
Claiming a GST refund should be a smooth process—but often, taxpayers are hit with refund rejections, deficiency memos, or partial sanctions. Whether you’re filing a refund for exports, inverted duty structure, or excess cash balance, the GST refund mechanism has several compliance traps.
In this blog, we unpack the 7 most common reasons for GST refund rejections under the current regime and give you clear, actionable advice to avoid them.
✅ 1. Mismatch in GSTR-1 and GSTR-3B
🔍 Why It Gets Rejected:
One of the most frequent causes is data mismatch between:
- GSTR-1 (Invoice-level outward supply details), and
- GSTR-3B (Summary return used for payment).
For export-related refunds (without payment of tax under LUT), officers validate the turnover disclosed in GSTR-1 vs. GSTR-3B. If there’s a mismatch, it leads to partial or full rejection.
🛠️ How to Avoid It:
- Always reconcile GSTR-1 and GSTR-3B before filing.
- Ensure export invoices are reported in Table 6A of GSTR-1.
- Report accurate zero-rated supplies in Table 3.1(b) of GSTR-3B.
- Use automated reconciliation tools or platforms like Vaive.ai to validate before filing.
✅ 2. Ineligible ITC Claimed
🔍 Why It Gets Rejected:
Refunds related to accumulated ITC are often rejected when:
- The ITC claimed includes blocked credits under Section 17(5) (e.g., food, motor vehicles).
- ITC is claimed on capital goods, which is not eligible for refund under Inverted Duty claims.
🛠️ How to Avoid It:
- Exclude blocked inputs and capital goods from the refund computation.
- Match ITC only from eligible invoices reported in GSTR-2B.
- Check the Inverted Duty Refund Formula carefully under Rule 89(5).
✅ 3. Lack of Supporting Documents
🔍 Why It Gets Rejected:
GST officers often reject refunds when key documents are missing:
- Shipping Bills
- Export Invoices
- Bank Realisation Certificates (BRC) or FIRC
- LUT acknowledgement (for exports without payment)
Without this documentation, refund eligibility cannot be verified.
🛠️ How to Avoid It:
- Maintain a refund filing checklist.
- Attach all mandatory documents as required under Rule 89(2).
- Use document management features in refund platforms or CRMs to avoid manual errors.
✅ 4. Wrong Selection of Refund Category
🔍 Why It Gets Rejected:
Choosing the wrong refund type on the RFD-01 portal leads to procedural rejection. Common mistakes include:
- Selecting “Export of goods with payment of tax” instead of “without payment”
- Claiming refund under wrong head (e.g., excess balance instead of accumulated ITC)
🛠️ How to Avoid It:
- Understand refund categories: Export with/without payment, Inverted Duty, Excess balance, etc.
- Refer to CBIC FAQs or Circulars like 125/44/2019-GST for clarity.
- Take assistance from GST experts or automated tools like Vaive.ai.
✅ 5. Late Filing Beyond Time Limit
🔍 Why It Gets Rejected:
Refunds must be filed within 2 years from the “relevant date” as defined under Section 54 of the CGST Act. Any delay makes the claim time-barred and ineligible.
🛠️ How to Avoid It:
- Know your relevant date:
- For exports: date of shipping bill/BRC
- For ITC refund: end of tax period
- Set internal reminders or automate refund due dates using tools.
✅ 6. Failure to Respond to Deficiency Memo (RFD-03)
🔍 Why It Gets Rejected:
If your application is found defective, the officer will issue an RFD-03 memo. If you don’t rectify and refile the application within 30 days, the claim is closed.
🛠️ How to Avoid It:
- Track refund filing status regularly.
- If you get an RFD-03, refile as fresh RFD-01 within 30 days with corrected information.
- Keep detailed notes of previous communications to avoid repetition of errors.
✅ 7. No Actual Exports or Fake Documentation
🔍 Why It Gets Rejected:
Refunds are rejected if exports were:
- Not substantiated with actual shipping or BRC documents.
- Found to be bogus or not reported correctly in ICEGATE data.
Also, cases flagged under ITC fraud investigations or fake invoice detection are automatically put on hold.
🛠️ How to Avoid It:
- Ensure all export data matches with ICEGATE portal.
- Don’t claim refund unless shipping, invoice, and payment details are complete.
- Avoid engaging in vendors or invoices flagged under risky exporters list.
⚖️ What If Your Refund is Rejected?
If your claim is partially or fully rejected, you have the following options:
- File RFD-05 appeal within 3 months of rejection.
- If rejection is based on factual grounds, file a rectified RFD-01 with supporting clarification.
- Use Vaive.ai to auto-draft detailed representations and appeal documents.
✍️ Final Thoughts
GST refund rejections can be prevented, not just contested. With proper reconciliations, timely filings, correct categorization, and complete documentation—you can ensure faster refunds and reduce disputes.
💡 How Vaive.ai Can Help You
Vaive.ai is your AI-powered assistant built specifically for GST litigation and consultancy. If your refund has been rejected or kept on hold, we help you:
- Draft professional replies to refund rejection orders
- Respond to deficiency memos (RFD-03) with clear, structured submissions
- Generate appeal-ready documents for GST refunds
- Save time with pre-formatted, legally sound templates for refund-related notices
Whether you’re a taxpayer or a consultant, Vaive.ai simplifies the drafting process—no more guesswork or manual formatting.
📩 Contact us at info@vaive.ai or WhatsApp/call +91-9871399306
