Replying to RFD-08: the refund rejection notice
A refund rejection is an adjudication. It deserves a reply built like one, because the appeal will be decided on this record.
RFD-08 is a notice proposing rejection of a refund claim, in whole or in part. The reply is filed in RFD-09 within fifteen days, and the order follows in RFD-06. A rejection order is appealable under Section 107. The reply must answer each ground with a document, must ask for a personal hearing, and must deal with the composition of the claim line by line, because a partial sanction is frequently the best realistic outcome.
The grounds that appear in almost every RFD-08
The claim exceeds the credit available, or the formula has been applied incorrectly. This is arithmetic, and it is answered with a computation.
Invoices claimed are not reflected in GSTR-2B, or relate to suppliers who have not filed. Answered with the reconciliation and the invoice level annexure.
Documents prescribed by the rules have not been furnished. Answered by furnishing them with the reply, and by pointing to what was uploaded and when.
The supply is not a zero rated supply, or the recipient is not outside India, or the service is an intermediary service. This is the substantive ground and it requires the agreement, the invoice, the remittance and the characterisation argument.
Limitation. Answered with the relevant date computation.
How to build the reply
A table of grounds, with the answer and the annexure reference for each. Officers deciding refunds work under volume; a table is read and a narrative is skimmed.
A restated computation of the claim, showing the amount you accept as not admissible, if any, and the amount you press. Conceding a genuinely inadmissible portion improves the credibility of the rest.
The full set of prescribed documents, re uploaded, with a covering index.
A request for a personal hearing. Refund rejections are frequently passed without a hearing and that is a clean appeal ground on the Section 75(4) line of reasoning applied to refund adjudications.
A reservation of the right to file a fresh application where the rejection is on a curable ground, so that the limitation position is protected.
After the order
Check whether the order deals with each ground and each document. An order that recites the notice and rejects without reasons is vulnerable.
Check whether the rejection is total or partial, and whether the sanctioned portion has been paid with interest.
Where the ground is curable and the two year period has not expired, consider a fresh application in parallel with the appeal.
Diarise the appeal limitation immediately; refund rejections are the most commonly abandoned appealable orders in GST.
What to do on Monday
Answer RFD-08 with a grounds table and an annexure index, not a letter.
Restate the computation and concede any genuinely inadmissible portion expressly.
Ask for a personal hearing in writing in the reply itself.
Diarise the appeal date on the day the rejection order is received.
This page states the general position. A reader with a specific question on their own facts may write to the GST practice at AMLEGALS.
Write to the GST practiceQuestions we are asked on this
How long do we have to reply?
Fifteen days from the notice, in RFD-09. Ask for an extension in writing if documents must be obtained from abroad.
Is a hearing required before rejection?
The rules contemplate an opportunity, and a rejection without one is a strong appeal ground. Ask for it expressly in the reply.
Can we refile after a rejection?
Where the rejection is on a curable procedural ground and limitation permits, yes. Where it is on the merits, the route is the appeal.
Is the partial sanction paid while the rest is contested?
It should be. Where it is not, write for it and claim interest.
Does an appeal against a refund rejection require a pre-deposit?
The pre-deposit is computed on tax in dispute. In a refund rejection there is usually no tax demand, and the position should be verified for your order.
In this cluster
- GST refunds: every category, every form, every deadline
- Export refunds: the LUT route versus the IGST route
- VKC Footsteps: why input service tax stays stuck in an inverted duty structure
- Provisional refund of ninety percent: the mechanism and how to keep it
- Deficiency memos in RFD-03 and the limitation reset problem
- Interest on delayed refunds under Section 56
- Unjust enrichment in GST refunds: when it applies, and when it does not
- Section 77: refund where tax was paid under the wrong head
- SEZ supplies and refund: endorsement, authorised operations and the disputes
- Deemed exports and the refund to the recipient
GST Insights is published by AMLEGALS for general information. Law stated as on 3 September 2026. Not advice on any particular set of facts; not an advertisement or a solicitation under Rule 36 of the Bar Council of India Rules. Readers with a question on their own facts may write to the GST practice of their own accord.