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How to Respond to an Indian GST Show-Cause Notice: Documents, Deadlines and Next Steps

Learn how to review an Indian GST show-cause notice, organize evidence, file a DRC-06 reply where applicable, and confirm the deadline for your notice.
From TheFinanceBase Team15 min to read
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Read the complete notice and its annexures, check the DRC-01 electronic summary, identify the GSTIN, tax period and statutory section, then answer every allegation separately with records and a reconciled calculation. Where the notice summary is uploaded in FORM GST DRC-01, the CGST Rules identify FORM GST DRC-06 for the reply. The deadline depends on the notice and applicable law: use the date printed in your notice and verify the current provision for its section, tax period and jurisdiction rather than assuming one standard reply period.

What a GST show-cause notice asks you to do

A show-cause notice (SCN) is a communication from a tax authority setting out proposed action and asking you to respond. In a GST matter, it may state the department’s view of the facts, the legal grounds, and proposed tax, interest, penalty or other dues. The notice is not the final order. Your reply is the opportunity to explain why the proposal should be withdrawn, changed or limited, and to provide records supporting that position.

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This guide concerns Indian GST proceedings under the Central Goods and Services Tax (CGST) framework, alongside any corresponding State or Union Territory law that applies. The right procedure depends on the section named in the notice, the tax period and the facts. Treat the complete notice—not just a portal summary—as the document to answer.

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An SCN can raise more than one issue or cover multiple tax periods. Read its allegations as distinct questions, rather than treating the total proposed demand as a single figure. For example, a difference in reported turnover and a separate ITC issue require different supporting records and may have different calculations. The response should make clear which facts and amounts relate to each issue.

What to check first

Act promptly. Save the notice, annexures, electronic summary and proof of service, then make a working copy for review. The DRC-01 summary includes reference and issue details, tax period, financial year, Act and section, brief facts, grounds, and a table of amounts. Compare these fields with the full notice and your GST records.

  1. Record service and dates. Note when and how the notice arrived, the response deadline printed on it, and any hearing date. Save portal messages, email or other delivery records along with the notice.
  2. Verify the recipient and authority. Check the GSTIN, legal name, issuing officer and jurisdiction. Flag a mismatch for review; do not assume a mismatch automatically invalidates the notice.
  3. Identify the legal route. Record the statutory section, financial year and each tax period cited. Confirm that the figures and allegations in the summary match the complete notice and its annexures.
  4. Separate the allegations. Create one row per issue, recording the department’s claim, the proposed tax, interest and penalty, the relevant records, and your response. This prevents a response to one issue from obscuring another.
  5. Calendar the next actions. Track the reply deadline, any hearing, and internal dates for gathering records and review. Verify the applicable time limit against current legislation for that specific notice and jurisdiction.

Keep a simple issue tracker with columns for the notice paragraph or annexure reference, the department’s claim, tax period, amount, records to retrieve, your position and exhibit number. Mark missing records and assign someone to obtain them. This helps identify whether an apparent difference is caused by a return-period mismatch, a transaction recorded in another ledger, or a substantive disagreement. Do not leave an allegation unanswered merely because the relevant records are still being gathered; identify what is missing and seek appropriate advice on the response and timing.

Check that the notice’s factual description and demand table are internally consistent. A discrepancy is a point to address, not proof by itself that the notice is invalid. Under section 75 in the CBIC-hosted CGST Act text examined for this guide, an order is limited to the amount and grounds specified in the notice and must set out relevant facts and the basis of decision. Preserve the versions of the notice and summary you received so you can refer to their exact wording if the figures or grounds appear different.

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How to establish the applicable deadline

There is no safe universal reply period to quote for every GST SCN. The time allowed can depend on the statutory provision, the period involved and applicable current law. Start with the deadline printed in the notice, and confirm it against the law applicable to your case before relying on a general guide or an old example.

Currency matters. The CBIC-hosted CGST Act text available for this guide includes sections 73, 74 and 75, but does not include section 74A. The available CGST Rules PDF is dated 1 January 2022. Those materials therefore cannot establish a current deadline for every category of notice or tax period. If the notice cites a provision not addressed by the text you are consulting, or the date appears inconsistent, seek current, notice-specific advice promptly. Do not wait for that review to begin gathering records.

