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THE FINANCEBASE List yours

Guide

How to respond to a GST demand notice and meet the deadline

By TheFinanceBase Team 10 min read

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Start by identifying exactly what you received. A GST show-cause notice, its DRC-01 summary, a DRC-01D recovery intimation and a DRC-07 order are different documents with different next steps. The deadline printed in your own notice, the legal provision it cites and the way it was served control your immediate response; there is no single, reliable reply period that applies to every GST notice.

Download the complete notice and annexures from the GST Portal, record the due date, prepare a point-by-point answer with records, and file it through the channel specified for that proceeding. Do not confuse a notice reply with an appeal from an order or assume that a payment form means payment is automatically the right answer.

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First identify which GST document you received

Read the document heading, form number, section cited and the relief or action demanded. GSTN’s published form descriptions distinguish these forms, and the distinction determines what you can file next.

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Document or form What it generally represents Immediate task
Show-cause notice (SCN) The department’s allegations and proposed tax, interest or penalty before an adjudication decision. Read the full notice, calculate the response date stated in it and submit a reasoned reply in the prescribed channel.
DRC-01 A summary of a show-cause notice. GSTN describes it as a summary that is served with the notice. Use the complete notice and annexures, not the summary alone, to prepare your response.
DRC-06 GSTN’s listed form for a taxpayer’s reply to a show-cause notice. File the reply and attachments through the GST Portal functionality available for that notice, then preserve the acknowledgement.
DRC-03 An intimation of voluntary payment or payment made against a notice or statement. Decide, based on the facts and law, whether payment, dispute, or a permitted partial payment is appropriate; the form itself does not settle that decision.
DRC-01D A recovery intimation for an amount recoverable under section 79, described in GSTN’s April–June 2024 functionality note. Do not treat it as an ordinary SCN reply. The historical note says no reply can be submitted through that functionality and describes payment within seven days from issue before recovery proceedings may begin. Verify the current portal and law immediately.
DRC-07 A summary of an adjudication order. Check whether the order is appealable and calculate the separate appeal period; a DRC-07 is not the initial notice stage.

If the portal notification and the downloaded PDF appear inconsistent, save both, note the dates and seek prompt professional advice. Never rely on an email subject line or a DRC-01 amount without opening the underlying notice.

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How to find the complete notice and attachments

  1. Sign in to the GST Portal using the registered taxpayer credentials. Use the legal entity’s account, not a personal account that cannot access the taxpayer record.
  2. Open the portal area labelled “Additional Notices & Orders” (or the current equivalent). Portal labels can change, so use the notice number, tax period and date to locate the record.
  3. Download every available file. Save the notice, DRC-01 summary, annexures, relied-upon statements, computations, hearing communications and any order or payment reference shown with it.
  4. Check that the files are complete. Compare annexure numbers, page counts, tax periods, GSTIN, legal name and the tax, interest and penalty breakup. A missing annexure can change the allegation and should be raised in the response or in a request for access.
  5. Create a dated evidence folder. Keep the original downloads unchanged, then work from copies. Record the portal download date and the notice’s stated service date.

GSTN’s functionality material explains that DRC-01 is made available with the notice through the portal. That summary is not a substitute for the notice, relied-upon material or calculation on which the department proposes to act.

How to determine the deadline that applies to your notice

Do not copy a deadline from another taxpayer’s case. The retrieved GSTN material does not establish one universal notice-stage response period, and it does not resolve every transition issue involving section 74A. Your own notice and the current Central Goods and Services Tax Act, rules, amendments and extensions must be checked.

Record the controlling dates

  • Date of issue: the date printed on the notice or generated in the portal.
  • Date and manner of service: the portal posting, email, physical delivery or other method recorded for your case.
  • Response due date: the date expressly stated in the notice, including any hearing date or separate document-submission date.
  • Provision cited: note whether the notice refers to section 73, 74, 74A or another provision, and read any rule or notification incorporated by reference.
  • Tax period: write the financial year, return period or transaction period covered. A notice may cover several periods with different calculations.
  • Extensions: record any general or case-specific extension and retain the notification or portal message that supports it.

