Short answer: A DRC-01 or DRC-07 portal date does not, by itself, start or extend the GST limitation period. DRC-01 is the electronic summary of a show-cause notice. DRC-07 is the electronic summary of the adjudication order. For demands governed by sections 73 and 74 of the Central Goods and Services Tax Act, the order deadline is calculated from the annual-return due date or, where relevant, the date of an erroneous refund. A court or Appellate Tribunal stay affecting service of the notice or issuance of the order is excluded from that calculation.
To decide whether a demand is time-barred, identify the applicable financial year and statutory provision, calculate the section 73 or 74 deadline, add any legally excludable stay period, and then examine the underlying signed notice, adjudication order, service evidence and portal records. Treat DRC dates as chronology evidence, not as a replacement for the statutory reference date or the underlying legal document.
As an Amazon Associate I earn from qualifying purchases.
What DRC-01 and DRC-07 are in the GST workflow
Rule 142 of the CGST Rules uses electronic forms to place summaries of demand documents on the GST portal. The forms help a taxpayer see the department’s action in the demand-and-recovery workflow, but the summary and the underlying legal document do different jobs.
Windows Errors? Fix Them Before They Spread
Repair common Windows errors and clear accumulated junk for a smoother, more stable PC - no reinstall needed.Free scan · no reinstallCrashes, No Sound, or Screen Glitches?
Random freezes, missing sound and display glitches usually trace back to one bad driver. Find and replace yours safely.Free scan · under a minuteDRC-01: summary of the show-cause notice
DRC-01 accompanies the show-cause notice (SCN). Rule 142 requires the notice summary to be served electronically in DRC-01. Its date can therefore help establish when the portal recorded or communicated the summary and how the notice chronology unfolded.
#1 Best Overall
The date is not automatically the date on which the section 73 or section 74 limitation period began. The statutory clock for the order is tied to the annual-return due date or erroneous-refund date, not simply to the day a DRC-01 entry appears. Compare the portal entry with the signed SCN, the document’s issue details and reliable proof of communication. If those records conflict, preserve each record rather than treating the portal timestamp as conclusive.
DRC-07: summary of the adjudication order
DRC-07 is the electronic summary of the order passed after adjudication. Rule 142 requires the order summary to be uploaded electronically in DRC-07. The upload is important evidence of the department’s recovery chronology, but it is not necessarily the date on which the order was signed, issued or served.
The underlying adjudication order is the legally significant act. Rule 142(6) states that the order referred to in the rule “shall be treated as the notice for recovery.” That recovery consequence comes from the order itself, not from a portal timestamp viewed in isolation. Keep the signed order, its issue and communication details, and the DRC-07 upload record as separate pieces of evidence.
Quick wins for a faster PC:
Fix the driver behind crashes, sound loss and screen glitchesFind Drivers →Clear out junk files and repair common Windows errorsFree Scan →Scan for outdated or missing drivers - takes under a minuteDriver Scan →Does a DRC-01 date stop or start limitation?
No. A DRC-01 date can show when the notice summary was served or recorded electronically, but it does not replace the limitation anchor in section 73 or section 74.
For a limitation analysis, ask three separate questions:
- What financial year or erroneous-refund event does the demand relate to?
- When was the annual return due, or when did the erroneous refund occur?
- When was the underlying order issued, after accounting for any period legally excluded because of a court or tribunal stay?
The DRC-01 date remains useful for testing notice chronology and service. It may reveal that the portal summary appeared before or after the paper or digitally signed notice, or that communication records are incomplete. Those facts can matter to procedural arguments, but they do not convert the form date into the statutory starting point for the order deadline.
Is the DRC-07 date the date of the GST order?
Not necessarily. The DRC-07 date normally identifies the electronic upload of the order summary. The legally important date must be established from the underlying adjudication order and the evidence showing its issue and communication.
What’s actually slowing this PC down?
Pick the symptom - the matching free tool is one click away.
A portal record can be later than the order’s signing or issue. It can also be the only easily visible date in a taxpayer’s account, which is why it is often mistaken for the order date. That shortcut is unsafe. Download the order itself, check its date and signature or authentication, and retain the portal upload history and service record alongside it.
For recovery, Rule 142(6) gives the order a specific role: the order is treated as the notice for recovery. This does not mean that uploading DRC-07 creates a new limitation period or cures an order issued outside the applicable statutory period. Recovery chronology and limitation chronology must be analyzed separately.
The statutory limitation anchors under sections 73 and 74
Sections 73 and 74 use a reference date that is independent of DRC-01 and DRC-07 uploads. The quoted statutory language is the starting point for demands covered by those provisions.
Section 73: three-year order period
“The proper officer shall issue the order under sub-section (9) within three years from the due date for furnishing of annual return for the financial year to which the tax not paid or short paid or input tax credit wrongly availed or utilised relates to or within three years from the date of erroneous refund.”
