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Reply to a GST show-cause notice by identifying the section and tax period, downloading the complete notice and its FORM GST DRC-01 summary, reconciling every proposed amount to your returns and records, and filing a point-by-point FORM GST DRC-06 response before the deadline shown in the notice. Attach an indexed evidence bundle, request a personal hearing in writing, and preserve the portal acknowledgement, ARN and uploaded files.
A show-cause notice proposes a demand; it is not the final recovery order. Your response should therefore make it easy for the adjudicating officer to test each allegation, correct factual errors and decide only the amount and grounds actually stated in the notice.
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What a GST show-cause notice means
A GST show-cause notice (SCN) asks why tax, interest or penalty should not be recovered. It gives you an opportunity to contest the proposed liability before an adjudication order is issued. The notice itself does not become the recovery instrument merely because it has been served.
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Under Rule 142 of the Central Goods and Services Tax Rules, 2017, the officer serves the notice with an electronic FORM GST DRC-01 summary. Your representation or reply is furnished in FORM GST DRC-06. If an order is later passed, its summary is uploaded in FORM GST DRC-07; that order summary is treated as the notice for recovery. The GST Council’s instruction index contains official guidance on electronic service of DRC-01 summaries and uploading DRC-07 order summaries.
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Start by preserving the date and mode of service. The exact reply deadline depends on the individual notice and the relevant tax period, so do not substitute a standard number of days for the date printed on your notice.
First-hour checklist after service
- Record the case identifiers. Note the GSTIN, legal name, notice number and date, service date and mode, tax period or financial year, the section invoked, and the officer or jurisdiction shown on the notice.
- Capture the proposed exposure. List each tax head—CGST, SGST/UTGST or IGST—along with proposed interest, penalty and any other amount. Record the reply deadline exactly as displayed.
- Download the full record. Save the complete SCN, the DRC-01 summary, annexures, relied-upon documents, calculations and any pre-notice communication. Preserve the files in their original format as well as a readable working copy.
- Check for missing material. If the notice refers to an annexure, statement or document that is not available, request it promptly in writing. State that you reserve the right to supplement your reply after receiving the missing relied-upon material.
- Freeze the evidence. Export the relevant GSTR-1, GSTR-3B, electronic liability and credit ledgers, invoices, credit notes, e-way records, payment references, books and correspondence for the period under dispute. Do not alter the underlying accounting records while preparing the response.
- Assign responsibility. Decide who will sign as authorised signatory, who will assemble evidence and who will attend the hearing. For a material or technically complex amount, arrange GST notice response from a tax professional early enough for review and filing.
Identify the legal route: section 73 or section 74
The section cited in the notice changes the allegation you must answer. Section 73 covers tax unpaid or short paid, an erroneous refund, or input tax credit wrongly availed or utilised for reasons other than fraud, wilful misstatement or suppression. Section 74 addresses the same types of demand where the notice alleges fraud, wilful misstatement or suppression to evade tax.
| Issue | Section 73 | Section 74 |
|---|---|---|
| Core allegation | Tax, refund or ITC error not attributed to fraud, wilful misstatement or suppression. | The same demand category, with fraud, wilful misstatement or suppression to evade tax alleged. |
| What your reply should test | Whether the tax or credit calculation is correct, attributable to you and within the applicable time limits. | All section 73 questions, plus whether the notice identifies and proves the alleged fraudulent conduct, wilful misstatement or suppression. |
| Drafting emphasis | Reconcile the figures and explain the statutory treatment of each transaction. | Challenge unsupported intent allegations separately; show the contemporaneous disclosures, returns, invoices and explanations that contradict them. |
| If the fraud allegation is not established | Not applicable. | Section 75(2) provides for redetermination by treating the notice as one under section 73. CBIC Circular 185/17/2022-GST explains the limitation consequence. |
Do not accept the section merely because it appears in the heading. Compare the section with the factual paragraphs. If the body does not explain the alleged fraud, wilful misstatement or suppression, raise that defect in your preliminary objections and again in the allegation-by-allegation response.
