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First identify the notice and the date that controls your reply
Read the complete notice and its attachments before drafting. Record the details below and compare them with the notice summary, if one was issued. The CGST Act and Rules cover several kinds of proceedings, so the section and procedure cited in your notice matter.
- GSTIN, notice or reference number, issuing authority, and statutory section or rule;
- tax period or financial year and the allegations made;
- issue date, service method and date, and the reply-by date stated in the notice;
- tax, interest, and penalty amounts, including the calculation and evidence cited; and
- any hearing option, payment route, or instructions for making a representation.
Do not assume the issue date is the service date. Section 169 of the CGST Act recognizes multiple methods of service, so check how and when this notice was served and whether it appears in the relevant portal records. If the service date or deadline is unclear, get case-specific advice promptly rather than relying on an assumed date.
How long do you have to reply?
Use the reply date in the notice together with the rule governing that particular proceeding. The available statutory procedures do not support applying one general number of days to every GST show-cause notice. For example, the CGST Registration Rules provide a seven-working-day response period for the specified REG-16 registration-cancellation procedure; that period is not a general deadline for tax-demand notices.
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Keep three different clocks separate: the taxpayer’s reply deadline, any deadline for the department to issue an adjudication order, and a conditional period connected with payment. Rule 142’s specified thirty-day payment mechanism does not create a universal thirty-day reply period.
Which form and filing route apply?
| Notice or procedure | What the rules identify | What to verify |
|---|---|---|
| Specified tax-demand proceedings, including covered section 73 or section 74 notices | Rule 142 provides for an electronic DRC-01 summary associated with specified notices and identifies DRC-06 as the reply or representation form in the circumstances covered by the rule. | Check the section cited, the notice and its summary, and the applicable filing instructions. Do not assume every GST notice uses DRC-06. |
| Specified registration-cancellation proceeding using REG-16 | The registration rules prescribe a distinct procedure and a seven-working-day response period for the relevant notice. | Check that the notice is the REG-16 cancellation procedure and follow its stated submission route and deadline. |
The official FORM GST DRC-06 includes fields for GSTIN, notice details, financial year, reply text, uploaded documents, and a personal-hearing choice. Use the form and portal or other service route that the notice and governing rules require; do not transfer the steps for one proceeding to another.
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How to prepare a point-by-point reply
- Match each allegation to the records. Compare the notice with relevant returns, invoices, ledgers, reconciliations, prior correspondence, and other supporting material. Mark factual errors, missing context, and disputed calculations.
- Answer issue by issue. For each allegation, state the relevant facts, your position, and the reason you agree or disagree. Refer to the supporting document by name or number so the authority can locate it.
- Explain disputed amounts. If a tax, interest, or penalty calculation appears wrong, show which entries or assumptions you dispute and provide your supporting calculation where possible. Do not leave a numerical allegation unanswered simply by making a general denial.
- Attach relevant evidence. Include records that support the response and identify them in the reply. Check that uploaded files are readable and correspond to the issues they are meant to address.
- Review the filing before submission. Confirm that the GSTIN, notice reference, period, reply text, and attachments are correct and that the submission addresses every allegation.
DRC-06 provides for a written response and a list of uploaded documents in the circumstances where that form applies. Avoid unsupported assertions: a clear explanation tied to identifiable records is more useful than a lengthy response that does not address the notice’s specific points.
Should you request a personal hearing?
Section 75(4) of the CGST Act provides for a hearing when the person makes a written request or when an adverse decision is contemplated. Where DRC-06 applies, its form includes a personal-hearing option. If a hearing is relevant to your response, make the request through the applicable procedure and keep a copy of it with your filing records.
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What if you cannot prepare the reply in time?
Section 75 allows an adjournment where sufficient cause is shown, with reasons recorded, and limits the number of adjournments during the proceeding. If you need more time, request an adjournment promptly, explain the specific reason, and follow the notice’s applicable procedure. A request is not an extension unless it is granted, so continue working toward the existing reply date while awaiting a decision.
Should you pay the amount mentioned in the notice?
Do not treat payment as a substitute for checking the notice’s legal route or deciding how to respond. Rule 142 describes reporting payment through DRC-03 and a conditional process under which qualifying payment within thirty days of service can conclude specified proceedings. Whether that process applies, what it would conclude, and whether payment is appropriate depend on the provision and facts involved. Confirm those points before relying on payment to resolve a notice.
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File carefully and preserve proof
- Use the form and submission route applicable to the specific notice, rather than assuming that one portal action covers every type of proceeding.
- Save the final reply, all attachments, and the acknowledgement or other evidence that the submission was received.
- Keep the complete notice, proof or record of service, and any later correspondence together with the filing proof.
- Check the portal and any communication channel identified in the notice for subsequent directions or hearing details.
If the amount is significant, the notice alleges fraud, the evidence is complex, or you are uncertain about limitation or jurisdiction, have the notice and draft response reviewed by a qualified GST practitioner or Indian tax lawyer. The applicable amended law and the facts of the individual proceeding determine the correct deadline and consequences.
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