Rules 90 and 92 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.
A refund claim moves through a defined chain of forms. Understanding where the clock starts and where it restarts is the difference between a sixty-day refund and an indefinite one.
Rule 90(1) and (2): an acknowledgement in FORM GST RFD-02 is issued within fifteen days of the application, if found complete. Rule 90(3): where deficiencies are noticed, a deficiency memo in FORM GST RFD-03 is issued within fifteen days, and the applicant is required to file a fresh refund application after rectification. Rule 92: the sanction order is FORM GST RFD-06; the payment order is RFD-05; withholding is RFD-07; and a proposed rejection is put to the applicant in RFD-08 with a reply in RFD-09.
The chain
| Stage | Form |
|---|---|
| Application | RFD-01 |
| Acknowledgement | RFD-02 |
| Deficiency memo | RFD-03 |
| Provisional sanction | RFD-04 |
| Payment order | RFD-05 |
| Final sanction or rejection | RFD-06 |
| Withholding / adjustment | RFD-07 |
| Notice of proposed rejection | RFD-08 |
| Reply to the notice | RFD-09 |
The deficiency memo resets everything
This is the most consequential feature of the process.
Rule 90(3): where deficiencies are noticed, the proper officer shall communicate the deficiencies in FORM GST RFD-03 through the common portal, requiring him to file a fresh refund application after rectification of such deficiencies.
Not "cure the defect and continue" — file a fresh application.
Two consequences:
The sixty-day clock in s.54(7) restarts from the fresh application. Interest under s.56 runs from sixty days after the fresh application, not the original one.
The two-year limit in s.54(1) keeps running. A deficiency memo issued close to the limitation date, followed by a fresh application after it, is time-barred.
The proviso to Rule 90(3): the time period from the date of filing of the refund claim in FORM GST RFD-01 till the date of communication of the deficiencies in FORM GST RFD-03 shall be excluded from the period of two years, in respect of any such fresh refund claim.
So the exclusion covers the time the department held the first application — but not the time the applicant takes to rectify.
Rule 90(4): where deficiencies have been communicated under the SGST or UTGST Rules, the same shall be deemed to have been communicated under this rule along with the deficiencies communicated under sub-rule (3).
Rule 90(5) and (6): withdrawal
Rule 90(5): the applicant may, at any time before the issuance of a provisional refund sanction order in RFD-04, a final refund sanction order in RFD-06, a payment order in RFD-05, an order for withholding in RFD-07 or a notice in RFD-08, withdraw the application by filing FORM GST RFD-01W.
Rule 90(6): on withdrawal, any amount debited from the electronic credit ledger under Rule 89(3) shall be credited back.
Withdrawal is useful where a defect is spotted before the officer does, since it avoids a deficiency memo on the record.
Rule 92: sanction
Rule 92(1) — where the officer is satisfied that a refund is due, he makes an order in FORM GST RFD-06 sanctioning the amount, mentioning the amount refunded provisionally under s.54(6), the amount adjusted against any outstanding demand, and the balance refundable.
Rule 92(2) — where the officer or the Commissioner is of the opinion that the refund is liable to be withheld under s.54(10) or (11), he passes an order in Part A of FORM GST RFD-07, informing the reasons.
Rule 92(2) proviso — where the refund is no longer liable to be withheld, an order in Part B of FORM GST RFD-07 is passed, releasing it.
Rule 92(3) — where the officer is satisfied that the refund is not admissible or not payable to the applicant, he issues a notice in FORM GST RFD-08 requiring the applicant to furnish a reply in FORM GST RFD-09 within fifteen days, and after considering it, makes an order in RFD-06 sanctioning or rejecting the claim.
The proviso to Rule 92(3): no application shall be rejected without giving the applicant an opportunity of being heard.
Rule 92(4) — where the refund is payable to the applicant, the officer issues a payment order in FORM GST RFD-05 for the amount, to be electronically credited to the bank account mentioned in the registration particulars.
Rule 92(5) — where the officer is satisfied that the amount is not payable to the applicant under s.54(8), he makes an order in RFD-06 and issues an advice in RFD-05 for crediting it to the Consumer Welfare Fund.
The sixty days
Section 54(7): the proper officer shall issue the order under s.54(5) within sixty days from the date of receipt of application complete in all respects.
Two words carry the weight: "complete in all respects". A deficiency memo asserts the application was not complete, which is what resets the clock.
Section 56 then pays interest at 6% for delay beyond sixty days, and 9% where the refund arises from an order that has attained finality. Section 56: interest on delayed refunds →
Key takeaways
- RFD-02 acknowledgement within fifteen days; RFD-03 deficiency memo within the same period.
- A deficiency memo requires a fresh application, restarting the sixty-day clock.
- The two-year limit keeps running, with only the department's holding period excluded.
- RFD-01W withdraws an application before any order, with the credit ledger re-credited.
- RFD-08 notice and RFD-09 reply within fifteen days precede any rejection, and a hearing is mandatory.
- The sixty-day period runs from an application complete in all respects.
Read next
- How to Respond to a GST Refund Deficiency Memo: RFD-03
- Section 56: Interest on Delayed Refunds
- Rule 89(1) and (2): Who Applies, and With What Evidence
- GST Refund Process Step by Step: RFD-01 to RFD-06
Need a hand with this claim? Our team handles the computation, RFD-01 filing and follow-up to sanction — see GST refund rejection and reply support.
Disclaimer: Positions stated as on 5 September 2026, based on the CGST Rules as amended to 31 March 2026 (ICAI Bare Law, 12th edition) and the ICAI Handbook on Refunds under GST (January 2026).