A GST show-cause notice (SCN) is a proposal that you explain why tax, interest or penalty should not be determined against you. It is not a confirmed demand merely because it has been issued. Read the detailed notice and its FORM GST DRC-01 summary, identify the cited section, tax period, allegations and calculation, then file a reasoned, evidence-backed reply by the date and in the manner stated in your notice.
In the Rule 142 procedure, the reply or representation is furnished in FORM GST DRC-06. A written request for a personal hearing can be made under section 75(4). The correct section, filing route and deadline depend on your notice and the period involved, so a complex, high-value or fraud-related case should be reviewed by a qualified Indian GST practitioner.
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What a GST show-cause notice means
An SCN starts the adjudication process. The proper officer is putting proposed liability and the reasons for it to you and inviting a response before deciding whether to confirm, modify or drop the proposal. Until an order is passed, the notice itself is not the same thing as a demand order.
The notice may propose tax, interest and penalty, and it should identify the legal provision, relevant tax period, factual allegations, computation and response instructions. The electronic record normally includes a FORM GST DRC-01 summary under Rule 142 of the CGST Rules, alongside the covered notice. The summary is not a substitute for reading the full notice and attachments.
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The GST Portal distinguishes show-cause-notice status from an appeal against a demand order. Your immediate task is therefore to participate in adjudication, not to file an appeal that presupposes an order already exists. See the GST Portal’s explanation of the later appeal stage at GST Portal FAQ: appeal against a demand order.
First triage: create a case record before drafting
Download the notice, DRC-01 summary, every attachment and the portal acknowledgement. Save the files in an unaltered format and record how and when they were served. Your working cover sheet should contain the following:
| Item | What to record | Why it matters |
|---|---|---|
| Notice identity | Notice number, date, issuing authority and jurisdiction | Prevents a reply being attached to the wrong proceeding and lets you refer to the exact communication. |
| Service evidence | Portal download date, email or other service record, and downloaded copies | Preserves proof of receipt and the material supplied to you. |
| Legal route | Section cited in the notice, including any reference to section 73, 74 or 74A | The statutory conditions and procedure differ by provision. |
| Tax period | Financial year, tax months or quarters and the return periods covered | The period can determine which demand provision applies. |
| Allegations | Each distinct allegation, transaction category and explanation offered by the officer | Your reply should answer each point rather than respond with general denials. |
| Amount | Proposed tax, interest, penalty and the calculation or annexure used | You need to reconcile the proposal to your books, returns and payments. |
| Procedural dates | Reply deadline, hearing date or hearing instructions, and filing route | The notice’s directions control your immediate response. |
Do not assume that the date shown in a dashboard, an email or DRC-01 is identical to the date in the detailed notice. Note any discrepancy and address it promptly in the reply or a separate procedural request.
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Identify the governing section from the tax period and allegations
Read the period before deciding whether a section 73, 74 or 74A framework is relevant. Section 74A was introduced for relevant determinations pertaining to financial year 2024–25 onwards. Earlier periods may fall under sections 73 or 74, depending on the alleged conduct and the statutory conditions. The 2024 amendment rules also updated references to section 74A in DRC-01A with effect from 1 November 2024. Confirm the current text and the section actually cited in your notice.
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| Tax period or issue | What to check | Source |
|---|---|---|
| FY 2024–25 onwards | Whether the determination is one to which section 74A applies and whether the notice correctly states the relevant conditions. | Gazette of India, 2024 CGST amendment rules; GST Council 53rd meeting materials |
| Earlier financial years | Whether the notice invokes section 73 or section 74 and whether its facts support that route. A section 74 allegation generally requires careful attention to the notice’s assertions about fraud, wilful misstatement or suppression. | CBIC tax information portal, section 74 |
| Any period | Compare the statutory provision, factual allegations, tax computation, interest basis and penalty proposal with the underlying records. | Use the section and directions stated in your own notice and the current statutory text. |
Do not relabel a notice as a fraud case simply because a penalty is proposed. Quote the exact allegation and explain whether the facts, documents and statutory tests support it. If fraud, wilful misstatement or suppression is alleged, obtain professional advice early because the consequences and evidence issues can be substantial.