Build a reconciliation that an officer can audit
A narrative denial is rarely enough when the notice contains figures. Create one master schedule that connects every proposed amount to the underlying return, invoice, ledger and payment. Use one row per allegation, invoice, period or adjustment—the level that lets a reviewer reproduce your conclusion.
| Column | What to enter |
|---|---|
| Notice reference | Paragraph, table or annexure number in the SCN or DRC-01. |
| Allegation | For example, outward-supply difference, ineligible ITC, duplicate credit, wrong tax head or unpaid tax. |
| Invoice or document | Invoice number and date, credit note, debit note, import document or other transaction identifier. |
| Return period | Month or quarter appearing in GSTR-1, GSTR-3B or another cited return. |
| Taxable value | The value used in the notice and the value supported by your records. |
| Tax split | CGST, SGST/UTGST and IGST shown separately; identify any tax-head mismatch. |
| ITC or output-tax entry | Ledger reference, return table and accounting entry where the amount was claimed or reported. |
| Payment reference | Challan, DRC payment reference or electronic liability-ledger entry, if tax was already paid. |
| Difference | Your recalculated variance, with the arithmetic shown rather than a rounded conclusion. |
| Supporting document | File name or index number for the invoice, return extract, ledger, reconciliation or correspondence proving the row. |
GST reconciliation software can assist with evidence gathering and matching records, but it does not decide whether a legal allegation is correct. Review every proposed match manually, retain the source records and explain exceptions in the DRC-06 reply.
Separate factual disputes from legal disputes
Mark each row as factual, legal or mixed. Factual disputes include a wrong tax period, duplicate invoice, payment already made, vendor mismatch, transcription error or amount attributed to the wrong GSTIN. Legal disputes include classification, place of supply, exemption, eligibility of ITC, limitation and penalty. This classification prevents a legal argument from hiding an arithmetic error and prevents a spreadsheet from being offered as a substitute for statutory analysis.
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Reconcile GSTR-1 and GSTR-3B without assuming they must match mechanically
For an output-tax allegation, compare the notice’s invoice population and period with the outward-supply details reported in GSTR-1 and the tax discharged in GSTR-3B. Explain timing differences, amendments, credit notes, advances or tax-head reallocations with the relevant document. For an ITC allegation, trace the claimed amount to the purchase invoice, the accounting ledger and the relevant GSTR-3B table, then explain vendor or period differences rather than deleting unmatched rows.
Every adjustment in your schedule should have a short conclusion: accepted, partly accepted, denied as factually incorrect, or denied as legally unsustainable. If you accept a limited amount, identify it precisely and ask that any order be restricted to that supported amount.
Use a point-by-point FORM GST DRC-06 format
Rule 142(4) states: “The representation … shall be furnished in FORM GST DRC-06.” Complete the portal form and attach a signed, paginated written submission that follows the notice’s numbering. A clear structure is more persuasive than a long unindexed narrative.
1. Heading and authority
State the GSTIN, legal name, registered address, notice number and date, tax period, section invoked and the authorised signatory. Identify the DRC-01 summary to which the reply relates.
2. Preliminary objections
Raise only objections supported by the record. Possible subjects are lack of particulars, missing relied-upon documents, jurisdiction, limitation, duplicate proceedings or an incorrect section. Explain the prejudice caused by each defect and request a specific remedy, such as supply of the document, correction of the period or dropping of the allegation. Do not use preliminary objections to avoid answering the underlying figures; provide a substantive response in the alternative.
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Mirror every paragraph, table and annexure item in the notice. For each item:
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- State whether you admit, deny or partly admit the factual proposition.
- Set out the relevant facts in date and document order.
- Identify the statutory rule or treatment on which you rely.
