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Refund Processing in a Virtual Environment: The Single Interface

One authority now processes both the central and the State portion, disburses both, and the taxpayer deals with one office — with the settlement handled behind it.

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Published
September 5, 2026
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Sep 30, 2026
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Last updated: September 2026Verified against: Government sources

Refund processing was originally split — the central authority handled the CGST and IGST portion, the State authority the SGST portion, and a claimant chased two offices for one claim.

That was replaced by a single interface with a single disbursement.

What the single interface changed

One application. RFD-01, filed once, covering all heads.

One processing officer. Whichever authority the taxpayer is assigned to, that officer disposes of the whole claim.

One set of forms. RFD-02 acknowledgement, RFD-03 deficiency, RFD-06 sanction, RFD-05 payment order — issued once, covering all heads.

One disbursement. A single credit to the bank account, through PFMS.

One appeal. Against the single order.

Before this, a claimant could receive a partial disbursement from one authority and a deficiency memo from the other on the same claim.

The consequences for a claimant

Deal with one office. Correspondence, hearings and clarifications go to the assigned officer, whether central or State.

One deficiency memo covers everything. Rule 90(4) puts it beyond doubt: where deficiencies have been communicated under the SGST or UTGST Rules, they shall be deemed to have been communicated under Rule 90(3) along with the deficiencies communicated under that sub-rule.

So a memo issued by either authority is a memo for the whole claim, and the fresh application requirement applies to all of it. Rules 90 and 92 →

One rejection, one appeal. A partial rejection of the SGST portion is part of the same order, appealed once.

Bank account validation matters more. With a single PFMS disbursement, a failed bank validation stops the entire refund, not a portion of it. Rule 10A →

What is uploaded

The application is entirely electronic, and the supporting documents are uploaded with it. Circular No. 125/44/2019-GST specified the statements and declarations to be uploaded for each category, and the portal enforces them.

The practical points:

Upload limits apply. Large claims with hundreds of invoices need the statements in the prescribed format rather than scanned documents.

The statements are validated against the returns. A statement of invoices that does not tie to GSTR-1 or GSTR-2B produces a query.

Additional documents may be sought. The officer may seek further documents, and the response is uploaded on the portal — but note that a request for documents is not a deficiency memo unless issued as RFD-03.

That distinction matters: an informal request does not restart the sixty-day clock; a deficiency memo does.

The provisional refund layer

Rule 91(2), substituted with effect from 01.10.2025, sits on top of the single-interface architecture: the proper officer, on the basis of identification and evaluation of risk by the system, shall make an order in FORM GST RFD-04 within seven days of acknowledgement, with the order not requiring revalidation, and a refusal requiring reasons in writing.

So for an eligible claim, the sequence is:

  1. RFD-01 filed;
  2. RFD-02 acknowledgement within fifteen days;
  3. RFD-04 provisional 90% within seven days of acknowledgement, on system risk evaluation;
  4. RFD-05 payment order and PFMS disbursement;
  5. RFD-06 final order within sixty days of the complete application.

Provisional refund and Rule 91(2) →

Practical notes

  • Identify the assigned authority at the outset. Correspondence to the wrong office delays nothing formally but wastes time.
  • Validate the bank account before filing, since one failure stops the whole disbursement.
  • Use the prescribed statement formats. Free-form uploads are queried.
  • Distinguish an informal document request from an RFD-03. Only the latter restarts the clock, and only the latter requires a fresh application.
  • Track the seven-day provisional window where the claim is eligible — a claim acknowledged and not provisionally sanctioned within seven days should prompt a follow-up.
  • Keep the PFMS failure reasons. Where disbursement fails, the reason is usually a bank validation issue that the taxpayer must fix.

Key takeaways

  • One application, one officer, one order, one disbursement through PFMS.
  • Rule 90(4): a deficiency communicated under the State rules is deemed communicated under the central rule.
  • The process is entirely electronic, with prescribed statement formats.
  • An informal document request is not a deficiency memo and does not restart the sixty days.
  • Rule 91(2) adds a seven-day, system-risk-based provisional sanction on top.
  • A failed bank validation stops the entire refund.

Read next

Disclaimer: Positions stated as on 5 September 2026, based on the CGST Rules as amended to 31 March 2026 (ICAI Bare Law, 12th edition), Circular No. 125/44/2019-GST and the ICAI Handbook on Refunds under GST (January 2026).

Quick recapKey facts & short answers

Key Facts About Refund Processing

  • 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.

Who processes a GST refund claim?

A single jurisdictional officer, central or State, who processes the entire claim including the portion belonging to the other authority.

Is the refund disbursed separately by each authority?

No. It is a single disbursement through the Public Financial Management System, with settlement between the Centre and the State handled administratively.

Refund Processing: 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.

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Questions, answered

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

A single jurisdictional officer, central or State, who processes the entire claim including the portion belonging to the other authority.

No. It is a single disbursement through the Public Financial Management System, with settlement between the Centre and the State handled administratively.

Yes. Rule 90(4) deems deficiencies communicated under the State rules to be communicated under the central rule for the whole claim.

Only where it is issued as a deficiency memo in FORM GST RFD-03, which requires a fresh application.

Within seven days of acknowledgement, under Rule 91(2), on the basis of system risk evaluation.

The entire disbursement stops. The account must be validated on the portal before filing.