When verifying the deadline, check the section actually cited, the tax period to which each allegation relates, the law in force for that period, and the applicable State or Union Territory framework. Also distinguish the reply date printed in the notice from dates for a hearing, payment route or later appeal. These are not interchangeable milestones. If the notice gives more than one date, identify what action each date applies to and confirm any ambiguity through the appropriate channel or a qualified adviser.

Keep evidence of service because the date and method of communication may matter when assessing a time limit or a payment option. If you discover the notice late, or the deadline is close, do not assume an informal contact with the department extends it. Check the current procedure and take prompt steps to prepare or file the response through the applicable process. A request for an adjournment should not be treated as an automatic extension of the reply deadline.

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Which documents to gather

Build the evidence around the allegation. Sending every record you possess can make the relevant proof harder to identify and may disclose unrelated sensitive information. Use a separate evidence set for each disputed issue, and keep a copy of everything submitted.

  • Notice and service file: the complete SCN, annexures, DRC-01 summary, any earlier DRC-01A communication, portal messages and proof of service.
  • Returns and reconciliations: the relevant GSTR-1, GSTR-3B and, where relevant to the issue, GSTR-2B or GSTR-2A; reconciliations, annual-return material or audit records where they bear on the allegation.
  • Transaction records: tax invoices, debit and credit notes, sales or purchase registers, ledgers, contracts, payment evidence, e-way bills, shipping or delivery records, and relevant business communications.
  • Input tax credit (ITC) records, if challenged: supplier invoices, evidence of receipt and use, supplier and payment details, ledger entries, return reconciliations, and workings for any reversal or repayment where applicable.
  • Calculations: a schedule that shows your position by tax period and separately identifies tax, interest, penalty and other amounts, with the basis for each figure. The DRC-01 summary itself separates tax, interest, penalty, fees, other dues and total.

This is a practical menu, not a mandatory checklist for every SCN. Include a document only when it helps prove or explain a relevant fact, calculation or legal position. For each exhibit, use a clear filename or index reference and point to the exact part that supports your response.

For each amount, work from the source records to the relevant return and then compare your calculation with the notice. Record the period, transaction or entry involved and the reason for any difference. If you dispute an interest or penalty figure separately from the tax amount, show that distinction rather than folding all components into one total. The DRC-01 summary’s separate amount categories make this reconciliation especially useful.

For an ITC allegation, organize records so the connection between the invoice, the relevant transaction and your accounting and return records is easy to follow. A supplier invoice alone may not explain every factual point the notice raises: include receipt, use, payment or reversal evidence when it is relevant to the specific allegation. For other transaction disputes, contracts and delivery evidence may help explain what occurred, while ledgers and payment records help trace how it was recorded. Avoid treating any one document list as conclusive without checking the actual grounds in the SCN.

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How to prepare a point-by-point reply

A useful reply makes it easy to connect each allegation to your answer and evidence. Match the notice’s numbering and grounds where possible. If the notice combines several claims, separate them in your response so that the facts and calculations for one do not get confused with another.

  1. Identify the notice. State the SCN reference number, issue date, GSTIN, financial year and tax periods. Say that the submission is your reply to that notice.
  2. Give a short background. Describe only the business or transaction facts needed to understand the disputed issues. List the issues you will address.
  3. Answer each allegation separately. State whether you agree, disagree or agree in part. Explain the relevant facts, then set out the legal basis for your position.
  4. Connect evidence to claims. Cite each supporting exhibit by its index number or filename, and explain what it shows. A large upload without a clear link to the allegations is less useful than a focused, indexed record set.
  5. Reconcile the amounts. Present a period-by-period calculation separating admitted and disputed portions. Show how you arrived at tax, interest, penalty and other figures, and identify any difference from the notice.
  6. State the requested outcome. Ask for withdrawal or modification of the proposed demand to the extent supported by the facts and law. Be precise about which issues and amounts your request covers.
  7. Make procedural requests clearly. If you need a personal hearing, request one in writing and select the hearing option in the form. If an adjournment is needed, explain the sufficient cause and request it in writing.
  8. Complete and retain the filing record. Verify the submission, attach legible documents, file through the required portal or process, and save the exact reply, exhibits and acknowledgement.

In each issue response, a clear sequence helps: restate the allegation fairly, identify the facts you accept or dispute, point to evidence, explain your calculation, and state the relief you seek. If you agree with one factual point but dispute the conclusion or amount, say so directly. If your records do not support a particular statement, do not overstate what they prove. A precise response is easier to assess and creates a better record of the disagreement.

