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Got a GST notice? Before writing anything, record the form number, reference number, GSTIN, tax period, issuing authority, date of service and the exact response date printed in the notice. An ASMT-10 scrutiny notice, a DRC-01B or DRC-01C mismatch intimation, a show-cause notice and a demand order are different stages with different remedies. Treating them as interchangeable can lead to a missed deadline or the wrong filing.
This guide follows India’s central GST framework and common portal workflows. It explains how to identify the allegation, reconcile it to your books and returns, choose between an explanation and payment, preserve proof of filing, and move to an appeal when an order has already been issued. Deadlines and portal screens can change, so verify the notice itself and current GST instructions; obtain qualified tax advice for large, disputed, fraud-related or time-barred matters.
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Start with a notice-control sheet
Do not begin by drafting a generic reply. Create one control sheet for each notice and fill it from the document and the portal record.
- Identity: GSTIN, legal name, notice or order number, form name and issuing officer.
- Period: financial year, tax month or quarter, and the return identified.
- Service: date and method by which the notice or order was communicated.
- Allegation: each discrepancy, tax head, amount and explanation requested.
- Deadline: the exact calendar date stated in the notice, plus any statutory period that applies.
- Status: draft, filed, acknowledged, paid, accepted, rejected or converted into an order.
Save the original PDF or portal download, not just a screenshot. A deadline should be calculated from the actual communication or service date and the form involved; never borrow the period from another GST procedure.
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Know which GST stage you are in
The same underlying transaction can appear in several processes, but each process has a different response.
| Stage | Typical document | What it asks you to do | Usual route |
|---|---|---|---|
| Return scrutiny | ASMT-10 | Explain listed discrepancies after scrutiny of a return. | Pay an accepted liability and inform the officer, or submit an ASMT-11 explanation. An acceptable explanation is communicated in ASMT-12. |
| Outward-supply liability mismatch | DRC-01B | Address a difference between GSTR-1/IFF liability and GSTR-3B liability. | Use the form-specific Part B response to pay or explain, following current portal instructions. |
| Input-tax-credit mismatch | DRC-01C | Address an ITC-related mismatch and identify any payment already made. | Match the payment ARN, GSTIN, stated payment cause and tax period, then submit the prescribed response. |
| Proposed adverse action | Show-cause notice | Explain why a proposed tax, interest, penalty, registration action or other measure should not be confirmed. | File the response and evidence in the form and time allowed by that notice. |
| Adjudicated liability | Demand or adjudication order | Comply with the order or challenge it. | Pay as required or file an appeal; a reply to an earlier notice is not an appeal. |
The form title is not a formality. It determines the legal stage, the evidence expected and whether you are still explaining a discrepancy or already challenging an enforceable order.
ASMT-10: how scrutiny works
What the notice means
The official form is titled “Notice for intimating discrepancies in the return after scrutiny.” It lists the return items that the officer considers inconsistent and directs the registered person to explain them by the date specified in the notice.
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Rule 99 of the CGST Rules, as reflected in the cited compilation, allows up to 30 days from service of an ASMT-10 for the explanation, or a further period permitted by the proper officer. The date printed on your notice controls your immediate workflow. If more time is needed, request it before the stated date and keep proof of the request; do not assume an extension exists until the officer permits it.
ASMT-11 and ASMT-12
You have two basic routes. If the discrepancy is correct, accept it, pay the resulting tax, interest and other amount and inform the proper officer. If it is not correct, or needs contextual explanation, furnish the reconciliation and evidence through ASMT-11. When the explanation is accepted, the officer communicates that result in ASMT-12. An ASMT-10 is therefore not itself a demand order, and paying an amount is not an automatic substitute for analysing the allegation.
Build a discrepancy-by-discrepancy reconciliation
Prepare one working paper row for every allegation. A single total-level explanation is difficult to audit and can leave one item unanswered.
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| Working-paper column | What to enter |
|---|---|
| Notice reference | Paragraph or serial number from the notice. |
| Return value | Field, table and figure reported in the relevant return. |
| Books value | Ledger, sales register, purchase register or tax account supporting the books figure. |
| Difference | Amount by tax head, period and transaction class. |
| Reason | Timing, amendment, credit note, wrong period, tax-rate issue, classification, duplicate entry, reversal or another fact supported by records. |
| Correction | Return amendment, accounting entry, payment, reversal or explanation already filed. |
| Evidence index | File name or schedule number for each invoice, ledger extract, reconciliation and payment record. |
| Position | Admit, partly admit, dispute or seek clarification, with the amount assigned to that position. |
Use the return and tax period named in the notice. Then compare the relevant return data with books, invoices, credit and debit notes, e-invoice or e-way records where relevant to the allegation, bank or payment records, prior amendments and any earlier correspondence. There is no universal evidence list: the right document depends on why the figures differ.
