Start by identifying the notice’s statutory section, form, tax period, allegations and stated response date. Then check each proposed amount against your returns and records, prepare a point-by-point reply with indexed supporting documents, and file it through the route that applies to that notice. FORM GST DRC-06 is used for replies covered by Rule 142(4)—not automatically for every GST communication. Keep the filed reply, attachments and acknowledgement, and request a hearing in writing if one is needed.
First identify what kind of GST communication you received
A show-cause notice proposing a demand under section 73 or 74 is different from a scrutiny discrepancy notice under section 61. The cited section and form help determine how to respond; the notice’s allegations, annexures and portal record show what you must address. Do not choose a reply form simply because a communication concerns GST.
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Download the complete notice and all available annexures, summaries and related portal messages. Record the notice reference, date and mode of service, issuing officer, GSTIN, tax period, stated response deadline and any hearing date. Compare the detailed notice with its electronic summary and flag missing or inconsistent information. Under Rule 142, covered demand notices have a summary in DRC-01, while a covered statement under section 73(3) or 74(3) has a summary in DRC-02.
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Which form or response route applies?
For a notice covered by Rule 142(4), furnish the reply in FORM GST DRC-06. The rule ties that form to notices whose summary is electronically uploaded in DRC-01. A scrutiny discrepancy communicated in ASMT-10 instead follows the ASMT-11 route for explaining or accepting the discrepancy.
| Form | Function in the cited CBIC material |
|---|---|
| DRC-01 | Electronic summary accompanying covered demand notices. |
| DRC-02 | Electronic summary accompanying a covered statement under section 73(3) or 74(3). |
| DRC-03 | Intimation of specified payment. |
| DRC-04 | Acknowledgement of specified payment. |
| DRC-05 | Order concluding covered proceedings following qualifying payment. |
| DRC-06 | Reply to notices covered by Rule 142(4). |
| DRC-07 | Electronic summary of an order; treated as a notice for recovery. |
| ASMT-10 | Scrutiny discrepancy notice. Its stated response period cannot exceed fifteen days under the cited CBIC assessment rules. |
| ASMT-11 | Response or acceptance of a scrutiny discrepancy. |
These form functions are based on CBIC-hosted rules material that identifies amendments through 1 January 2022. Confirm the current rules and portal process, as later amendments or notifications may affect them.
How much time do you have to reply?
There is no safe universal deadline for every GST show-cause notice. Follow the date and instructions in your particular notice and check the provision it cites. The CBIC assessment rules specifically state that an ASMT-10 notice must give a response period not exceeding fifteen days. That limit applies to this scrutiny procedure; it is not a general deadline for demand notices under sections 73 or 74.
Do not assume that a payment period mentioned in a statutory provision is also the deadline to submit a reply. For example, sections 73(8) and 74(8) include thirty-day periods for specified payment consequences after notice, but those provisions do not establish a blanket reply deadline. The law and consequences differ between the sections, and the applicable text can depend on the tax period and amendments.
Build an allegation-by-allegation evidence file
There is no universal statutory attachment checklist for every notice. Choose records that substantiate the particular facts and calculations being challenged. Practical documents to consider include:
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- The complete notice, its summary, annexures and related portal correspondence.
- Returns and reconciliations for the tax periods at issue.
- Sales and purchase invoices, plus relevant credit or debit notes.
- Electronic and accounting ledgers, payment challans, and DRC-03 or DRC-04 records if relevant.
- Contracts, purchase orders, delivery or transport records, and correspondence that bears on the alleged supply.
- Input tax credit records and reconciliations when credit is disputed.
- A calculation schedule comparing your figures with the department’s figures.
Create an index and label each attachment so that the relevant document is easy to locate from the corresponding reply point. The DRC-01 summary identifies brief facts, grounds, tax and other dues; it does not make every document above mandatory in every case.
Draft a clear, point-by-point reply
- Identify the case. State the notice reference, GSTIN, tax period, cited section and notice date.
- Follow the notice’s sequence. Respond separately to each ground or paragraph so it is clear what is admitted, disputed or requires clarification.
- Explain the facts and legal basis. Address the actual allegation, acknowledge contrary facts where relevant, and avoid unsupported assertions or broad admissions.
- Show the calculation. Set out your figures beside the department’s figures, broken down as relevant by tax, interest, penalty, period and tax head. Identify any amount already paid and attach supporting proof.
- Connect claims to evidence. Cite the annexure number for each material factual statement and include an index.
- Identify what is missing. If information or material relied on is needed to respond fully, specify it clearly.
- State what you seek. Request a reasoned decision on your submissions and evidence, and request a personal hearing in writing if you need one.
Keep a complete copy of the submitted package. Do not send sensitive original records unless the proper process specifically requires them.
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Understand the section cited before deciding whether to pay or contest
Section 73 concerns specified tax, refund or input-tax-credit issues for reasons other than fraud, wilful misstatement or suppression of facts to evade tax. Section 74 addresses those issues when the notice alleges fraud, wilful misstatement or suppression to evade tax. A section 74 allegation is not proof that the alleged conduct occurred: respond to the notice’s actual facts and legal grounds.
The sections have different payment and penalty consequences and different outer periods for orders. The tax period and applicable amendments matter, so do not rely on a general summary to calculate a case-specific amount or deadline.
Before deciding whether to pay, contest, or address only part of a proposed demand, compare the factual and legal strength of each ground, the available records, confidence in the calculations, consequences under the cited section and time available to prepare a complete response. The Act and rules describe payment routes, including specified payments before notice and within thirty days after notice under subsections (8); the consequences are not identical under sections 73 and 74. Rule 142 provides for DRC-03 to intimate specified payments and DRC-05 in the covered conclusion process. Verify the current law and calculation before acting.
Ask for a hearing in writing when appropriate
Section 75(4) of the Central Goods and Services Tax Act, 2017 says: “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.” If a hearing would help you explain disputed facts or calculations, make the request in writing and keep proof of it. A hearing request does not replace the written reply.
File the reply and preserve proof
- Use the method and deadline specified in the notice and the procedure applicable to that notice type. For a notice covered by Rule 142(4), use DRC-06; for an ASMT-10 scrutiny notice, use the ASMT-11 route.
- Check that the final reply and each attachment are complete, readable and consistent with the figures in the reply.
- Save the submitted reply, attachments, filing reference and portal acknowledgement. Keep proof of any separate written hearing request.
If the portal is unavailable or the deadline is close, seek prompt professional advice about a legally valid way to preserve your response. The cited material does not establish a universal fallback filing procedure.
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Rule 142 provides for DRC-07 as the electronic summary of an order and treats that summary as a notice for recovery. If an adverse order arrives, read the complete order—not just its summary—and promptly verify the applicable correction, review or appeal route and deadline with a qualified adviser. Those post-order deadlines depend on the circumstances and are not set out comprehensively here.
When professional help is especially useful
Consider consulting a GST practitioner, chartered accountant or tax counsel if the proposed demand is substantial, the notice alleges section 74 conduct, input tax credit is disputed, reconciliations are complex, or a hearing is scheduled. A professional can review the notice, calculations, evidence and current law together; this article is general information, not individualized tax or legal advice.
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