For a notice whose summary is uploaded electronically in FORM GST DRC-01, rule 142(4) of the Central Goods and Services Tax (CGST) Rules specifies FORM GST DRC-06 for the reply. Read the full notice and its annexures, identify the legal provision and deadline stated there, then answer each allegation with clearly labelled supporting records. Not every document called a GST show-cause notice necessarily follows the DRC-06 route; follow the process stated in your notice and verify the current rules that apply to your proceeding.
First, identify the notice, its legal basis and your deadline
Start with the complete notice, not only its electronic summary. Under rule 142, a summary in DRC-01 accompanies specified notices, while DRC-02 is used for certain statements. The notice and any annexures or relied-upon material may contain allegations and details that are not apparent from the summary. The rule is set out in the CBIC-hosted CGST Rules, 2017, Part A; the retrieved copy is dated 2021, so later amendments may affect the applicable procedure.
Make a working record of the following before drafting:
- Notice number and the issue and service dates shown.
- Tax period or financial year and the statutory section cited.
- Each allegation, proposed tax, interest and penalty, and the calculations or records relied on.
- The response deadline and any hearing details or payment option stated in the notice.
- Any annexures, statements or other material referred to but not included in the summary.
Use the deadline in your notice as the immediate reference point. The materials cited here do not establish the deadline for your particular notice or a universal number of days, so do not import a timeline from a different proceeding.
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Why the statutory section matters
The cited CGST Act text distinguishes sections 73 and 74 by the grounds alleged. That distinction can affect how you frame the response and which legal consequences or timelines may apply. The Act page linked below is older and does not by itself establish current amendments or the complete current rules for section 74A. The GST Portal’s appeal FAQ mentions section 74A among demand-order categories, but does not explain the notice-reply procedure. Confirm the provision, effective date and current applicable law for your case before relying on a template or timeline.
| Provision | What the cited Act text establishes | What to check before replying |
|---|---|---|
| Section 73 | Addresses cases other than fraud, wilful misstatement or suppression to evade tax. | Check the notice’s stated grounds, applicable version of the law and the specific deadline or payment option in the notice. |
| Section 74 | Addresses the specified fraud-related grounds of fraud, wilful misstatement or suppression to evade tax. | Examine the factual basis for those allegations and verify the applicable legal consequences and procedure against current authoritative material. |
| Section 74A | The GST Portal appeal FAQ lists section 74A among appealable demand-order categories; the cited sources do not establish its complete current notice-reply rules. | Do not assume that the section 73 or 74 explanation or timelines apply. Confirm the current provision and effective date relevant to the notice. |
Sources: CBIC-hosted CGST Act text and the GST Portal appeal FAQ.
How to prepare a point-by-point reply and evidence schedule
Build the response around the notice’s numbered allegations. A simple schedule helps the officer and your adviser trace each assertion to the record that supports it. This is a practical drafting method, not a statutory exhaustive evidence checklist.
- Classify each allegation. Mark whether you admit it, dispute it, or need clarification. If only part is admitted, identify the precise part rather than giving an unqualified response.
- State the relevant facts. Identify the period, transaction, amount and records involved. Keep factual explanation separate from legal submissions.
- Match evidence to the point. Depending on the allegation, relevant material may include returns, invoices, ledgers, contracts, payment proof, reconciliations or correspondence. Include only records that support or clarify the point.
- Explain calculations and differences. Give the period, amount, source records and calculation method for a reconciliation or other numerical explanation. Do not leave the reader to infer how an attachment answers the allegation.
- Label every attachment consistently. For example, refer to a file as “Annexure A” in the reply and use the same label in the uploaded-document list. Check that the cited attachment actually contains the relevant record.
- Address the material relied upon. If the notice refers to annexures or records beyond the summary, respond to the substance of those materials rather than treating the summary as the whole case.
DRC-06 provides a reply field and a list of uploaded documents; it does not supply a universal argument template. The prescribed form is in the CBIC-hosted CGST Rules, 2017, Part B forms PDF.
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What to include in FORM GST DRC-06
Where rule 142(4) applies, furnish the reply in FORM GST DRC-06. The form captures the taxpayer’s GSTIN and name, notice reference and issue date, financial year, reply, uploaded-document list, personal-hearing option and authorised-signatory verification. Complete the fields against the actual notice and ensure the reply and document list refer to the same evidence labels.
The form PDF is an official form reference, not a guarantee that the portal screens or upload requirements currently look the same. Follow the instructions and live filing route associated with your notice. The source materials do not establish current attachment-size limits or every portal screen.
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Should you request a personal hearing?
DRC-06 includes a personal-hearing option. Section 75 of the CGST Act says an opportunity of hearing is to be granted where requested in writing or where an adverse decision is contemplated. If you want a hearing, make the request expressly in writing and retain it with your filed reply. See the CBIC-hosted CGST Act text.
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- Use the filing route and instructions stated in the notice and applicable live GST Portal process; use DRC-06 where the rule 142(4) route applies.
- Before submitting, check that the reply addresses every allegation, attachment labels match the uploaded-document list, and each file opens and is readable.
- After filing, save a copy of the reply and attachments, the ARN, acknowledgement or other portal receipt, and any written hearing request.
- Keep the notice, relied-upon material and filing proof together so you can refer to the same record if the proceeding continues.
The available official references establish the DRC-06 form and electronic handling under rule 142, but they do not establish every current portal screen or upload limit. Do not rely on an assumed file-size limit or interface description.
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When to get professional help
Consider having a qualified GST practitioner review the response when the notice alleges fraud, wilful misstatement or suppression; the proposed liability is substantial; the dispute turns on complex input tax credit or reconciliation issues; or the stated deadline is close. This is particularly important where the legal classification itself is contested, because a response framed for a different statutory provision may not address the allegations or consequences in the notice.
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