Yet he responded with scores of 50 and 47 in last month's two-match home Twenty20 series against Australia which the tourists won 2-0.
Rahul has been given another opportunity to make a case for inclusion as a reserve opener or a number four at the World Cup in England and Wales starting in May and Kohli said the 26-year-old was on a "different level" at his best.
"It's difficult to find a consistent player, who can play good cricketing shots and still win you games at a strike-rate of over 140 or 150," Kohli told a news conference ahead of the opening game of the five-match ODI series in Hyderabad.
"It'll be interesting to see what happens in the final World Cup squad. Definitely, he's made a strong case for himself. It's good he's in great nick and hopefully he can carry it forward.
"We'll have to work out the batting combination to try and give game-time to guys we want to. But, I don't see the bowling combination changing."
Australia skipper Aaron Finch said regular wicketkeeper Alex Carey would take the gloves in Hyderabad after being overlooked for the T20s when Melbourne Stars' Peter Handscomb was given the chance instead.
"Alex has done well when he's had his opportunities and I know he was really disappointed missing out," Finch said.
"But Pete had done a good job for the Stars and gave us the luxury of playing that extra bowler, which was so important at the end of the day.
"Going forward, (the wicketkeeper) is likely to be in that middle-order, number seven spot."
Finch said Glenn Maxwell, who scored 56 and an unbeaten 113 in the two T20s, could be promoted from number seven.
"His two knocks here were unbelievable... he'll get an opportunity a bit higher up the order, no doubt," Finch added.
"His record in India is very good, the way he played in Australia, even in the ODIs there was good improvement.
"Whether that's six, whether it's five - I'm not sure yet. But he'll get an opportunity a bit higher than seven."
(Reporting by Shrivathsa Sridhar in Bengaluru; Editing by Toby Davis)
