No. It is the notice contemplated by Rule 92(3) before the decision.
2. Which form is used for the reply?
FORM GST RFD-09.
3. What is the stated response period?
Fifteen days from receipt of the notice, subject to correctly establishing that event and applicable counting rules.
4. Is RFD-03 the same procedure?
No. It concerns deficiencies and corrected fresh filing under Rule 90.
5. Should the reply address legal grounds or only invoices?
Both. Link each challenged statutory condition to the actual facts and evidence.
6. Can overlapping objection values simply be added?
No. Reconcile the unique disputed amount while answering every ground.
7. Does an earlier acknowledgment guarantee entitlement?
No. Completeness acknowledgment and substantive refund eligibility are different.
8. Can a claim be partially sanctioned?
Rule 92(3) expressly contemplates sanction in whole or part as well as rejection.
9. Is a hearing required before rejection?
The proviso requires an opportunity of being heard.
10. Does filing RFD-09 itself prove a hearing occurred?
No. Preserve the actual opportunity and hearing record separately.
11. Is a requested extension automatically granted?
Do not assume so. Make and follow up a supported request promptly.
12. Which form records the final decision under this rule?
FORM GST RFD-06.
13. Is sanction identical to a fresh bank receipt?
No. Reconcile provisional refunds, valid adjustments and actual disbursement.
14. Is rejected ITC recredit always unconditional immediately?
No. Read Rule 93 and its explanation before assuming PMT-03 entitlement or abandoning an appeal.
15. Can delay in replying affect refund interest?
Rule 94(2) contains the specified applicant-delay exclusions; analyse the actual period and facts.
16. Does this article settle an appeal’s deadline or preconditions?
No. Examine the actual final order, service and separately applicable appellate law.
Conclusion
Prepare a ground-wise RFD-09 reply to a proposed refund rejection, reconcile the contested amount and preserve the hearing and final-order trail.
Sources and primary references
CBIC refund guidance: RFD-08, RFD-09 and the hearing opportunity; Notification 38/2023-Central Tax, clause 14: Rule 94(2), effective 1 October 2023.