Reconcile the notice to your filed returns first, then trace every disputed figure to the underlying invoice, ledger entry and payment or reversal record. Start by identifying the exact notice form, statutory section, tax period, allegation, amount, response date and electronic filing route. A GSTR-2B mismatch workflow, a DRC-01C return-compliance intimation and a show-cause or demand notice are different procedures; the instructions in the communication control.
The process below is an evidence-building exercise, not a substitute for advice on the specific notice or the current law. Portal screens and legal provisions can change, so verify the live notice instructions and current CGST rules before submitting anything.
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1. Freeze the facts in the notice before opening your books
Save the complete communication as issued, including every annexure, calculation sheet and download from the GST portal. Keep the original file name and a copy outside the portal so you can prove what was served. Record the facts in a control sheet:
- reference number and the dates shown for issue and service;
- issuing authority and your GSTIN;
- financial year and each tax period covered;
- notice or intimation form, such as DRC-01C or a form linked to a show-cause or demand proceeding;
- sections of the CGST Act or rules cited;
- the allegation, including outward-tax shortfall, input-tax-credit (ITC) excess, late payment, interest or penalty;
- the tax, interest and penalty amounts, with the notice’s own breakup;
- the response date stated in the communication; and
- the portal menu or filing route specified for the reply.
Do not infer a deadline from another taxpayer’s notice. Rule 142 covers several routes and does not establish one universal reply period. The exact date and filing method in your communication, read with the governing provision, should drive your timetable.
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Keep delivery evidence as well: the portal acknowledgement, email, service date and any downloaded status page. If the document is labelled DRC-01C, put it in a separate workstream immediately. It is a return-compliance intimation with its own Part B response, not a shorthand version of every GST notice.
2. Build a period-wise return and evidence pack
Make one folder for each financial year and tax period named in the communication. Download the filed return records and portal statements before changing or correcting anything. Your core pack should contain:
- filed GSTR-1 for each relevant period;
- filed GSTR-3B for each relevant period;
- GSTR-2B for each relevant period, downloaded in the format available on the portal, including Excel or JSON where offered;
- the sales register, purchase register and general-ledger extracts used to prepare those returns;
- invoice PDFs or other legally maintained tax-invoice records, along with credit notes, debit notes, export documents and amendment records that explain the entries;
- electronic cash-ledger and credit-ledger records, challans and payment acknowledgements that bear on the allegation; and
- earlier replies, refund or reversal records and correspondence that the notice specifically references.
Use a consistent file naming convention such as 2025-26_2025-07_GSTR3B_filed.pdf and 2025-07_ITC_invoice_ABC123_attachment-07.pdf. Number attachments once and keep the same number in your reconciliation schedule and reply. This prevents an officer from having to guess which invoice supports a paragraph.
GSTR-1 is the statement of outward supplies. Its contents include invoice-level details, credit and debit notes, exports, advances, amendments and summary information. GSTR-2B is a recipient-side statement of supplier-filed information for ITC reconciliation; it can be viewed and downloaded from the portal. Neither download, by itself, replaces the books or the legal eligibility review.
3. Reconcile outward supplies: sales register to GSTR-1 to GSTR-3B
Match the invoice-level fields
Export the sales register and GSTR-1 data into a working sheet and match, at minimum:
- invoice number and invoice date;
- recipient GSTIN where relevant;
- taxable value;
- tax rate and each tax component; and
- the period in which the document was reported.
Use a stable key that does not silently treat two different invoices as one. Where a numbering change or amendment makes an exact key impossible, retain the original number, amended number and a note explaining the relationship.
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Separate adjustments instead of netting them away
List credit notes and debit notes separately from original invoices. Do the same for exports, advances, exempt, nil-rated and non-GST supplies, and amendments. A net sales total can conceal a missing invoice, an incorrect tax rate or a credit note reported in a different period. The schedule should show the gross document, the adjustment and the resulting return amount so the notice figure can be reproduced.
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After the GSTR-1 match, compare the resulting tax liability with the corresponding GSTR-3B tables and the payment records. For each period, explain a difference as one identifiable cause, such as a reporting-period shift, amendment, credit-note timing, advance adjustment or a data-entry error. Do not combine unrelated variances merely because the total happens to agree.
Where the notice alleges under-reported outward tax, prepare a bridge with these columns: notice amount, GSTR-3B amount, GSTR-1 amount, sales-register amount, adjustment amount, tax already paid and residual variance. Attach the documents that prove each bridge step.
Understand the limited role of GSTR-1A
GST Portal guidance describes GSTR-1A as an optional facility to amend or add records for the same period before GSTR-3B is filed. A change flows into the supplier’s GSTR-3B, while the recipient-side ITC effect of a supplier’s GSTR-1A change appears in the next period’s GSTR-2B. Treat that as a period-timing fact, not as a general permission to rewrite an old return outside the applicable rules.
