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Act quickly, identify the procedural stage, and answer the department’s calculation line by line. A GST show-cause notice is a proposal, not a final liability. Reply in the applicable form (generally FORM GST DRC-06 for covered proceedings) before adjudication. If a final order has already been communicated, the usual remedy is an appeal under section 107, normally within three months, subject to the statutory pre-deposit and a limited condonation period. Rectification under section 161 is reserved for an obvious error apparent on the record.
Start by deciding whether you have a notice or an order
The document’s stage controls what you should do next. A show-cause notice (SCN) states the department’s proposed tax, interest or penalty and asks why that proposal should not be confirmed. It is not, by itself, a final demand. You have an opportunity to submit facts, documents and legal objections before the adjudicating authority passes an order.
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A final adjudication order records the authority’s determination after considering (or purporting to consider) your representation. A challenge to that order ordinarily proceeds through the statutory appeal mechanism rather than a first-time SCN reply. Under rule 142, the electronic notice summary is generally issued in FORM GST DRC-01, while the demand-order summary is uploaded in FORM GST DRC-07. A representation in covered proceedings is furnished in FORM GST DRC-06. The summary is not a substitute for reading the complete notice or order and every annexure.
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| What you received | What it means | Immediate route |
|---|---|---|
| SCN with DRC-01 summary | Proposed liability; adjudication has not yet been completed | Authenticate it, reconcile the allegations, and file a reasoned representation in the applicable form before the stated deadline |
| Adjudication order with DRC-07 summary | Department has determined a demand, interest and/or penalty | Consider a section 107 appeal within the statutory period; check pre-deposit and portal requirements |
| Document containing an obvious clerical or arithmetical mistake | Potential error apparent on the face of the record | Consider a narrow section 161 rectification request, without treating it as a substitute for an appeal |
Authenticate the communication before responding
Do not pay or upload sensitive records solely because an email, letter or PDF appears to be from a GST authority. The Directorate General of GST Intelligence (DGGI) states that official communications can be verified using the identifier appropriate to the issuing platform and document type, including a DIN, an eOffice Issue Number or a GSTN RFN number. Use the matching official verification route, compare the verified details with the document, and save the verification result.
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- Record the identifier exactly as displayed, including letters, numbers and punctuation.
- Confirm the issuing authority, officer, jurisdiction and communication date.
- Use the GST portal or the official departmental verification page reached through your normal secure login, not an unverified link in a message.
- Preserve the original message, downloaded PDF, annexures, portal screen and verification result.
Authentication does not decide whether the demand is legally correct. It only prevents you from missing a genuine deadline or disclosing records in response to a forged communication.
Create a case record on the day you receive it
Before drafting arguments, make a one-page chronology and a disputed-amount schedule. Capture every item below from the notice or order, not from a paraphrased email:
- Issuing officer, office and jurisdiction.
- Statutory section cited and the tax period or financial year.
- Allegation: short payment, erroneous refund, input tax credit (ITC), classification, valuation, mismatch or another issue.
- Tax, interest and penalty proposed or confirmed, with the department’s calculation for each line.
- Date on the document, date and method of service, and the response or payment date stated.
- Every annexure, relied-upon statement, data extract and worksheet referred to in the communication.
- Any earlier notice, audit letter, reply, hearing notice, order or payment connected with the same period.
Save an unaltered copy and a working copy. A summary such as DRC-01 or DRC-07 may omit the factual narrative and calculation needed to test the demand.
Check the statutory section and tax period
Section 73: periods through financial year 2023–24 without the specified fraud allegation
The CBIC Tax Information Portal describes section 73 as applying to tax periods up to FY 2023–24 where the issue is not based on fraud, wilful misstatement or suppression of facts to evade tax. The provision still involves a show-cause process and can result in tax, interest and penalty consequences, but its statutory treatment differs from section 74.
Section 74: periods through financial year 2023–24 where fraud-related conduct is alleged
The same portal describes section 74 for periods through FY 2023–24 when the notice alleges fraud, wilful misstatement or suppression of facts to evade tax. Those words matter: a notice should not be answered as though it were a routine reconciliation merely because the arithmetic resembles a section 73 case. Address the factual basis for the allegation, the evidence relied upon, and whether the statutory ingredients are actually pleaded and supported.
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Section 74A: verify the current law rather than borrowing an old deadline
The GST Portal’s appeal FAQ lists section 74A proceedings among appealable demand orders. The materials available for this guide do not establish section 74A’s complete notice, adjudication or limitation rules. Do not copy a section 73 or section 74 deadline onto a later-period section 74A matter. Check the operative consolidated Act, amendments effective for the relevant tax period, the exact notice and the current portal instructions before filing or advising on time limits.