Free tools Windows power users keep installed
One-click scans. No signup required.
Special offer. See more information about Outbyte and uninstall instructions. Please review EULA and Privacy policy.
For a section 73 matter, identify the relevant financial year’s annual-return due date. If the demand concerns an erroneous refund, use the erroneous-refund date as the alternative reference point. The proper officer’s order must be issued within three years from the applicable reference date, subject to any statutory exclusion such as a qualifying stay.
Section 74: five-year order period
“The proper officer shall issue the order under sub-section (9) within a period of five years from the due date for furnishing of annual return for the financial year to which the tax not paid or short paid or input tax credit wrongly availed or utilised relates to or within five years from the date of erroneous refund.”
Section 74 uses the same types of reference dates but a five-year period. Do not use the DRC-01 notice-summary date or DRC-07 upload date as a substitute for the annual-return due date or erroneous-refund date.
Scope of these formulas
The quoted sections apply to periods governed by those provisions. Newer financial years, including matters potentially governed by the section 74A regime or later notifications, may require a different statutory analysis. Label the financial year and the provision used before performing any calculation; never assume that every GST demand follows the same formula.
How the important dates differ
| Date or event | Legal trigger | Document function | Service or communication evidence | Effect on statutory deadline | Recovery or appeal chronology |
|---|---|---|---|---|---|
| Annual-return due date or erroneous-refund date | The reference event specified in section 73(10) or 74(10) | Anchors the calculation of the order period | Annual-return records, refund records and applicable statutory documents | Three years under section 73 or five years under section 74, for covered periods | Provides the baseline against which the order’s timing is tested |
| DRC-01 notice summary | Electronic service of the SCN summary under Rule 142 | Summarizes the show-cause notice | Portal service record, the underlying signed notice and proof of communication | Does not itself set the section 73 or 74 order deadline | Helps establish notice and response chronology |
| Underlying adjudication order | Issuance of the order under the applicable demand provision | Contains the adjudication decision and demand | Signed or authenticated order plus communication details | The order must be issued within the applicable period, after lawful exclusions | Drives recovery and the taxpayer’s appeal timeline |
| DRC-07 upload | Electronic upload of the order summary under Rule 142 | Summarizes the adjudication order | Portal upload history kept separately from the order and service proof | Does not independently extend or restart limitation | Shows when the recovery summary entered the portal; Rule 142(6) gives the order recovery significance |
| Service or communication date | Actual communication of the notice or order to the taxpayer | Shows when the document was made available or served | Electronic delivery logs, portal access records, acknowledgements or other service proof | Must be assessed separately from the upload timestamp | Can affect response and appeal chronology, depending on the governing rule |
| Court or Appellate Tribunal stay period | A stay of service of notice or issuance of order | Suspends the affected procedural step for the duration of the stay | Stay order, start date, end date and the order’s precise scope | Section 75(1) excludes the stay period from the specified section 73 or 74 computation | Changes the final date only to the extent the stay legally covers service or issuance |
How to check whether a GST demand is time-barred
- Identify the demand provision and financial year. Read the SCN and order to determine whether the matter is under section 73 or section 74 and which financial year the tax, input tax credit or refund relates to. If the period may fall under section 74A or another later rule, stop and obtain the applicable provision before using the formulas below.
- Find the correct statutory reference date. For tax not paid, short-paid or input tax credit wrongly availed or utilised, locate the due date for furnishing the relevant annual return. For an erroneous-refund demand, locate the date of the erroneous refund. Keep the record that proves the date.
- Apply the statutory period. Add three years for a covered section 73 matter or five years for a covered section 74 matter. State the reference date, the provision and the resulting end point in writing so another person can reproduce the calculation.
- Check for a qualifying stay. Section 75(1) provides that where service of the notice or issuance of the order is stayed by a court or Appellate Tribunal, the period of that stay is excluded from the computation. Record the stay order, the date it began, the date it ended and whether it covered service, issuance or both. Do not add a period merely because litigation was pending; the exclusion depends on the actual stay.
- Compare the deadline with the underlying order. Use the issue or issuance evidence for the adjudication order, not DRC-07 alone. Determine whether the order was issued within the calculated period after the documented exclusion.
- Analyze service and portal chronology separately. Compare the DRC-01 and DRC-07 records with the signed notice, signed order and communication proof. A mismatch can raise a service or procedural issue without changing the statutory anchor.
- Preserve the calculation. Save the downloaded forms, notices, orders, portal history, annual-return or refund records, stay orders and any applicable extension or notification. A defensible limitation objection depends on a complete chronology.
Illustrative calculations
The following examples show the method only. They do not determine the deadline for a real case, where the financial year, governing provision, statutory amendments, notifications and exact document dates must be verified.