Place the earliest defensible filing date on your calendar, not the last date you think might apply. If the date is unclear, file a clarification or extension request through the available channel and obtain legal advice while continuing the substantive response. An unanswered notice can move toward an order even when the taxpayer is still trying to reconstruct records.

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Keep notice and appeal deadlines separate

The deadline to answer a show-cause notice is not the deadline to appeal a DRC-07 or other adjudication order. GSTN’s FAQ on filing an appeal against a demand order summarizes a three-month period from communication of a qualifying decision or order, with up to one additional month of condonation for sufficient cause. The same FAQ summarizes a minimum pre-deposit of 10% of disputed tax. Those are order-stage appeal summaries; they do not create a notice-stage reply period. Verify the current statutory provision, order type, computation and filing requirements before relying on them.

Build a point-by-point GST notice response

A useful reply lets the officer match each allegation to your position and evidence without guessing. There is no single official attachment list for every allegation, so include only records that prove or explain the points in your particular notice.

Make an allegation matrix

Notice point Your position Evidence and calculation Requested result
Quote the paragraph, table or annexure reference and the amount. Admitted, partly admitted, disputed, or not understood. Identify the return, invoice, ledger, reconciliation, contract, payment record or correspondence that supports the position. Withdraw the proposed demand, correct the amount, allow credit, or grant another specific procedural relief.

Use the notice’s numbering. If an allegation is wrong, state the exact correction rather than simply saying “not acceptable.” If the department’s computation is incomplete, show your own calculation and explain each difference.

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Match records to the allegation

  • Turnover or tax mismatch: reconcile the relevant returns, sales register, general ledger and tax payment records for the exact period.
  • Input tax credit issue: identify the invoices, supplier information, payment trail, accounting entries and reconciliation that address the stated defect. Do not attach unrelated purchase files merely to make the bundle larger.
  • Classification or rate issue: provide the invoice description, contract or scope of supply, classification analysis and the rate used for each disputed item.
  • Place-of-supply or export issue: include contracts, shipping or delivery records, recipient details and payment evidence relevant to the allegation.
  • Interest or penalty calculation: reproduce the department’s figures, show your alternative calculation and identify payments, credits or dates that alter the result.
  • Procedural or service objection: preserve the portal notification, service record, earlier correspondence and any request for documents or hearing.

Label each attachment and cross-reference it in the paragraph where it is used. Redact unrelated personal information, but do not remove dates, GSTINs, invoice numbers or totals needed to verify your explanation.

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State what is admitted and what is disputed

Silence can make a response difficult to interpret. Separate uncontested arithmetic or tax from genuinely disputed liability. If you accept a limited amount, identify the exact tax, interest and penalty components and explain whether a payment has already been made or is being proposed. Do not describe a payment as a concession unless you intend that legal effect and have taken advice.

Submit the reply through the correct channel and preserve proof

  1. Use the notice-specific reply functionality. GSTN identifies DRC-06 as the reply form for a show-cause notice. Open the relevant notice in the portal and use the current filing workflow offered for that record.
  2. Complete every required field. Enter the notice number, date, tax period and amounts exactly as shown. A mismatch can make it hard to connect the reply to the proceeding.
  3. Upload the signed or authenticated reply and indexed attachments. Follow the portal’s current file-size, format and signing requirements. If the portal limits attachments, combine logically numbered files and explain the index in the reply.
  4. Submit before the recorded deadline. Do not wait until the final hour; portal outages, authentication failures and file-validation errors can prevent filing.
  5. Save evidence of filing. Download the filed DRC-06, acknowledgement or reference number, submission timestamp, uploaded files and any confirmation page. Keep a copy of the notice and the exact version submitted.
  6. Monitor the portal afterward. A hearing notice, request for additional information or order may appear separately. Check the registered email and portal notices regularly.

If technical failure prevents filing, capture screenshots showing the error and time, contact the portal support route identified on the site, and seek advice on a contemporaneous alternative submission. A later explanation is stronger when it includes objective proof of the failed attempt.

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Should you pay through DRC-03?

DRC-03 is described by GSTN as an intimation of voluntary payment or payment against a notice or statement. Its existence does not by itself prove that the proposed demand is correct or that immediate payment is mandatory.