Use a short opening summary to list the issues and the overall position, but do not let it replace the detailed replies. Attach a reconciliation table where figures are disputed, and refer to it in the relevant issue section. Keep terminology consistent across the narrative, table and uploaded documents—for example, use the same exhibit label in the text and document list. Review the final set for legibility, completeness and unintended personal or commercially sensitive material unrelated to the allegations.

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Do not rely on a claim that a notice is defective as a substitute for answering the substance. Review whether it identifies the factual basis and statutory provision, and whether the amounts correspond to the allegations. Section 75 of the CGST Act text available for this guide says an order is limited to the amount and grounds specified in the notice and requires relevant facts and the basis of decision in the order. A possible defect is a matter for case-specific legal analysis, not an automatic conclusion that the notice has no effect.

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Which form to use and how to file

For a notice whose summary is uploaded electronically in FORM GST DRC-01, rule 142(4) identifies FORM GST DRC-06 for submitting the representation or reply. The official form asks for the GSTIN and name, SCN reference number and issue date, financial year, reply text, uploaded documents, a personal-hearing choice, and verification by an authorised signatory.

  1. Open the relevant GST notice and confirm that its summary is in DRC-01 and that DRC-06 is the applicable reply route for your notice.
  2. Prepare the narrative and indexed supporting files before completing the form, so the reply text and document list refer to the same exhibits.
  3. Enter the notice particulars accurately, provide the point-by-point response, list and upload the documents, and select the personal-hearing option if requesting one.
  4. Complete the verification through the authorised signatory and submit using the applicable portal process.
  5. Save the submitted form, all uploaded files and the portal acknowledgement. Record the submission date and any reference number.

Portal labels and processes can change. Follow the current filing flow shown for your notice and preserve evidence of submission. If the notice does not fit the DRC-01/DRC-06 route, confirm the required process rather than forcing the response into a form that may not apply.

Before submission, check that the SCN reference number and issue date match the notice, the financial year and tax periods are correct, and all attachments listed in the reply are actually uploaded. Confirm that the authorised signatory completes the verification and that the requested hearing choice is recorded. After submitting, reopen or download the filed copy if the portal allows it and compare it with your final version; keep the acknowledgement with that exact copy.

Personal hearings and adjournments

Section 75(4) of the CGST Act text available here 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 DRC-06 form also has a Yes/No personal-hearing field. If oral submissions would help explain a disputed record, calculation or legal issue, make the request in writing in the form and in the reply itself, and keep a copy.

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A hearing request can be useful where the written record needs explanation or an issue is factually complex. State clearly that you request a personal hearing and identify the matters you would like to address. Keep any notice fixing a hearing and note the date, time, mode and any records you are asked to bring or provide. Do not assume that requesting a hearing pauses other obligations or replaces the need to file a written reply.

Section 75(5) in that Act text provides for an adjournment where sufficient cause is shown, limits adjournments to three during the proceedings, and requires reasons to be recorded in writing. Check the current provision and procedure before relying on it in your case. If you need more time, explain the specific reason and request an adjournment as early as possible; do not assume that filing such a request automatically changes the reply deadline.

Section 75(6) states: “The proper officer shall, in his order, set out the relevant facts and the basis of his decision.” A well-organised submission can help create a clear record of what you disputed, the evidence you supplied and the outcome you requested.

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If you agree with only part of the demand

Separate the admitted part from the disputed part in both your narrative and your calculation. Identify the specific issue and period you accept, the amount you calculate, and the records or legal position for the portion you contest. Avoid describing the entire demand as admitted or denied if that does not reflect your position.

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Compare the practical paths before taking action: identify the section and allegation, applicable period and time limit, admitted versus disputed tax, interest and penalty, any statutory effect of payment, need for further records or a hearing, and the filing requirements. The right path depends on the actual notice and facts. A payment route should not be assumed to settle amounts or proceedings outside the provision that creates that effect.

Payment and settlement consequences depend on the statutory section and facts. The CGST Rules dated 1 January 2022 describe reporting certain payments through FORM GST DRC-03; they also describe a DRC-04 acknowledgement in the specified situation of payment before notice. DRC-03 includes fields for the cause of payment and, where relevant, notice details. Do not assume that making a partial payment automatically disposes of the balance or that a payment route available under one provision applies to another.

