GST Refund Rejected Without explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
If your refund was rejected in RFD-06 and you were never heard, the order has a serious procedural weakness. The CGST Rules say in plain words that no refund application shall be rejected without giving the applicant an opportunity of being heard. That gives you a strong ground, but you still have to act within the appeal window.
Rule 92(3) requires the officer to issue RFD-08, receive your reply in RFD-09 (15 days), and only then pass RFD-06. Its proviso says no refund application shall be rejected without an opportunity of being heard. A rejection that skips the notice or the hearing can be challenged in appeal under section 107 (three months from communication, plus one month for sufficient cause). Clerical slips in the order can be corrected under section 161. Keep the appeal clock in view while you explore other routes.
The procedure the officer must follow
The refund rejection procedure is short and fixed by Rule 92(3):
| Step | What the rule requires |
|---|---|
| 1 | Officer is satisfied, for reasons to be recorded in writing, that all or part of the claim is inadmissible |
| 2 | Notice in FORM GST RFD-08 is issued to the applicant |
| 3 | Applicant replies in FORM GST RFD-09 within fifteen days of receipt |
| 4 | Officer considers the reply |
| 5 | Order in FORM GST RFD-06, sanctioning in whole or part or rejecting |
| Proviso | No application shall be rejected without an opportunity of being heard |
Two separate protections sit inside this rule. One is the written notice with reasons (you must know the case against you). The other is the hearing (you must be able to answer it). Missing either can make the order vulnerable.
Where the RFD-08 also proposes to recover ineligible ITC under section 73 or 74, section 75(4) adds a further safeguard for that limb: a hearing must be granted where you request one in writing or where any adverse decision is contemplated.
If you are looking at an order like this now, our GST refund rejection support starts with a read of the ARN trail to see exactly which step was skipped.
Three situations that look alike but are not
1. No RFD-08 at all. The refund went straight from acknowledgement to a rejection order. This is the clearest breach, because the rule requires the notice before the order.
2. RFD-08 issued, but no hearing date given. You may have replied in RFD-09, but the officer passed the order without calling you. The proviso on hearing is still engaged. Check whether your reply asked for a hearing; if it did and was ignored, that strengthens the ground.
3. Hearing offered, but you did not attend. If a date was fixed and communicated on the portal and nobody appeared or sought an adjournment, the argument is much weaker. Check every notice and communication recorded against the ARN on the portal, and your registered email, before assuming no hearing was offered.
Your options, in order of usefulness
1. Appeal under section 107
This is the main remedy. Any person aggrieved by an order of an adjudicating authority can appeal to the Appellate Authority within three months of communication of the order, and the Appellate Authority can allow one further month if you show sufficient cause. In the appeal, plead the procedural breach first (violation of the proviso to Rule 92(3) and of natural justice) and then argue the merits in full. Do not rely on the procedural point alone; if the authority sends the case back, you want the merits already on record.
Our guide on appealing a refund rejection order covers the form, the documents and the fresh claim you file once you succeed.
2. Rectification under section 161
Section 161 lets the authority that passed an order correct an error apparent on the face of the record, on its own or when you point it out within three months of the order (no rectification after six months, except for purely clerical or arithmetical slips). This is useful where the order has an obvious slip, such as a wrong amount or period, but it is not a substitute for an appeal when the complaint is that you were never heard. Treat it as a parallel step, not a replacement, and do not let it eat into the appeal period.
3. Writ petition
Where the breach of natural justice is clear, a writ petition before the High Court is available in principle. It is a costlier and more specialised route, and courts usually expect you to use the statutory appeal unless there is a good reason not to. Take advice on whether your facts justify it.
What not to do
- Do not simply refile the same claim. A fresh RFD-01 for the same period does not undo a rejection order and may be rejected again, and the time limit keeps running.
- Do not give an undertaking not to appeal just to get the ITC re-credited through PMT-03, unless you have decided to accept the rejection. Rule 93 re-credits rejected ITC only after such an undertaking or once the appeal is finally decided.
Building the appeal file
- Download the RFD-06 order and every notice and reply on the ARN.
- Take screenshots showing the absence of an RFD-08 or a hearing notice, with dates.
- Prepare a timeline: filing, acknowledgement, any notice, reply, order date, date of communication.
- Re-prove the claim on merits: statements, refund formula working, GSTR-2B, shipping bills, BRCs.
- File within three months, and note the date of communication carefully.
For a view of the notice stage done properly, see our RFD-08 reply format. If you were never told why the refund was rejected at all, common reasons for rejection will help you guess the ground before you reconstruct it.
Need help with a refund rejected without hearing?
A rejection passed without a hearing is often recoverable, but only if the appeal is filed in time and argues both the procedure and the merits. We can review the order, prepare the appeal and the fresh claim that follows a favourable order. See GST refund rejection and appeal support, or read about our broader GST notices and litigation work.
Key takeaways
- Rule 92(3) requires RFD-08, a reply in RFD-09, and consideration of that reply before RFD-06.
- Its proviso bars rejection of any refund application without an opportunity of being heard.
- Section 107 appeal (three months plus one) is the main remedy; plead procedure and merits together.
- Section 161 rectification suits obvious errors, not a missing hearing.
- Check the portal for any hearing notice before you argue that none was given.
Read next
- RFD-08 show cause notice: reply format
- Appealing a refund rejection order
- Re-credit of rejected refund through PMT-03
- Partial GST refund sanction in RFD-06
Disclaimer: Positions stated as on 30 September 2026, based on the CGST Act and Rules as amended, the Finance Act 2026, and the ICAI Handbook on Refunds under GST (January 2026). Verify current notifications before filing.