Section 73 example
Assume a covered section 73 demand relates to a financial year for which the annual return was due on 31 December 2021. The three-year statutory point is 31 December 2024. A DRC-01 uploaded in March 2023 does not move that reference date, and a DRC-07 uploaded in January 2025 does not by itself prove that the order was issued within time. The signed order and any qualifying stay must be examined against the 31 December 2024 point.
Section 74 example
Assume a covered section 74 demand uses an annual-return due date of 31 December 2021. The five-year statutory point is 31 December 2026. The portal dates may help establish when the notice and order summaries were communicated, but the five-year calculation still begins with the annual-return due date, unless the demand is instead based on an erroneous refund.
Erroneous-refund example
If the demand concerns an erroneous refund, substitute the refund date for the annual-return due date in the applicable three-year or five-year calculation. The refund record should identify the date used; neither DRC form creates an alternative refund date.
Stay example
Suppose a qualifying court order stays issuance of the order for a documented period. Section 75(1) excludes that stay period when computing the section 73 or 74 period. The calculation must show the original statutory point, the exact stay interval and the adjusted point. A stay that concerns a different procedural act, or an order whose scope is unclear, should not be counted automatically.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Why the underlying documents matter more than a single timestamp
Portal summaries are valuable because they create an electronic trail, but a limitation challenge usually turns on the relationship among several records:
- The SCN: Check the date, allegations, tax period, statutory provision and authentication.
- DRC-01 and service proof: Preserve the summary and evidence of how and when it was communicated.
- The adjudication order: Check the order date, signature or authentication, findings, tax period and demand calculation.
- DRC-07 and upload history: Preserve the summary and the portal event separately from the order.
- Annual-return or refund evidence: Prove the statutory reference date used in the calculation.
- Stay orders: Keep the complete text and calculate only the period and procedural step actually covered.
This separation prevents two common errors: treating a form upload as the legal act itself, and treating a notice or order communication date as the statutory reference date. It also makes it possible to argue distinct issues—limitation, service, recovery and appeal timing—without blending their dates.
Common mistakes and how to correct them
Using the DRC-01 date as the limitation start
Why it fails: DRC-01 summarizes the SCN; sections 73 and 74 anchor the order period to an annual-return due date or erroneous-refund date.
Correction: Calculate from the statutory reference event and use DRC-01 only to test notice chronology and service.
Calling the DRC-07 upload the “order date”
Why it fails: Uploading the summary and issuing the underlying order are separate events.
Correction: Read the signed or authenticated order, verify its issue details and retain the upload record as corroborating chronology.
Assuming DRC-07 extends limitation
Why it fails: Rule 142(6) gives the order recovery significance; it does not state that uploading the summary extends the section 73 or 74 period.
Rank #4
Correction: Ask whether the order itself was issued within the statutory period after any section 75(1) exclusion. Do not treat a later upload as a new deadline.
Adding all litigation time to the deadline
Why it fails: Section 75(1) excludes a stay period only when service of notice or issuance of order was stayed by a court or Appellate Tribunal.
Correction: Read the stay order’s scope and calculate the exact covered interval.
Applying the formula to the wrong financial year or regime
Why it fails: The annual-return due date depends on the financial year, and later regimes may use different provisions.
Do these 3 things before closing this tab:
1Clear out junk files and repair common Windows errors2Scan for outdated or missing drivers - takes under a minute3Repair Windows errors before they cause bigger problemsCorrection: Identify the period first, then select the governing section and any applicable notification before calculating.
Practical record-keeping checklist
For each demand, create a chronology with these fields:
- Financial year and tax period covered by the demand.
- Applicable provision: section 73, section 74 or another identified regime.
- Annual-return due date, or erroneous-refund date where that is the applicable anchor.
- Calculated three-year or five-year point.
- SCN date, DRC-01 date and proof of service.
- Adjudication order date, authentication and proof of communication.
- DRC-07 upload date and portal reference.
- Every court or Appellate Tribunal stay, including scope and exact start and end dates.
- Any documented extension or notification that legally applies to the period.
- The final calculation showing why the order is, or is not, within time.
Keep the original downloads and metadata where possible. Screenshots can support the chronology, but they should not replace the underlying notice, order, service record or stay order.
What the dates do—and do not—establish
DRC-01 establishes a portal record for the notice summary and helps test service chronology. DRC-07 establishes a portal record for the order summary and supports recovery chronology. The adjudication order is the operative recovery document under Rule 142(6). Neither form upload supplies the section 73 or 74 limitation anchor.
Recommended Free Tools
The reliable limitation analysis is therefore document-based: identify the applicable statutory reference date, apply the correct three-year or five-year period for the covered regime, exclude only a qualifying stay under section 75(1), and compare the result with the issuance evidence for the underlying order. Portal dates remain important, but they answer a different question.
Quick Recap
Product prices and availability are accurate as of the date/time indicated and are subject to change. Any price and availability information displayed on Amazon at the time of purchase will apply.