Know which GST forms are involved
| Form | Role | What you should do |
|---|---|---|
| FORM GST DRC-01 | Electronic summary of a covered show-cause notice under Rule 142, issued alongside the detailed notice. | Use it as a cross-check, but draft against the full notice, annexures and documents. |
| FORM GST DRC-06 | Reply or representation in the Rule 142 procedure. | Use the form and portal route applicable to your notice, upload the reasoned reply and evidence, and preserve the acknowledgement. |
| FORM GST DRC-01A | A distinct pre-notice communication. Rule 142 provides for a submission in Part B in the circumstances specified there. | Do not treat Part B of DRC-01A as the reply to a served SCN. Check whether the communication is pre-notice or a formal notice and follow its own instructions. |
The underlying Rule 142 text and form references are in the CBIC CGST Rules (Part A). Portal labels and workflows can change, so follow the live instructions displayed for your notice.
Build an allegation-by-allegation reply
A persuasive response lets the officer move from allegation to fact, record and legal conclusion without guessing what you mean. Prepare a working matrix before writing narrative paragraphs.
| Column | Entry to prepare |
|---|---|
| Allegation reference | Paragraph, annexure or issue number in the notice; quote a short identifying phrase. |
| Position | Mark the issue admitted, disputed or not applicable. If only part is accepted, identify that part precisely. |
| Facts | Set out the transaction chronology, parties, supply details, return treatment and relevant correspondence. |
| Legal response | Explain why the cited provision does or does not apply to those facts. Address each condition relied on by the officer. |
| Computation | Show the correction to taxable value, tax, interest or penalty, with a clear cross-reference to records. |
| Evidence | Give the exhibit number and page or file reference for each factual proposition. |
| Relief | State the precise result sought for that issue: drop it, reduce it, correct the calculation or consider the explanation and evidence. |
Keep the language factual and specific. A generic statement that the notice is “not acceptable” does not answer an invoice mismatch, classification point, input-tax-credit objection or computation. Conversely, do not make an admission merely to appear cooperative when the record does not support it.
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Reconcile the proposed tax, interest and penalty
Reperform the officer’s calculation from the source records. Depending on the allegation, reconcile the proposal to GST returns, invoices, credit notes, e-way or delivery records, ledgers, bank and payment records, agreements, electronic credit or cash ledgers, and earlier correspondence. Use a separate schedule for each tax period and issue.
- Confirm that every transaction included by the notice belongs to the stated taxpayer, registration and period.
- Identify duplicates, cancelled documents, credit notes, exempt or non-GST supplies and transactions already reported or paid.
- Match taxable value and tax rate to the invoice and return fields the notice relies on.
- Check whether interest has been calculated on the correct base and period, and show your alternative calculation where it is wrong.
- Separate tax, interest and each proposed penalty; a concession on one component should not silently admit another.
- Explain any difference between your reconciliation and the notice’s annexure line by line.
Where the notice does not disclose enough detail to reproduce the computation, identify the missing fields, request the underlying working or documents, and provide the reconciliation that can be completed from records presently available.
Assemble and index the evidence
Attach only material that supports a stated proposition, and label it so the officer can find it. A practical index may include:
| Evidence group | Typical records | Use in the reply |
|---|---|---|
| Returns and ledgers | Relevant GSTR filings, electronic liability or credit ledgers and general or sales ledgers | Shows reporting, tax payment and period treatment. |
| Transaction documents | Invoices, debit or credit notes, purchase and sales registers, contracts and delivery records | Tests whether the alleged supply, value, rate or recipient is correct. |
| Payment trail | Challans, bank records and payment references | Supports tax already discharged or a correction to the outstanding amount. |
| Correspondence | Earlier replies, audit communications, clarifications and officer letters | Shows what was previously supplied and avoids inconsistent positions. |
| Technical or factual explanation | Reconciliations, working papers, system extracts and signed statements where appropriate | Explains a data mismatch or complex transaction in a verifiable form. |
Number exhibits consecutively, add a contents page, refer to each exhibit in the relevant paragraph, and keep a complete copy of exactly what was uploaded. Redact information only where legally appropriate; do not remove context that the authority needs to verify your explanation.
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Draft the formal reply and state the relief sought
Use a clear sequence:
- Heading and authority. Identify the taxpayer, GSTIN, notice number, date, issuing officer and the tax period.
- Preliminary statement. Say that the response is to the SCN and DRC-01 summary, and identify any service, jurisdiction or document-access issue without burying the substantive answer.
- Issue-wise response. Follow the notice’s numbering. For each allegation, give the position, facts, law, calculation and exhibit reference from your matrix.
- Computation schedule. Present the proposed and corrected tax, interest and penalty separately, with totals that can be checked against the exhibits.
