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Freedom251 › Blog › DRC-06

How Businesses Can Respond to a GST Show-Cause Notice

By Freedom251 Team · · 5 min read

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Read the complete notice, identify its legal provision and tax period, and reconcile each allegation with your records before replying. For the Rule 142 process described here, Form GST DRC-06 is used to submit the reply and supporting documents and to indicate whether you request a personal hearing. The correct route and deadline depend on the notice, the period involved, and the law in force.

1. Retrieve the complete notice and record the key details

Do not draft a reply from an email alert, an informal message, or a short portal summary alone. Obtain and read the complete notice and the records available on the GST common portal. Make a working copy and note:

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  • Notice reference number, issue date, issuing authority, and service details.
  • The statutory provision cited and the financial year and tax period covered.
  • Each allegation, the facts and documents relied upon, and the department’s tax, interest, and penalty calculations.
  • The response deadline and any information about a personal hearing.

Where applicable, compare the notice with its DRC-01 electronic summary. The summary is not the complete notice: read the underlying notice to understand the allegations and material relied upon. CBIC Instruction No. 04/2023-GST, dated 23 November 2023, says that summaries of specified notices are to be served electronically in DRC-01 and order summaries uploaded in DRC-07. The instruction describes the electronic-summary requirement; a missing summary does not, by itself, establish that a notice is invalid.

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2. Match the provision to the tax period and allegation

Check the period before relying on a section’s timelines or consequences. In the CBIC text of the Central Goods and Services Tax Act reviewed on 4 October 2026, sections 73 and 74 are stated to apply to determination for periods up to FY 2023-24:

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Route in the cited Act text Allegation category Period stated in that text
Section 73 The specified non-fraud category Periods up to FY 2023-24
Section 74 Alleged fraud, wilful misstatement, or suppression of facts to evade tax Periods up to FY 2023-24

This distinction identifies the route described in that Act text; it does not determine whether the allegation is correct. Do not automatically apply sections 73 or 74, their timelines, or their consequences to a period from FY 2024-25 onward. For later periods, check the current official Act, rules, amendments, and the provision actually cited in the notice. The precise route and any payment or penalty consequences depend on those sources and the facts.

3. Reconcile each allegation against your records

Build the response around the issues the notice actually raises. Gather only records relevant to those issues, which may include returns, invoices, credit notes, ledgers, payment records, input tax credit support, reconciliations, and correspondence. Do not state that a document exists unless you have it.

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Prepare an issue-by-issue working schedule

For every allegation, record the department’s stated amount and calculation, your own position, the supporting records, and any difference that remains. Separate tax, interest, and penalty rather than treating a combined demand as one figure. If you accept only part of an amount, show the part accepted and explain how you calculated it.

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  • Admitted: identify the amount and records supporting the position.
  • Disputed: state the specific factual or legal basis for the disagreement and identify the evidence.
  • Partly admitted: separate the accepted and disputed portions and reconcile each one.

4. Draft a point-by-point reply

A reply should let the officer trace each statement to the relevant allegation and evidence. A practical structure is:

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  1. Taxpayer identification and notice reference.
  2. A short outline of the response and the issues in dispute.
  3. Any supported preliminary objections, such as jurisdiction, service, limitation, or missing relied-upon particulars. Explain the facts and basis; do not assume that identifying a procedural concern automatically invalidates the notice.
  4. A response to each allegation, in the order raised, with the relevant facts and legal grounds.
  5. A reconciliation of the tax, interest, and penalty calculations.
  6. An indexed list of attachments explaining what each document supports.
  7. Your choice about requesting a personal hearing, followed by the required verification and authorized-signatory details.

Use clear labels for attachments and refer to those labels in the relevant parts of the reply. Keep factual statements precise; unsupported assertions make it harder to assess the response.

5. Submit the reply through the applicable process

For the Rule 142 process described in the cited CGST Rules, Form GST DRC-06 is the reply form under Rule 142(4). The form provides fields for the notice reference and date, financial year, reply, uploaded-document list, personal-hearing choice, and verification. Confirm the current form and filing workflow on the GST portal and follow the process and deadline stated in the applicable notice; portal menus and filing steps may change.

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  1. Complete the reply and verify that the notice reference, period, and taxpayer details match the notice.
  2. Upload the indexed supporting documents in the prescribed process and check that the files are readable and complete.
  3. Indicate whether you request a personal hearing and complete the form’s verification and signatory requirements.
  4. Submit before the deadline applicable to your notice and save the portal acknowledgement or reference number.

There is no universal response deadline that should be assumed for every GST notice. Check the actual notice and applicable law. If the deadline is unclear or the record is incomplete, obtain qualified advice promptly rather than ignoring the notice.

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6. Decide whether to request a personal hearing

DRC-06 includes a yes-or-no choice about a personal hearing. Consider whether explaining a disputed computation, factual record, or legal issue orally would assist in your case, and discuss the choice with your adviser where the stakes or legal issues warrant it. Requesting a hearing is not a substitute for a complete written reply and supporting records. The appropriate choice depends on the notice and the circumstances; the form alone does not establish what strategy is best.

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7. Keep the filing record and track what follows

Retain the filed DRC-06, the exact attachments submitted, the acknowledgement or reference number, copies of the notice and portal summaries, and any later hearing notice or order. Keep a dated copy of the final submission so you can establish what was filed.

If an order follows, read the full order rather than relying only on DRC-07. Under CBIC Instruction No. 04/2023-GST, DRC-07 carries an order summary, including payable tax, interest, and penalty as applicable; it is not a substitute for understanding the full order and its reasoning.

When to get professional review

Consider consulting a chartered accountant, GST practitioner, or tax lawyer if the notice alleges fraud or suppression, involves a substantial demand, raises a complex classification or input tax credit issue, or turns on limitation, service, a hearing, or a possible appeal. Professional review is especially useful where the correct statutory route or the legal effect of a procedural issue is uncertain.

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DRC-06GSTGST show-cause noticeIndiaTax compliance

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