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CBIC scrutiny instructions emphasise that discrepancies should be specific where possible and quantified where possible. Mirror that standard in your reply: identify the exact field, amount, transaction population and reason rather than asserting that the accounts are correct in general.
Choose explanation, payment or both
When the discrepancy is accepted
Calculate tax and applicable interest under the facts of the case, confirm the correct tax head and period, and use the payment route permitted for that procedure. The cited CBIC instruction describes DRC-03 as the route for paying an accepted amount during scrutiny and says the taxpayer should notify the officer or furnish the corresponding ASMT-11 explanation. Attach the payment reference and a calculation showing how the amount was derived.
When the discrepancy is disputed
Explain the legal and factual basis, quantify your own figure and attach the records that prove it. Do not pay a disputed amount merely to make the notice disappear unless qualified advice shows that payment is the appropriate strategy. Payment can affect later proceedings, while a clear, timely reconciliation preserves the distinction between an admitted and a contested amount.
When only part is correct
Separate admitted and disputed lines. Pay and document the admitted portion, then explain the balance with a transaction-level schedule. State whether the difference is caused by timing or by an error that will be corrected in a specified return, but do not promise a correction that the law or portal does not permit.
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One free scan finds every outdated or missing driver and matches the right update for your exact hardware.Free scan · exact hardware matchDRC-01B: liability mismatch between outward supplies and tax paid
DRC-01B is a separate mismatch workflow, not an ASMT-10 response. Vendor documentation describes it as a comparison of liability reported in GSTR-1 or IFF with liability paid in GSTR-3B. The mismatch intimation is followed by a response in Part B, generally by paying the difference or explaining why the comparison is not correct.
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Reconcile the two return populations
- Export the GSTR-1 or IFF liability for the period identified.
- Export the corresponding GSTR-3B liability and payments by tax head.
- Map amendments, credit notes, advances, reverse-charge items and transactions reported in a different period.
- Check whether a tax amount was paid under the wrong head or offset through an eligible credit.
- Prepare a bridge from the portal figures to the books and identify any admitted balance.
Submit the Part B response only after checking the period and figures displayed by the portal. Keep the response ARN and any payment reference with the reconciliation. Current portal labels and blocking rules should be verified at the time of filing.
DRC-01C: input-tax-credit mismatch
DRC-01C concerns an ITC mismatch process and must be handled separately from DRC-01B’s outward-liability comparison. The official portal FAQ cited for this workflow highlights matching details that are easy to enter incorrectly.
Details to check before filing
- Payment ARN: enter the ARN for the payment you are relying on, if payment has been made.
- GSTIN: confirm that the GSTIN in the response matches the notice and the payment record.
- Cause of payment: select or state the reason exactly enough to connect the payment to the mismatch.
- Tax period: use the period in the intimation, not merely the month in which you paid.
Vendor help for accounting software describes Part A as the mismatch intimation and Part B as the response, with a payment or explanation path. The same vendor guidance warns that a response may be required within seven days and that a later GSTR-1 or IFF filing could be restricted until payment or explanation. Treat that seven-day warning as vendor guidance, not a universal statutory deadline: verify the live GST Portal instruction and the particular intimation before relying on it.
ITC evidence
Trace each disputed credit to the purchase register, tax invoice, supplier details, receipt of goods or services, payment records, reversal calculations and the relevant return. Explain timing differences, credit-note adjustments, blocked-credit classifications or duplicate claims with a numbered schedule. Do not upload an undifferentiated ledger dump that forces the officer to reconstruct your case.
Show-cause notices require a merits response
A show-cause notice proposes an action; it is not the same as a scrutiny intimation. Read the “grounds,” the proposed tax, interest and penalty, and the hearing or reply instructions. Answer every allegation in the same order as the notice.
Structure the response
- Identify the notice, period, statutory provision cited and relief requested.
- Give a short factual chronology, including filing, amendment, payment and prior correspondence dates.
- Respond to each allegation under a separate heading and state whether it is admitted, partly admitted or denied.
- Explain the calculation and attach a transaction-level schedule.
- Address interest and penalty separately; a tax explanation does not automatically answer a penalty allegation.
- Request a personal hearing when the notice or applicable procedure provides for one, and keep proof of attendance or adjournment.
Fraud, wilful misstatement or suppression allegations can have materially different consequences. Obtain professional advice before making admissions or signing a statement in a high-value or enforcement-related matter.
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When a demand order has already been passed
An order changes the question from “How do I explain this discrepancy?” to “Will I comply or challenge the adjudication?” A reply to the notice does not become an appeal merely because it disputes the order.
Check the order first
- Confirm the communication date and the authority that issued the order.
