My GST refund is delayed — what can I do?

The refund process under Section 54 of the CGST Act, 2017 and Rules 89–92 of the CGST Rules, 2017 runs on fixed milestones:

• Filing deadline: The application in Form GST RFD-01 must generally be filed within 2 years from the 'relevant date', which varies by refund type (e.g. date of export, end of the tax period).
• Acknowledgement (RFD-02) or deficiency memo (RFD-03): The officer should scrutinise the application and either acknowledge it as complete or flag deficiencies — the Rules provide for this within 15 days of filing.
• Provisional refund (RFD-04): For zero-rated supplies (exports, SEZ supplies), 90% of the claim may be sanctioned provisionally within 7 days of acknowledgement. From 1 October 2025, Rule 91(2) was amended and CBIC began risk-based provisional sanction, which has also been extended to inverted duty structure claims for applications filed on or after that date.
• Final order (RFD-06): Under Section 54(7), the final sanction or rejection order must be passed within 60 days from the date of receipt of the complete application.

Note that if a deficiency memo is issued, the corrected application is treated as a fresh application, so the 60-day clock typically restarts from the re-filing date. Procedures change through circulars and notifications — confirm the current position on the GST portal or with CBIC before relying on a specific timeline.

Yes. Section 56 of the CGST Act makes interest on delayed refunds a statutory entitlement — it is not a favour the officer can refuse.

• Ordinary refunds: Interest at 6% per annum (notified rate) from the day after the 60-day window expires until the date the refund is credited.
• Refunds arising from an appellate, tribunal or court order: The notified rate is 9% per annum, computed with reference to the application filed after that order.
• How it is paid: Interest is meant to be sanctioned along with the refund (in Form GST RFD-05/RFD-06). If the order sanctions the refund but omits interest, raise this in writing with the proper officer and, if refused, treat the omission as an appealable decision.

Several High Courts have held that interest runs from the original application date where a deficiency memo was issued without valid reason, but the law on the precise start date is still developing. Rates are fixed by notification and can change — confirm the current rate on the GST portal or CBIC website before computing your claim.

The most common reasons a refund application stalls are:

• Deficiency memo (RFD-03): Missing invoices, statements (e.g. Statement 3 for exports, Annexure B for ITC), CA certificate, or undertakings. You must cure the deficiency and file a fresh RFD-01.
• Data mismatches: Differences between GSTR-1 and GSTR-3B, ITC claimed versus what appears in GSTR-2B, or — for IGST export refunds — mismatches between shipping bill data on ICEGATE and your GSTR-1/Table 6A.
• Show cause notice (RFD-08): Where the officer proposes to reject all or part of the claim, you get a notice and must reply in Form RFD-09 (usually within 15 days). An unanswered RFD-08 almost always leads to rejection.
• Withholding under Section 54(10)/(11): The refund can be withheld if you have not filed returns or have unpaid, unstayed tax, interest or penalty dues — or where the Commissioner believes the refund is likely to adversely affect revenue in a pending appeal.
• Bank account not validated on the GST portal or PFMS, which blocks disbursement even after sanction.
• Risk flags on the supplier chain (e.g. ITC from cancelled or non-existent suppliers), which trigger manual verification.

Work up the ladder in this order, keeping copies and screenshots at every step:

1. Track the ARN: Log in to the GST portal → Services → Refunds → Track Application Status. Check whether an RFD-02, RFD-03, RFD-08 or RFD-06 has been issued and whether the bank account is validated.
2. Respond to any notice through the portal (Services → User Services → View Notices and Orders) within the time given.
3. Write to the jurisdictional proper officer (Central or State, as shown on your registration) citing your ARN, the filing date and Section 54(7), and request sanction with Section 56 interest.
4. Escalate to the Assistant/Deputy Commissioner and then the Commissioner of your jurisdiction if there is no response within 2–3 weeks.
5. Raise a GSTN ticket on the GST self-service grievance portal if the problem is technical (status not updating, disbursement failure, portal error) — or call the GST helpdesk at 1800-103-4786. Save the ticket number.
6. File on CPGRAMS (pgportal.gov.in) under the Department of Revenue/CBIC for Central-jurisdiction cases, or use your State GST department's grievance channel. CBIC zones also run Grievance Redressal Committees that take up recurring trade issues such as refund delays.

A rejection or partial rejection in Form RFD-06 (or a refusal to pay interest) is an appealable decision:

• First appeal — Appellate Authority (Section 107): File Form GST APL-01 on the portal within 3 months of the order being communicated; a further 1 month may be condoned for sufficient cause. A pre-deposit (generally 10% of the amount in dispute) applies to appeals involving a tax demand — check whether and how it applies to your refund appeal.
• Second appeal — GST Appellate Tribunal (Section 112): Against the Appellate Authority's order, in Form GST APL-05, within 3 months, with a further pre-deposit. GSTAT benches have only recently become operational — confirm current filing timelines and transitional deadlines on the GSTAT portal.
• Writ petition (Article 226): Where the department simply sits on a complete application, withholds without a reasoned order, or refuses statutory interest, High Courts regularly issue directions to process the refund with interest. This is the usual remedy for pure inaction, since there is no order to appeal against.

A refund that is sanctioned after a successful appeal attracts the higher 9% interest rate under Section 56. For large amounts or legally contested refunds (e.g. inverted duty formula disputes), engage a GST practitioner or indirect-tax lawyer.