4. Reconcile ITC: GSTR-2B to the purchase register and books
Start at document level
For every purchase document in the notice or your ITC claim, compare the purchase register, accounting ledger and GSTR-2B. Match supplier GSTIN, invoice number, invoice date, taxable value, each tax component and the period in which the credit was claimed. Mark the result as matched, unmatched, duplicate, amended, credit-noted, reverse-charge or under eligibility review.
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A useful ITC schedule includes:
- tax period;
- notice allegation or line reference;
- supplier and invoice number;
- taxable value and tax component;
- GSTR-2B reference;
- purchase-register and ledger reference;
- variance and its cause;
- action taken, such as retain, reverse, defer or pay reverse-charge tax; and
- attachment number.
Investigate every mismatch category
| Mismatch | What to check | Possible treatment in the reconciliation |
|---|---|---|
| Invoice in books but absent from GSTR-2B | Supplier filing status, supplier GSTIN, invoice number, amendment and period | Explain the timing or data issue and assess whether credit is legally available before claiming or retaining it |
| GSTR-2B entry absent from the purchase register | Whether the purchase belongs to your business, was booked in another period or is a duplicate | Trace it to the ledger and underlying invoice; do not claim it merely because it appears in the statement |
| Duplicate invoice or duplicate credit | Invoice number, supplier GSTIN, tax amount and repeated ledger lines | Remove the duplicate and document any reversal or payment |
| Credit note or amendment | Original invoice, supplier’s adjustment and period reflected in GSTR-2B | Reduce or correct the claim in the period required by the applicable rules |
| Reverse-charge transaction | Nature of supply, reverse-charge tax computation and payment record | Show the reverse-charge payment and the related credit treatment separately |
| Credit appearing in GSTR-2B but restricted by law | Business use, blocked-credit provisions and other statutory conditions | Self-assess eligibility; reverse or exclude the amount where required |
The portal expressly advises reconciliation between GSTR-2B and the purchase register, avoidance of duplicate credit, reversal when required and payment of reverse-charge tax. A match in GSTR-2B is evidence to investigate, not a complete legal eligibility decision. Other provisions can make a credit unavailable, so your books, invoice facts and statutory restrictions must be reviewed together.
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Keep timing separate from eligibility
Supplier filing or amendment timing can move an invoice from one GSTR-2B period to another. Record both the document date and the period in which it became visible or was claimed. Do not describe a timing difference as an ineligible credit, and do not use timing as an excuse for a credit that fails a substantive condition.
5. Tie each disputed number to the books and payment trail
For every amount in the notice, create a traceable chain:
- Copy the notice’s line or calculation into the schedule.
- Identify the corresponding GSTR-1, GSTR-3B or GSTR-2B entry and cite its period and table or document reference.
- Locate the invoice, credit note, debit note or other source record.
- Locate the sales or purchase-register line and general-ledger posting.
- Check the electronic liability ledger, cash or credit ledger, challan, reversal entry, refund record or other payment evidence that bears on that allegation.
- State the outcome: data error, timing or amendment, ineligible credit, tax already paid, or unresolved item.
- Assign an attachment number and keep the calculation that reproduces the figure.
Attach payment evidence only when it answers the allegation. A random bank statement or a complete ledger dump makes review harder; a challan tied to the exact tax period and liability line is more persuasive. If a difference remains unresolved, label it unresolved and quantify it rather than calling the entire notice settled.
6. Draft a point-by-point electronic reply
Use the route specified for the actual communication
Rule 142 describes electronic summaries such as DRC-01 for specified notices and provides for DRC-06 representations or replies in the covered cases. The prescribed DRC-06 form asks for the notice reference and date, financial year, reply text, uploaded documents, a personal-hearing preference and verification by the authorised signatory. Follow the form and portal path attached to your notice rather than uploading a generic letter to the wrong menu.
Organize the reply around the allegations
- Identification: state the GSTIN, notice reference, financial year, periods and the communication date.
- Short position: state which amounts are accepted, disputed, already paid, reversed or still being verified. Use the same figures as the reconciliation schedule.
- Allegation-by-allegation response: reproduce each numbered allegation in a short heading, then explain the calculation and the documentary trail.
- Reconciliation table: show notice figure, return figure, books figure, adjustment and residual amount for each issue.
- Evidence map: refer to attachment numbers immediately after the statement they prove.
- Relief or next action: state the correction, reversal, payment or deletion you seek and request a personal hearing where the actual procedure permits and the facts warrant it.
- Verification: complete the authorised-signatory declaration and submit through the prescribed electronic route.
The DRC-06 verification contains this prescribed sentence: “I hereby solemnly affirm and declare that the information given hereinabove is true and correct to the best of my knowledge and belief and nothing has been concealed therefrom.” Treat it as the form’s official declaration. Check every number and attachment before signing it.