- Separate tax, interest, penalty and any other amount.
- Check whether payments or credits already made were given effect.
- Note the appeal form, portal route and any stated pre-deposit instruction.
- Calculate the last day from the actual communication date, then obtain advice if limitation is uncertain.
First appeal period and pre-deposit
The GST Portal FAQ cited for this topic describes a three-month period from communication of an adjudicating authority’s decision or order for a first appeal and a 10% pre-deposit of disputed tax before filing. Those figures must be checked against the current statute, amendments, special provisions and the facts of the order. Do not calculate the deadline from the date you happened to download the order if it was communicated earlier.
File, acknowledge and preserve the record
A technically correct explanation is still risky if you cannot prove when and what you filed. Keep a single folder for each GSTIN, financial year and notice reference.
- Original notice or order and portal download date.
- Final reply PDF or form-generated submission.
- Working-paper reconciliation and evidence index.
- ARN, acknowledgement number, submission timestamp and portal status.
- DRC-03 or other payment challan, CIN and bank confirmation where applicable.
- Officer correspondence, extension request, hearing notice and hearing notes.
- Any revised return, amendment or accounting entry made after the notice.
Use a read-only copy of the filed package and retain the editable working papers separately. Reconcile the acknowledgement to the exact GSTIN and period; a response filed under another registration is not a cure for a missed filing.
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Timing differences
Sales, credit notes or ITC can fall into different tax periods because of amendment timing. Build a month-by-month bridge and show where each amount was reported. If the law permits correction in a later return, identify that return and retain the supporting document.
Duplicate or omitted invoices
Match invoice number, date, supplier or customer GSTIN, taxable value and tax amount. Mark the duplicate or omission in both the register and the return comparison, then quantify the net effect rather than presenting only a gross total.
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Wrong tax head or classification
Trace the original payment and the ledger posting. Explain the correction mechanism available for the tax head and avoid netting an incorrect head against a different liability without verifying the permitted adjustment.
Credit-note and ITC reversals
Link each credit note to the original invoice and show the reversal date. For ITC, distinguish an ineligible credit from a credit that was eligible but claimed in a different period; the evidence and remedy are not the same.
Common mistakes that make a notice worse
- Replying to an ASMT-10 as if it were a demand order.
- Using a DRC-01B explanation for a DRC-01C ITC mismatch.
- Counting a universal number of days instead of following the date printed in the notice.
- Submitting a total figure without a transaction-level reconciliation.
- Uploading files with no index, period labels or tax-head mapping.
- Paying a disputed amount without recording whether it is admitted or paid under protest where applicable.
- Ignoring a portal acknowledgement or assuming a saved draft is a filed reply.
- Relying on software’s workflow warning as if it were the statute.
- Waiting until the deadline day to discover that the authorised signatory, digital signature or portal login does not work.
- Continuing to file routine returns without checking whether a mismatch process has created a portal restriction.
Use accounting software as a control, not as legal judgement
Reconciliation software can reduce repetitive exports, compare return data and retain task history. Vendor documentation for some accounting platforms describes DRC-01B and DRC-01C workflows, including payment and explanation paths. Such a feature can help assemble data, but it does not decide whether the tax demand is legally correct, whether an invoice is admissible evidence or whether an appeal is in time.
Keep the source ledgers and portal downloads outside the application as well. A software-generated reconciliation should be reviewed by the person responsible for GST compliance, with exceptions documented and resolved before submission.
When to obtain professional help
Engage a qualified tax professional promptly when the notice alleges fraud, suppression or wilful misstatement; covers several periods or registrations; involves a large disputed amount; follows a search or inspection; concerns blocked ITC or classification with substantial consequences; or has an expired or uncertain deadline. Provide the complete notice-control sheet, reconciliation, payment history and submission record so advice can focus on the disputed issue rather than rebuilding the file.
A practical response checklist
- Identify the exact form, period, authority, service date and deadline.
- Download the notice and all portal attachments.
- List every discrepancy and reproduce the officer’s figures.
- Reconcile each item to returns, books, invoices and payments.
- Classify each line as admitted, partly admitted, disputed or requiring clarification.
- Select the correct route: ASMT-11, DRC-01B Part B, DRC-01C response, show-cause reply or appeal.
- Calculate tax, interest and any admitted amount; obtain review before payment.
- File through the prescribed portal route before the controlling deadline.
- Save the ARN, acknowledgement, payment reference and final evidence package.
- Monitor the portal for ASMT-12, an order, a hearing communication or a filing restriction.
The safest response is specific, quantified and traceable. Identify the procedure first, then reconcile the exact allegation, choose the remedy that fits the facts and preserve proof of every action. That sequence prevents a scrutiny explanation, mismatch response and appeal from being treated as one generic GST form.
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