Reconcile the department’s computation with your records
Build a separate row for every disputed invoice, return period or adjustment. For each row, show the department’s figure, your figure, the difference, the document proving your figure and the legal reason the proposed treatment is wrong. Depending on the allegation, the useful record may include:
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- GSTR returns and filed amendments.
- Electronic liability and credit ledgers, payment challans and proof of discharge.
- Tax invoices, debit notes, credit notes, purchase and sales registers.
- Contracts, purchase orders, delivery records and proof of receipt or supply.
- E-way bills where the allegation concerns movement of goods.
- Supplier correspondence, reconciliations and responses to earlier departmental queries.
- Accounting ledgers and working papers showing how tax, turnover or ITC was calculated.
Do not assume that a portal mismatch proves a tax shortfall. Identify whether the difference is a timing issue, amendment, credit note, duplicate entry, wrong GSTIN, cancelled document, place-of-supply treatment or a genuine omission. State what the department would need to verify and attach the record that permits that verification.
Draft a substantive reply to a show-cause notice
A credible reply is organized allegation by allegation, not as a general denial. Use a numbered schedule that mirrors the notice.
- Opening and authority. Identify the notice number, date, tax period, registration and the capacity in which you reply. State that the response is filed without waiving any objection that is expressly preserved.
- Issue-by-issue response. Quote or accurately summarize each allegation, then state your position, the supporting record, the corrected computation and the legal reason the proposed demand should not be confirmed.
- Tax calculation. Show the department’s amount and your calculation in separate columns. If only part is disputed, identify the undisputed and disputed portions rather than presenting one uncheckable total.
- Interest. Address interest independently. Explain any payment date, credit, reversal or calculation assumption affecting the period or base on which interest is computed.
- Penalty. Respond to the statutory basis and factual allegation separately. A disagreement with tax arithmetic is not the same issue as an allegation of fraud, wilful misstatement or suppression.
- Jurisdiction, limitation and service. Raise a genuine objection if the wrong authority acted, the period is time-barred under the applicable provision, service was defective, or the notice does not disclose the case you must meet. Explain the prejudice and identify the record supporting the objection.
- Hearing request. Request a personal hearing where the statute or the complexity of the facts makes oral clarification material. Specify the issues that require explanation; do not treat a hearing request as a replacement for documentary evidence.
- Relief sought. Ask for the proposed tax, interest and penalty to be dropped to the extent unsupported, and state any alternative relief that follows from your computation.
Attach an indexed evidence set. Number each attachment, describe it in an annexure list and cite the number in the relevant paragraph. Keep the upload files readable and retain the exact set submitted.
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File the representation and preserve proof
Use the form and portal path applicable to the proceeding; rule 142 identifies DRC-06 as the representation form for covered proceedings. Before selecting “submit,” check that the tax period, notice reference, officer and amount match the communication.
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- Open the notice or demand module and select the response option attached to the relevant proceeding.
- Enter or confirm the notice reference and select the applicable form, including DRC-06 where the proceeding requires it.
- Upload the signed reply and indexed annexures in the permitted file formats and sizes.
- Review every field and attachment; a successful upload of a short summary does not prove that the full evidence set was filed.
- Submit using the authorized signatory or other permitted authentication method.
- Download the acknowledgment and record the ARN, submission timestamp and portal status.
Keep the acknowledgment, portal receipt, screenshots showing successful upload, the final submitted PDF and proof of service. If the portal fails, record the date, error message and attempted submission, then use the official support or alternative filing channel specified for that proceeding. Never let an unrecorded technical problem become your only evidence of compliance.
What changes after a final GST demand order?
Section 107 provides an appeal to the Appellate Authority within three months from communication of the decision or order. The statutory text states:
“Any person aggrieved by any decision or order passed under this Act or the State Goods and Services Tax Act or the Union Territory Goods and Services Tax Act by an adjudicating authority may appeal to such Appellate Authority as may be prescribed within three months from the date on which the said decision or order is communicated to such person.”
The Act permits a further one-month period where sufficient cause prevented timely presentation. Treat this as a limited condonation window, not an automatic extension. Calculate the deadline from the legally relevant communication date and confirm the current provision, applicable state or union territory law and any amendment affecting your order.
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Pre-deposit and admitted liability
An appeal requires payment of the admitted portion and a statutory pre-deposit on the disputed tax. The exact amount and any applicable cap depend on the current statutory text and the type of order. The GST Portal FAQ describes the pre-deposit as at least 10% of disputed tax; because portal guidance and statutory amendments can change, verify the amount shown for your proceeding before payment. Preserve challans and ledger entries proving both the admitted payment and pre-deposit.