Questions to answer before paying

  • What exact legal and factual allegation does the payment address?
  • Does the amount include tax, interest and penalty, and are those components separately supported?
  • Are you accepting the whole demand, only an uncontested portion, or making a payment for another reason allowed by law?
  • Will payment affect your right to contest the balance or require a particular disclosure?
  • Can the payment be accurately linked to the notice number, period and taxpayer account?

Compare the proposed amount with your own reconciliation and obtain tax advice where liability, limitation, classification, input tax credit or penalty is disputed. If you make a payment, retain the DRC-03 reference, challan, bank confirmation and the explanation of what the payment covers. Continue to meet the notice-response deadline unless the authority has formally changed it.

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What to do when the document is DRC-01D

Do not answer a DRC-01D as though it were an ordinary show-cause notice. GSTN’s April–June 2024 functionality note describes DRC-01D as an intimation for an amount recoverable under section 79. It states that the taxpayer cannot submit a reply through that functionality and describes payment within seven days from issue before recovery proceedings may be initiated.

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Because that description comes from a historical functionality release, verify the live document, current portal behavior and current law immediately. Record the issue date, amount and section 79 reference; check whether an earlier order or demand exists; and obtain urgent professional advice about payment, stay, rectification or other available remedies. Preserve proof of every contact and attempted submission.

If a DRC-07 order has already been issued

A DRC-07 summary signals an adjudication order stage, not merely a proposal. Download the full order and computation, identify the communication date and determine whether the order is appealable. Read the order’s reasoning, confirmed tax, interest and penalty, adjustment of prior payments and any recovery instruction.

Check the appeal window separately

GSTN’s appeal FAQ summarizes filing an appeal against a qualifying decision or order within three months from communication, with authority to condone up to one further month for sufficient cause. It also summarizes a minimum pre-deposit of 10% of disputed tax. Treat these as portal guidance, not a substitute for checking the current statute, the exact order type, the disputed-tax calculation and the filing prerequisites for your case.

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Do not wait for recovery action before examining appeal options. Assemble the order, notice, DRC-01, your DRC-06 reply, acknowledgements, hearing records, payment references and evidence bundle so the appeal grounds can be tied to the adjudication findings.

Common mistakes that cause avoidable problems

  • Using the DRC-01 summary alone: the summary may omit factual detail or relied-upon material found in the full notice and annexures.
  • Assuming a standard reply period: the applicable date depends on the notice, service, provision, period and any extension.
  • Confusing reply and appeal dates: an appeal period after DRC-07 does not answer an SCN.
  • Sending a narrative without a reconciliation: unsupported assertions do not show how the department’s figures are wrong.
  • Uploading unlabelled documents: an officer cannot reliably connect a large bundle to individual allegations.
  • Paying without defining the purpose: a DRC-03 entry should be tied to a specific liability and retained with its proof.
  • Ignoring a recovery intimation: DRC-01D is a different stage and may require urgent action.
  • Failing to preserve submission proof: keep the filed form, attachments, acknowledgement, reference number and timestamps.

A practical deadline-day checklist

  1. Identify the document: SCN, DRC-01, DRC-01D or DRC-07.
  2. Download the full record and all annexures from “Additional Notices & Orders.”
  3. Write down GSTIN, notice number, issue date, service date, tax period, section and stated due date.
  4. Check whether the date is for a reply, hearing, payment, or appeal.
  5. Build an allegation matrix with an admission or dispute, explanation, evidence and requested outcome for every point.
  6. Reconcile tax, interest and penalty with returns, ledgers, invoices and payment records relevant to the allegation.
  7. Decide separately whether any DRC-03 payment is legally and commercially appropriate.
  8. File the notice reply using DRC-06 where the portal identifies that form, before the recorded deadline.
  9. Download the acknowledgement and submitted files, then monitor for hearings, queries or orders.
  10. Escalate promptly to a qualified GST professional when the amount is material, records are missing, a recovery intimation has arrived, or an order has already been issued.

The safest approach is procedural discipline: classify the document, use the date and provision in that document, answer every allegation with traceable evidence, and preserve proof of what you filed. A GST Portal form number is a clue to the stage of the case, not a replacement for reading the complete record or checking the law currently in force.

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