The same 2022 Rules text describes a specific route under sections 73(8) and 74(8): payment of tax and interest under section 73(8), or tax, interest and penalty under section 74(8), within 30 days of service of a notice may be intimated in DRC-03, after which the proper officer issues DRC-05 concluding proceedings in respect of that notice. This is a provision-specific figure from the 2022 Rules, not a general response deadline or a universal settlement rule. Verify that the provision, tax period and current law apply before relying on it.

If you are considering paying an admitted amount while contesting the rest, keep the payment calculation and filing records distinct from the substantive reply. Identify what the payment covers and the legal provision on which you rely, and do not imply that a payment settles a disputed balance unless the relevant rule and facts support that conclusion. Where amounts or consequences are unclear, get case-specific advice before treating payment as a final resolution.

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What to do after submitting

  • Keep the portal acknowledgement and a copy of the exact submission, including every exhibit uploaded.
  • Record hearing dates and keep dated notes of hearings, requests for information and follow-up communications.
  • Monitor the GST portal and registered contact channels for further notices, hearing schedules, orders or requests for information.
  • If an order is communicated, record the communication date and promptly check the applicable appeal or other remedy deadline under current law. The reply process and the appeal process have different requirements.

Maintain one case file containing the notice, service proof, filed reply, exhibits, acknowledgements and later communications in date order. If the department seeks clarification or further records, note the request date and scope, then preserve what you send and proof of delivery. This record will help you track the proceedings and determine what to review if an order follows.

If an order is issued, compare it with the notice and your response: note the issues decided, amounts, stated reasons and date of communication. Section 75(6) in the CBIC-hosted CGST Act text says the proper officer must state the relevant facts and basis of decision. Record any concern that the order addresses a different ground or amount, but check the applicable remedy and deadline promptly; this guide does not set out a complete appeal procedure.

If the notice involves a substantial amount, disputed ITC, complex transactions or uncertain procedure, consider getting case-specific help from a qualified GST practitioner, chartered accountant or tax lawyer. Share the complete notice, service information, records and calculation with them; a summary alone may omit facts that determine the correct route.

Frequently Asked Questions

What is the deadline to reply to a GST notice?

Use the response date stated in the notice as urgent, then verify the time limit under current law for the section, tax period and jurisdiction involved. There is no universal period established here for every GST SCN. The CBIC-hosted CGST Act text examined for this guide includes sections 73, 74 and 75 but not section 74A, so it cannot resolve every current notice deadline. The 30-day period described in the 1 January 2022 CGST Rules concerns a specific payment route under sections 73(8) and 74(8); it is not a general reply deadline.

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Which GST form do I use to reply to an SCN?

Where the notice summary is uploaded electronically in FORM GST DRC-01, rule 142(4) identifies FORM GST DRC-06 for the representation or reply. DRC-06 includes fields for your reply, uploaded documents, personal-hearing choice and verification by an authorised signatory. Confirm that this route applies to your notice and follow the current portal process.

Can I ask for a personal hearing?

Yes. Section 75(4) in the CBIC-hosted CGST Act text says a hearing is to be granted when requested in writing by the person chargeable with tax or penalty, or when an adverse decision is contemplated. DRC-06 also has a Yes/No hearing field. If a hearing would help, request it explicitly in writing and keep a copy. A request does not replace the written reply or automatically change its deadline.

What if I agree with only part of the tax demand?

Identify the admitted and disputed portions separately by issue and tax period, and show the calculation for each. Explain the evidence and legal basis for the part you contest. Payment consequences depend on the provision and facts: the CGST Rules dated 1 January 2022 describe a specific 30-day payment route under sections 73(8) and 74(8), but that is not a universal settlement rule. Do not assume a partial payment disposes of the balance.

What should I do if I need more time or an adjournment?

If an adjournment is needed, request it in writing as early as possible and explain the specific sufficient cause. Section 75(5) in the Act text examined for this guide limits adjournments to three during the proceedings and requires reasons to be recorded in writing. Check the current provision and procedure for your case, and do not assume an adjournment request automatically extends the reply deadline.

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The Bottom Line

Respond to the actual notice, not just its summary: verify the section, periods and deadline; answer each allegation with focused records and a separate calculation; use DRC-06 where the DRC-01 route applies; and keep proof of every filing and communication. Check current law for your notice before relying on a deadline or payment consequence.

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