Deficiency Memo | GST Refund Application | GST RFD-03
Goods and service tax requires the filing of multiple forms and in case of any deficiency in information furnished, department issues a deficiency memo highlighting information not furnished or information furnished incorrectly.
Similarly, for the purpose of claiming a refund, an applicant requires to furnish refund application in form GST RFD-01. If the proper officer finds any deficiency in the filed application then he will issue form GST RFD-03 highlighting deficiencies in the application.
1. Time Limit for Issuance of Deficiency Memo
After filing a complete refund application, the jurisdictional officer shall issue an acknowledgment in form GST RFD-02 within 15 days of the generation of ARN.
Deficiencies, if any, shall be communicated through form GST RFD-03 within such 15 days.
Accordingly, the jurisdictional officer needs to issue either a deficiency memo (form GST RFD-03) or an acknowledgment (GST RFD-02) within 15 days of the generation of ARN.
After issuing the acknowledgment if a proper officer finds any deficiency subsequently then; There is no ground subsequently to issue the deficiency memo.
2. Fresh application after Deficiency Memo
On the generation of deficiency memo, the officer shall not further process the refund application, and the taxpayer will need to file a fresh refund application.
Any amount debited from input credit ledger shall be re-credited. It does not need the issuance of an order in form GST PMT-03.
The taxpayer shall file a fresh refund application with different ARN after rectifying the discrepancy highlighted in the memo.
On processing of fresh refund application, Jurisdictional officer shall not issue another deficiency memo; Unless any discrepancy highlighted has not been rectified or any other substantive discrepancy is noticed.
One needs to file a fresh refund application after a deficiency memo. That’s too within 2 years of the relevant date, as per Section 54(14) of the CGST Act.
