Rules 90 and 92: Acknowledgement, Deficiency and Sanction

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

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

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).