APL-01 portal workflow
The GST Portal FAQ states that an order must exist before an APL-01 demand appeal is filed. If the order is not uploaded, the FAQ says a self-certified copy must be submitted within seven days of filing for the portal’s final acknowledgment process. Monitor the filing for the final acknowledgment rather than assuming that an initial submission screen is the completed appeal.
The same FAQ says that, when an appeal is admitted, the portal flags the balance disputed amount as non-recoverable. That is the portal’s stated handling; it is not a guarantee about every recovery action, every type of order or every jurisdictional situation. Continue to comply with any separate communication and obtain professional advice if recovery is threatened.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Choose between appeal and rectification carefully
| Route | Use it for | Key timing or condition | What it is not |
|---|---|---|---|
| SCN representation | Correcting facts, calculation and legal grounds before adjudication | File in the applicable form by the notice’s valid deadline | Not an appeal against an order that has already been passed |
| Section 107 appeal | Contesting the merits, evidence, jurisdiction or legal interpretation of an adverse order | Normally three months from communication, with a possible further one month for sufficient cause; admitted tax and pre-deposit requirements apply | Not a way to ignore an SCN deadline |
| Section 161 rectification | An error apparent on the face of the record in a decision, order, notice, certificate or other document | Affected person may bring it to the issuing authority’s notice within three months from issue; general outer period is six months, subject to the statutory exception for purely clerical or arithmetical correction from accidental slip or omission | Not a substitute for an appeal over disputed evidence or legal interpretation |
Section 161 requires the authority that issued the document to consider rectification. If the correction would adversely affect a person, natural-justice requirements apply. Use this route for an unmistakable record error—such as a transcription, totaling or accidental omission problem—not merely because you disagree with the authority’s view of contested facts.
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Paying before checking the document
An urgent payment request can distract from authentication and the difference between a proposal and a confirmed order. Verify the identifier, stage, period and calculation first. If payment is commercially or legally necessary, record what is admitted and what remains disputed.
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Replying to the summary instead of the allegations
DRC-01 and DRC-07 are electronic summaries. A reply that only says “the demand is wrong” does not answer the underlying narrative, annexures or line-item computation. Obtain the complete communication and respond to each allegation.
Using the wrong period’s deadline
Sections 73 and 74 in the cited material concern periods through FY 2023–24. A later-period proceeding, including one invoking section 74A, must be checked against the current Act and amendments. Do not copy a date from an older notice or an online checklist.
Uploading without retaining the acknowledgment
A portal status can change, and a draft or partially uploaded file is not proof of filing. Download the ARN or acknowledgment, preserve the submitted files and keep the service record.
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Rectification is narrow and time-limited. If the dispute involves evidence, limitation, interpretation or the amount properly payable, protect the appeal deadline even if you also submit a rectification request.
When professional help is proportionate
Consider a GST practitioner, chartered accountant or tax lawyer when the amount is material, the notice alleges fraud or suppression, limitation or jurisdiction is disputed, records are voluminous, or an appeal deadline is close. Give the adviser the authenticated notice or order, full annexures, chronology, reconciliation, prior correspondence and filing proof. A professional cannot replace missing records, so assemble the evidence before the meeting.
Final action checklist
- Verify the communication through its DIN, eOffice Issue Number or GSTN RFN route.
- Classify it as SCN/DRC-01, order/DRC-07 or a possible rectification issue.
- Record the section, tax period, authority, service date and response deadline.
- Read the complete document and annexures, not only the electronic summary.
- Reconcile every disputed line with returns, ledgers, invoices, challans, contracts and relevant transport records.
- Separate tax, interest and penalty arguments and quantify your alternative result.
- File the applicable response, generally DRC-06 for covered proceedings, and preserve the ARN, acknowledgment and submitted evidence.
- If an order has been passed, calculate the section 107 deadline, pay the admitted portion and verify the current pre-deposit requirement before APL-01 filing.
- Use section 161 only for an apparent record error, while protecting any appeal deadline.
- Recheck the live Act, rules, state or union territory law and portal instructions immediately before acting.
Sources and currency note
This guide reflects official GST and CBIC materials available for the position reviewed on 13 October 2026. Portal workflows, forms, statutory text and state or union territory rules can be amended. The rules PDF used for the form references is dated 2022 and may not contain every later amendment. For an actual matter, rely on the live consolidated law, the exact communication and the portal instructions applicable to your registration and tax period.
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