RFD-08 Reply Format 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.
An RFD-08 is the officer telling you, in writing, that some or all of your refund claim looks inadmissible and asking why it should not be rejected. You answer in FORM GST RFD-09 within 15 days. The reply is the single most important document in a refund dispute, because the order that follows (and any appeal) will be built on what you put on record now.
Under Rule 92(3) of the CGST Rules, where the officer is satisfied, for reasons recorded in writing, that the whole or any part of a refund is not admissible, he issues a notice in FORM GST RFD-08 and you reply in FORM GST RFD-09 within fifteen days of receipt. Only after considering the reply can he pass RFD-06 sanctioning or rejecting the claim, and the proviso says no refund application can be rejected without an opportunity of being heard. A good RFD-09 reply answers each ground separately, attaches evidence, and asks for a personal hearing.
What an RFD-08 notice actually is
RFD-08 is titled "Notice for rejection of application for refund". It comes after the application has been acknowledged (RFD-02), which means the claim was complete on paper. The officer's objection is now about substance: eligibility of credit, the calculation, the relevant date, a document that does not tie up, or unjust enrichment.
Where the objection is that part of the ITC itself was ineligible, the ICAI Handbook notes that the notice is issued under section 54 read with section 73 or 74, and can ask two things at once: why the refund should not be rejected, and why the ineligible credit should not be recovered with interest and penalty. Read the notice for both limbs. A reply that answers only the refund limb leaves the recovery limb uncontested.
| Stage | Form | What happens |
|---|---|---|
| Application | RFD-01 | Claim filed, ARN generated |
| Acknowledgement | RFD-02 | Claim treated as complete |
| Notice | RFD-08 | Officer proposes rejection (whole or part) with reasons |
| Your reply | RFD-09 | Due within 15 days of receipt |
| Order | RFD-06 | Sanction in whole or part, or rejection |
| Re-credit / payment | PMT-03 / RFD-05 | Rejected ITC re-credited later; sanctioned amount paid |
If the grounds look weak, it is often worth having the reply drafted by someone who handles GST refund rejection cases regularly, because the reply fixes the record for appeal.
Before you draft: four checks
- Date of receipt. The 15 days run from receipt. Note the date the notice appeared on the portal.
- Every ground, numbered. List each objection in the notice as a separate point. Officers often bundle three issues into one paragraph.
- Figures. Rework the officer's computation. Many notices rest on a simple mismatch, for example turnover picked from the wrong return or a shipping bill counted in the wrong period.
- Documents. Gather what disproves each ground: GSTR-2B extracts, shipping bills and EGM details, BRC/FIRC, invoices, the ledger debit entry, the CA certificate where relevant. Our refund file checklist lists the usual set.
There is also a practical cost to delay. Under Rule 94(2), any time you take beyond fifteen days to reply to an RFD-08 is excluded when interest on delayed refund is computed. A late reply can reduce the interest you later receive.
Specimen RFD-09 reply structure
This is a specimen for you to adapt, not a form to copy word for word. The portal's RFD-09 has a text box and an upload facility; most practitioners type a short summary in the box and upload the full reply as a signed PDF with annexures.
SPECIMEN — REPLY TO NOTICE IN FORM GST RFD-08
To: The Proper Officer,
From: , GSTIN [______],
Subject: Reply in FORM GST RFD-09 to Notice No. [____] dated [____] in respect of refund application ARN [____] for the period [____]
1. Background. Briefly state the refund category, period, amount claimed, date of filing and date of acknowledgement.
2. Summary of grounds in the notice. Reproduce each ground as Ground 1, Ground 2, and so on, in the officer's own words.
3. Reply to Ground 1.
- Facts: what actually happened, with dates and figures.
- Law: the section, rule or circular that supports the claim (cite only what you have checked).
- Evidence: "Annexure A — GSTR-2B extract for showing the invoices listed in the notice."
- Conclusion: "The ground is therefore not sustainable and the amount of Rs [____] is admissible."
4. Reply to Ground 2, 3... Same four parts for each.
5. Reconciliation. A short table: amount claimed, amount the notice proposes to reject, amount you accept (if any, with reason), amount you contest.
6. Recovery limb (if the notice invokes section 73/74). Reply separately, since interest and penalty turn on different facts.
7. Request for personal hearing. "The applicant requests an opportunity of personal hearing before any order is passed, as provided in the proviso to Rule 92(3)."
8. Prayer. That the notice be dropped and the refund of Rs [____] be sanctioned with interest as applicable.
Annexures: list, numbered, each referred to in the body.
Verification and signature of the authorised signatory, with date and place.
Common mistakes in RFD-09 replies
- Generic replies. "The claim is as per law" does not answer anything. Each ground needs facts and a document.
- Arguing new facts later. Appellate authorities look at what was placed before the adjudicating officer. Put your evidence in now.
- Silence on a ground. An unanswered ground is usually treated as accepted.
- No hearing request. Ask in writing, even if you expect the officer to fix a date anyway.
- Accepting part without saying so clearly. If you accept a small portion, say exactly how much and why. That keeps the rest cleanly in dispute, and the accepted part can be re-credited through PMT-03 once the order is final.
If the objection is ITC missing from GSTR-2B, see refund rejected for ITC not in GSTR-2B. If the order comes out without any hearing, read refund rejected without personal hearing.
After the reply
After considering the reply, the officer passes RFD-06 for the whole amount, part of it, or nil. A partial or full rejection can be appealed within three months of communication under section 107. Our overview of the whole refund process shows where this stage sits.
Need help with an RFD-08 notice?
Fifteen days is short when the notice raises several grounds and the documents sit with different teams. We can read the notice, rebuild the computation, prepare the RFD-09 reply with annexures and appear at the hearing. See our GST refund rejection and notice support, or start from the GST refund services overview.
Key takeaways
- RFD-08 is issued under Rule 92(3) when the officer thinks all or part of the refund is inadmissible.
- Reply in RFD-09 within fifteen days of receipt; delay beyond that is excluded from interest.
- No refund can be rejected without an opportunity of being heard, so ask for a hearing in writing.
- Answer every ground separately with facts, law and a numbered annexure.
- If the notice also proposes recovery under section 73/74, answer that limb separately.
Read next
- Common reasons for GST refund rejection and remedies
- Rule 90–92: acknowledgement, deficiency and sanction
- Appealing a refund rejection order
- 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.