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When a Refund Is Rejected: Re-Credit, Appeal and PMT-03

A rejected claim does not lose the credit — but the re-credit is conditional on an undertaking, and the condition is one most claimants would rather not give.

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September 5, 2026
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Oct 13, 2026
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Last updated: October 2026Verified against: Government sources

Filing a refund claim debits the credit ledger. Rejecting it does not automatically put the credit back — and the route by which it returns forecloses an appeal.

The two routes back

Route 1 — accept the rejection. File an undertaking not to appeal, and the credit is re-credited through PMT-03. The credit returns to the ledger and can be used against output tax.

Route 2 — appeal. The credit stays debited until the appeal is finally decided. If the appeal succeeds, the refund is paid. If it fails, the credit is re-credited then.

The choice, and how to make it

The undertaking is the price of getting the credit back quickly. Whether to give it depends on three things.

How strong is the rejection ground? A rejection for a documentary defect that can be cured is often better re-filed than appealed — but note that a fresh application is only possible within the two-year limit from the relevant date. The relevant date →

Is the credit usable? For a business with output tax liability, re-credited credit is as good as cash. For a permanent exporter with no domestic liability, credit that cannot be utilised is not a substitute for a refund — and appealing is the only way to convert it.

What is the value? Appeal costs a 10% pre-deposit under s.107(6) on the disputed amount, plus time. For a small claim, the undertaking is usually the better economics.

The forms

RFD-01 — application, with the credit ledger debited. RFD-08 — notice proposing rejection. RFD-09 — reply, within fifteen days. RFD-06 — order sanctioning or rejecting. PMT-03 — re-credit order. RFD-01B — the refund order details, showing the debit and the sanction.

Rule 92(3) proviso: no application shall be rejected without giving the applicant an opportunity of being heard. A rejection order passed without a hearing, or without an RFD-08 notice, is defective. Rules 90 and 92 →

The common rejection grounds, and the answers

Deficiency treated as rejection. A deficiency memo under Rule 90(3) is not a rejection. It requires a fresh application. Where an officer issues an RFD-06 rejection on what is really a deficiency, the ground is wrong and the order is appealable on that basis.

Time bar. Check the relevant date for the category — the eleven starting points differ, and an officer applying the wrong one is a common error.

Unjust enrichment. Where the claim falls in s.54(8)(a) to (f), the certificate is not required and a rejection on that ground is misconceived. Section 54(8): unjust enrichment →

Formula dispute. Rule 89(4) or 89(5) computation differences — Net ITC composition, the 1.5 times cap, Adjusted Total Turnover exclusions. Answerable with the working.

GSTR-1 to shipping bill mismatch. Not a rejection ground under Rule 96 — it postpones the deemed filing date until rectified. Rule 96 →

Missing SEZ endorsement. A genuine ground, and only the SEZ entity can supply it.

Supplier non-compliance. Where credit claimed as refund is disallowed because a supplier did not file, the answer runs through s.16(2)(aa), Rule 37A and the evidence of a genuine supply. Rule 37A →

Erroneous refund: the other direction

Where a refund has been paid and is later found not to have been due, it is recovered as an erroneous refund.

Section 73, s.74 or s.74A applies, depending on the period and whether fraud, wilful misstatement or suppression is alleged, with interest under s.50.

Rule 96B is a specific instance — refund on export of goods where the proceeds are not realised. Rule 96B →

Section 74A governs FY 2024-25 onwards and merges the two limbs with differentiated penalties.

Note that an erroneous refund demand is a demand proceeding with the full protections — notice, reply, hearing, order, appeal — unlike the Rule 96B thirty-day deposit obligation, which is a voluntary step preceding it.

Key takeaways

  • Rule 89(3) debits the credit ledger when the claim is filed.
  • Rule 93(2): re-credit through PMT-03 only on an undertaking not to appeal, or after an appeal is finally decided against the applicant.
  • Appealing preserves the claim but keeps the credit debited and costs a 10% pre-deposit.
  • A deficiency memo is not a rejection — it requires a fresh application.
  • Rejection requires RFD-08, a reply and a hearing.
  • An erroneous refund is recovered under s.73, s.74 or s.74A with interest.

Read next

Disclaimer: Positions stated as on 5 September 2026, based on the CGST Act and Rules as amended to 31 March 2026 (ICAI Bare Law, 12th edition) and the ICAI Handbook on Refunds under GST (January 2026).

Quick recapKey facts & short answers

Key Facts About Refund Is Rejected

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

What happens to my credit if a refund is rejected?

It is re-credited to the electronic credit ledger through an order in FORM GST PMT-03 — but only after an undertaking not to appeal, or after an appeal is finally decided against the applicant.

Can I get the credit back and still appeal?

No. Rule 93(2) conditions the re-credit on an undertaking not to file an appeal.

Answer a GST notice within its time limit even if the answer is only a request for more time.

— TaxClue GST Desk

Refund Is Rejected: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

People also ask

Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

It is re-credited to the electronic credit ledger through an order in FORM GST PMT-03 — but only after an undertaking not to appeal, or after an appeal is finally decided against the applicant.

No. Rule 93(2) conditions the re-credit on an undertaking not to file an appeal.

No. It requires a fresh application after rectification, and the period from the original filing to the memo is excluded from the two-year limit.

Yes. The proviso to Rule 92(3) requires an opportunity of being heard, preceded by a notice in RFD-08.

A pre-deposit of ten per cent of the disputed amount under section 107(6), plus time.

As an erroneous refund under section 73, 74 or 74A, with interest under section 50.