- Relief clause. Request that the proposed liability be dropped or modified to the amount supported by the record, that calculation errors be corrected, and that the evidence and explanations be considered.
- Procedural requests. Add a written request for a personal hearing if you want one, and any specific request for missing documents or additional time.
- Verification and signature. Complete the declaration and authorised-signatory requirements shown by the applicable form or portal workflow.
Avoid unsupported admissions, unexplained spreadsheets and boilerplate copied from an unrelated proceeding. If one issue is accepted and another disputed, separate them so the officer can decide each independently.
Request a personal hearing in writing
Section 75(4) of the CGST Act states: “An opportunity of hearing shall be granted where a request is received in writing from the person chargeable with tax or penalty, or where any adverse decision is contemplated against such person.” The text is available on the CBIC tax information portal, section 75.
If you want to explain a reconciliation, answer questions or clarify evidence orally, include an express hearing request in the reply rather than assuming that uploading documents is enough. Identify the notice, ask that the hearing be granted under section 75(4), give contact details and, if useful, state periods when you can attend. Keep the submitted copy and proof that the request was received.
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Ask for more time or an adjournment only with reasons
If records are missing or the volume of material makes the stated response date impracticable, send a reasoned request promptly and before that date. Explain what is unavailable, why it is needed, what steps you have taken to obtain it and the specific additional time requested. The law addresses adjournment for sufficient cause, with reasons recorded; a request does not automatically extend the deadline.
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File the substantive material you can responsibly provide rather than waiting silently. If the authority grants an extension or fixes another hearing date, save the written order or portal communication with your case record.
File through the route stated in the notice and preserve proof
- Log in to the GST Portal using the taxpayer credentials or authorised representative access applicable to the registration.
- Open the notice or adjudication workspace identified in the communication and confirm that the notice number and tax period match your draft.
- Select the reply or representation option indicated for that proceeding. Where Rule 142 applies, the rule identifies FORM GST DRC-06; do not substitute DRC-01A Part B for a served-notice reply.
- Upload the signed reply, computation schedules and indexed exhibits in the permitted file formats and sizes. If the portal imposes separate fields for comments and attachments, repeat the issue reference consistently.
- Complete the required verification, digital signature or electronic verification step for the taxpayer or authorised signatory.
- Submit and download the acknowledgement, ARN or other confirmation, the final uploaded PDF and the attachment list. Record the date and time shown by the system.
If the portal fails, capture the error, time and notice details, and use the alternative channel expressly permitted by the notice or current portal instructions. Do not rely on an unsent draft or an email that the notice does not recognise as a filing route.
What happens after the reply
Monitor the notice workspace, registered email and other service channels for hearing communications, requests for clarification and the adjudication order. Keep a log of every submission and communication. If the officer confirms, changes or drops the proposal, compare the order with each issue and computation in your reply.
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1Scan for outdated or missing drivers - takes under a minute2Repair Windows errors before they cause bigger problems3Fix the driver behind crashes, sound loss and screen glitchesAn order confirming liability creates a separate decision point. Assess the appeal process, forum and time limit from that order and the current law; the SCN reply is not itself an appeal. If the order contains a new issue or amount that was not fairly put to you, obtain advice promptly about the available procedural response.
Common mistakes that weaken an SCN response
- Responding only to the DRC-01 summary and ignoring the detailed notice or annexures.
- Using a fixed “standard” deadline instead of the date and directions in the actual notice.
- Confusing a DRC-01A pre-notice submission with a DRC-06 reply to a served SCN.
- Choosing section 73, 74 or 74A without checking the tax period and the allegations stated.
- Submitting a narrative with no allegation index, calculation schedule or exhibit references.
- Admitting tax, fraud, wilful misstatement or suppression without checking the factual and legal basis.
- Requesting a hearing orally or informally but keeping no written proof of the request.
- Uploading an unsigned, incomplete or different version from the copy retained internally.
- Assuming that an extension request automatically pauses the response date.
- Treating a later demand order as if the SCN stage were already an appeal.
When to obtain professional help
Consult a qualified Indian GST practitioner or indirect-tax adviser where the proposed amount is material, multiple registrations or periods are involved, records are incomplete, the notice alleges fraud, wilful misstatement or suppression, or the computation cannot be reproduced. Give the adviser the original notice, DRC-01, all attachments, service proof, your draft matrix, return and ledger exports, payment records and prior correspondence. Early review is more useful than asking someone to repair an unsupported admission after filing.
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