- Refer to the exact evidence index number and the row in your reconciliation schedule.
- State the relief: delete the item, recompute it, treat tax as already paid, or apply the correct tax head.
Do not make a blanket denial when one transaction is accepted. A precise admission of a supported amount can distinguish it from an inflated or duplicated demand.
4. Tax, interest and penalty submissions
Address tax first, then interest and penalty as separate issues. Show why the proposed tax is wrong or what amount, if any, remains. Explain the basis for any interest computation challenged by you. If section 74 is invoked, deal expressly with the absence of fraud, wilful misstatement or suppression where the notice does not establish those elements. Ask that unsupported penalty be removed even if a tax adjustment is considered.
5. Relief and verification
List the orders you want the officer to make: drop the demand, reduce or recompute it to the supported amount, remove unsupported interest or penalty, correct clerical errors, supply missing material and grant a personal hearing. Add the verification and signature of the authorised signatory, then attach the reconciliation and document index.
Prepare an evidence index that survives review
Number every file and page. A practical index can contain:
- Notice, DRC-01 summary and service record.
- Returns and amendments for each disputed period.
- Invoice, credit-note, debit-note and import-document extracts.
- Electronic liability and credit-ledger entries and payment references.
- Books or ledger extracts tying the transaction to the return.
- Vendor correspondence or confirmations used to explain a mismatch.
- Calculations showing the notice figure, your correction and the resulting balance.
- Earlier replies, pre-notice communications and proof that requested documents were supplied.
Name files consistently, keep them readable and avoid password protection unless the portal accepts it and the password is supplied. If a file is too large, split it into logically labelled parts and refer to each part in the index. Redact unrelated personal information, but do not remove details needed to identify the transaction.
File the reply on the GST portal and preserve proof
- Open the notice or DRC-01 entry under the correct GSTIN and confirm that the tax period, section and notice number match your working papers.
- Select the reply option and complete FORM GST DRC-06. Use the written submission as the principal attachment rather than uploading disconnected spreadsheets without explanation.
- Upload the indexed evidence in the permitted file formats and sizes. Check that each attachment opens after upload and that the file names correspond to your index.
- Request a personal hearing in the written reply and in the portal field, if available. Do not rely on an oral request made later.
- Submit using the authorised signatory’s prescribed authentication. Wait for the portal confirmation and record the ARN or acknowledgement number.
- Download the filed DRC-06, final attachment list and acknowledgement. Save screenshots showing the submission status and date, especially where the portal displays a deadline or technical error.
If the portal rejects an upload, capture the error, preserve the attempted files and seek a documented technical remedy promptly. Do not silently replace a failed submission with an unindexed email and assume it has the same procedural effect.
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Request and use the personal hearing
Section 75(4) provides: “An opportunity of hearing shall be granted where a request is received in writing…” It also applies where an adverse decision is contemplated. Make the request in the DRC-06 reply and repeat the notice number, tax period and contact details needed for scheduling.
Prepare a short hearing note
- One-page chronology of service, filing and key communications.
- One-page statement of the amount accepted, disputed and already paid.
- Table mapping each disputed item to the evidence index.
- Three or four legal propositions, each tied to the relevant allegation.
- Specific relief requested, including correction of clerical or tax-head errors.
Take the indexed bundle and the filed acknowledgement. Answer questions from the records rather than introducing an unverified new calculation. If the officer permits additional evidence, file it promptly with a covering note identifying the hearing date, the document and the allegation it addresses. Keep proof of that submission.
Adjournments are limited
Section 75(5) permits an adjournment for sufficient cause, but no more than three adjournments may be granted to a person during the proceedings. Ask early, state the reason and propose a realistic date. Do not treat adjournment as a substitute for filing the substantive reply by the original deadline.
Check the safeguards before an order is issued
Section 75(6) requires the order to set out the relevant facts and the basis of the decision. Compare the draft or final reasoning with your indexed evidence and note whether each material contention was addressed.