Write explanations that can be tested
Replace statements such as “the mismatch is due to a technical issue” with a testable explanation: identify the invoice, the supplier filing period, the return table, the ledger line and the resulting tax difference. Do not make an unsupported admission simply to close a paragraph, and do not deny a figure that your own schedule cannot explain. If the notice calculation is unclear, identify the missing basis and ask for the working while answering the portions you can document.
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7. Treat DRC-01C as a separate return-compliance workflow
The GST Portal manual says a DRC-01C intimation may be generated when the ITC difference between GSTR-2B and GSTR-3B exceeds a predefined limit. It states that filing Part B is mandatory to explain and reconcile the difference. It also warns that failure to file Part B can prevent filing GSTR-1 or an Invoice Furnishing Facility (IFF) statement for a later period.
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8. Read the cited legal route instead of guessing from the mismatch
The CBIC-hosted CGST Act text distinguishes section 73 from section 74 by the alleged reason for a tax shortfall, erroneous refund or wrongly availed or utilised ITC. Section 73 is framed for reasons other than fraud, wilful misstatement or suppression to evade tax; section 74 addresses those alleged circumstances. The section cited, the period and the facts in the notice determine the legal route. A mismatch by itself does not prove intent.
Rule 142 also describes DRC-03 payment intimation and DRC-04 or DRC-05 outcomes for specified payment situations, including a 30-day provision tied to particular section 73 or section 74 proceedings. That provision is not a universal reply deadline. Before paying, replying or doing both, verify the current rule, notification history and the exact directions in the notice.
9. Use a document checklist before submission
| Evidence group | Include when it supports the allegation |
|---|---|
| Notice record | Complete notice, annexures, calculation sheets, reference number and service evidence |
| Outward supplies | GSTR-1, sales register, invoices, credit and debit notes, export or advance records, amendments and GSTR-3B |
| Input tax credit | GSTR-2B, purchase register, invoices, supplier amendments, credit notes, blocked-credit analysis and reversal workings |
| Books | Relevant general-ledger extracts and the journal entries that explain corrections or reversals |
| Payments and reversals | Challans, electronic ledger extracts, tax-payment records, reversal entries or refund records tied to the disputed amount |
| Procedural filing | DRC-06 or the form specified in the notice, uploaded-document list, personal-hearing selection and final acknowledgement |
Remove duplicate or irrelevant files. A concise indexed pack lets the officer move from allegation to proof without searching through unrelated accounting data.
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10. Common failure modes and how to correct them
Using one deadline for every notice
Why it fails: different forms and provisions follow different procedures. Fix: use the date and route printed in the communication and check the cited law.
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Calling GSTR-2B the final answer on ITC
Why it fails: the portal itself cautions that other legal provisions can restrict credit. Fix: perform the document, business-use and statutory-eligibility review and show any reversal.
Netting sales and purchase differences
Why it fails: a credit-note timing issue can conceal an omitted invoice or a duplicate credit. Fix: maintain separate outward-liability and ITC schedules and explain each variance.
Submitting a narrative without a calculation
Why it fails: the reviewer cannot reproduce your conclusion. Fix: include the notice-to-return-to-books bridge and attachment number for every line.
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Uploading a generic reply to the wrong route
Why it fails: DRC-01C, DRC-06 and other electronic workflows have different fields and consequences. Fix: follow the portal menu and form named in the notice, and save the acknowledgement.
Changing historical data without checking the permitted mechanism
Why it fails: GSTR-1A has a defined same-period, pre-GSTR-3B role and does not create a blanket correction facility. Fix: identify the applicable amendment or payment route before filing.
11. Final quality check before you click submit
- Does the reply identify every notice period, allegation, section and amount?
- Can a reviewer trace each disputed figure from the notice to a return entry, invoice, book entry and payment or reversal record?
- Are credit notes, debit notes, amendments, exports, advances and timing differences shown separately?
- Have duplicate credits, reverse-charge tax and legally restricted ITC been considered?
- Do the totals in the narrative, schedule and uploaded workings agree?
- Are attachment numbers consistent and every referenced file readable?
- Have you selected or declined a personal hearing deliberately rather than leaving the field unchecked?
- Is the authorised-signatory verification complete?
- Have you saved the final submission, acknowledgement and a copy of every uploaded document?
For a complex, high-value or legally disputed matter, have a qualified chartered accountant or GST practitioner review the reconciliation and proposed response before filing. Professional review is particularly valuable where the notice alleges fraud or suppression, covers multiple years, involves substantial blocked credit or combines tax, interest and penalty calculations.
12. Keep the evidence after the reply
Preserve the submitted form, acknowledgement number, portal status, final schedules, source returns, invoices, ledgers and payment records for the period required under the applicable record-retention rules. If the portal later shows an order, further intimation or hearing date, add it to the same notice folder and update the issue log. A clean chain from notice to evidence is useful not only for the first reply but also for any subsequent clarification, hearing or appeal.
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