Section 75(7) prohibits confirmation of an amount above the amount stated in the notice or confirmation on grounds different from those in the notice. Preserve the SCN and DRC-01 version served on you so you can compare the amount, tax heads and grounds with any eventual DRC-07 summary. A changed calculation is not automatically invalid, but the order cannot cross the statutory boundaries of the notice.
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If an adverse order is uploaded, download FORM GST DRC-07 and the full order, record the date of communication and compare the recovery summary with the reasoning. The DRC-07 summary is treated as the notice for recovery, so do not leave it unreviewed while disputing an earlier SCN.
When a section 74 allegation is not proved
A section 74 notice must do more than label an error as fraud or suppression. In your response, identify the specific conduct alleged, the document said to prove it and the reason the ordinary return or disclosure is said to be deceptive. Then show the contemporaneous invoices, returns, ledgers, correspondence or explanations that contradict the allegation.
Ask for a finding on the fraud, wilful-misstatement or suppression issue before any penalty is sustained. If that allegation is not established, section 75(2) provides for redetermination by treating the notice as one under section 73. CBIC Circular 185/17/2022-GST explains the limitation consequence of that treatment. Make limitation a separate submission with the relevant tax period, service dates and procedural events, rather than assuming that a change from section 74 to section 73 automatically resolves the time issue.
If you cannot finish by the deadline
Do not ignore the notice. File the most complete supported DRC-06 possible by the stated deadline, clearly identify any document still awaited and request permission to supplement. If the deadline has passed, submit immediately with a written explanation, attach proof of any portal failure or service problem and request that the reply be taken on record. Continue to request the statutory hearing in writing. An informal promise to send documents later is not a substitute for a filed acknowledgement.
Because the exact deadline and limitation position depend on the notice and tax period, have a tax professional review a late filing, a large amount, a section 74 allegation, a disputed jurisdiction or a technically complex ITC reconciliation.
Choose a response strategy by risk, not by document volume
| Decision factor | Lower-complexity response | Higher-risk response |
|---|---|---|
| Section | Section 73 with a single, demonstrable return or payment mismatch. | Section 74 or mixed sections with an intent allegation. |
| Dispute type | Factual correction supported by invoices, ledgers and payment references. | Classification, place of supply, exemption, ITC eligibility, limitation or penalty issue. |
| Exposure | Tax-only amount that can be reproduced from your books. | Material interest and penalty exposure or multiple tax heads. |
| Evidence | Complete, indexed records matching the notice period by period. | Missing relied-upon documents, vendor mismatches or inconsistent return populations. |
| Procedure | Clear service record, valid jurisdiction and sufficient particulars. | Possible service, jurisdiction, limitation, duplicate-proceeding or notice-particularity defect. |
| Representation | Authorised signatory can explain the schedule and legal position. | Professional representation is justified by amount, complexity or the consequences of a section 74 finding. |
Use the table to decide how much review you need, not whether evidence can be skipped. Even a small factual demand should be answered in DRC-06 with a reconciliation and acknowledgement.
Quick Recap
Final filing checklist
- Notice number, date, GSTIN, period and section match on every document.
- Service date, reply deadline, tax heads, interest and penalty are recorded.
- Complete SCN, DRC-01, annexures and relied-upon documents are saved.
- Every allegation has an admission, denial or explanation under a matching heading.
- Reconciliation ties notice figures to GSTR-1, GSTR-3B, invoices, ledgers and payments.
- Factual and legal disputes are separated, with a conclusion for each row.
- Section 74 intent allegations, limitation and penalty are addressed specifically where applicable.
- Evidence is paginated, indexed and readable.
- FORM GST DRC-06 is filed by the stated deadline and a written hearing request is included.
- ARN, acknowledgement, filed PDF, attachments and portal screenshots are preserved.
- Any later DRC-07 order is checked against the notice amount and grounds.
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