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How to Reply to a GST Show-Cause Notice: Documents, Deadlines and Steps

A practical guide to responding to a GST show-cause notice: identify the notice route, check the applicable deadline, organize evidence, file the right reply and retain proof.
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Start by identifying the section, notice type, tax period, allegations and response deadline shown in the notice and on the GST portal. Check each proposed tax, interest and penalty amount against your returns and records, then prepare a point-by-point reply with indexed evidence. For notices covered by Rule 142(4), the reply is filed in FORM GST DRC-06; a scrutiny discrepancy notice in ASMT-10 follows a different route.

First identify what kind of GST communication you received

Do not choose a reply form based on the words “GST notice” alone. Read the section cited, form number, detailed notice, any summary or annexures, and the corresponding portal communication. Note the issuing officer, tax period, date and mode of service, stated deadline, and any hearing date. Check that the detailed notice and its summary are available and consistent. Under the CBIC rules, covered demand notices are accompanied by a summary in DRC-01; a covered statement under section 73(3) or 74(3) has a summary in DRC-02.

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The route can differ substantially by notice type. A demand proceeding under section 73 or 74 is not the same as a discrepancy notice issued in scrutiny under section 61. Section 73 concerns specified tax, refund or input-tax-credit issues for reasons other than fraud, wilful misstatement or suppression of facts to evade tax. Section 74 concerns such issues alleged to arise by reason of fraud, wilful misstatement or suppression to evade tax. A section 74 citation is an allegation, not proof that the allegation is established.

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What is the deadline to reply?

There is no safe single deadline to quote for every GST show-cause notice. Use the date and instructions in your particular notice and check the governing provision. The CBIC assessment rules say the response period specified in an ASMT-10 scrutiny discrepancy notice must not exceed fifteen days. That limit is specific to the ASMT-10 procedure; it is not a general deadline for demand notices under sections 73 or 74.

Sections 73(8) and 74(8) also contain thirty-day periods for specified payment provisions after notice, but those are not universal reply deadlines. The payment consequences differ between the two sections. Verify the law applicable to the relevant tax period, including amendments, before relying on a statutory period.

Which documents should you gather?

There is no universal statutory attachment checklist: choose evidence that answers the actual allegations and supports your figures. These practical examples may be relevant depending on the case:

  • The complete notice, its summary, annexures and related portal communications.
  • Returns and reconciliation statements for the periods in question.
  • Sales and purchase invoices, credit notes and debit notes.
  • Relevant accounting or electronic ledgers, payment challans, and DRC-03 or DRC-04 records where applicable.
  • Contracts, purchase orders, delivery or transport records, and correspondence that relate to the alleged supply.
  • Input tax credit records and reconciliations if credit is disputed.
  • A calculation schedule that sets out your figures beside the department’s, broken down by period, tax head, tax, interest and penalty where applicable.

Keep a complete copy of the package you submit. Do not send sensitive original records unless the applicable process specifically requires them.

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How to prepare a clear, evidence-backed reply

  1. Make an allegation-by-allegation schedule. For each notice paragraph, record the cited provision, the department’s factual assertion, the amount and period involved, your response, the supporting document, and any unresolved issue. The DRC-01 summary identifies brief facts, grounds, and tax and other dues; use the detailed notice as well, not just the summary.
  2. Reconcile the figures. Compare the notice’s calculations with relevant returns, invoices, books, ledgers, payment records and other records. Separate tax, interest and penalty amounts and identify any amount already paid. State the basis for a disagreement rather than offering unexplained totals.
  3. Draft in the notice’s sequence. Identify the notice reference, GSTIN, tax period, section and date. Respond to each ground in order, distinguish admitted facts from disputed ones, and explain the legal basis for each disagreement. Address contrary facts rather than ignoring them.
  4. Index and cross-reference the evidence. Give each annexure a clear label and cite it beside the factual statement it supports. State specifically what information or relied-upon material you need if you cannot respond fully without it.
  5. Request a hearing in writing when needed. Section 75(4) provides for an opportunity of hearing where a written request is received or where an adverse decision is contemplated. Sections 73 and 74 also address the hearing opportunity when requested in writing. Keep proof of your request.
  6. Ask for a reasoned decision. Close by asking the proper officer to consider the submissions and evidence and issue a decision addressing them.

Avoid unsupported assertions, inconsistent figures and broad admissions that go beyond what you have checked.

Does the reply go in DRC-06 or ASMT-11?

For the category covered by Rule 142(4)—a reply to a notice whose summary was electronically uploaded in FORM GST DRC-01—the prescribed reply form is FORM GST DRC-06. Do not assume DRC-06 applies to every GST communication. A scrutiny discrepancy communicated in ASMT-10 follows the ASMT-11 explanation or acceptance route instead.

Form Use described in CBIC rules or assessment material
DRC-01 Electronic summary accompanying covered demand notices.
DRC-02 Electronic summary accompanying a covered statement under section 73(3) or 74(3).
DRC-03 Intimation of specified payment.
DRC-04 Acknowledgement of specified payment.
DRC-05 Order concluding covered proceedings following qualifying payment.
DRC-06 Reply for notices within the Rule 142(4) category.
DRC-07 Electronic summary of an order; treated as a notice for recovery.
ASMT-10 Scrutiny discrepancy notice.
ASMT-11 Scrutiny response or acceptance of discrepancy.

Should you pay, contest, or address only part of the demand?

Compare the factual and legal strength of each ground, the records available, confidence in your calculations, the applicable payment consequences, the notice deadline and the next procedural steps. The Act and rules provide payment routes at specified stages, including provisions before notice and payment provisions after notice under sections 73 and 74. Rule 142 uses DRC-03 for specified payment intimations, DRC-04 for acknowledgements and DRC-05 in the covered conclusion process.

Because sections 73 and 74 have different payment and penalty consequences, do not decide solely by looking at the total demand or assume payment has the same effect in both cases. Check the current law and case-specific calculations before choosing whether to pay, contest, or address only part of a demand.

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File the reply and preserve proof

  1. Submit by the method, in the form and by the deadline that apply to the notice and portal procedure.
  2. Save the final reply, every attachment, the filing reference and portal acknowledgement.
  3. Keep separate proof of any written hearing request and of its submission.

If the portal is unavailable or the deadline is close, promptly seek qualified advice on a legally valid way to preserve your response. The available official material does not establish one fallback procedure for every situation.

What to check if an order follows

Rule 142 provides for DRC-07 as the electronic summary of an order and treats that summary as a notice for recovery. If an adverse order arrives, read the complete order—not only its summary—and promptly verify the applicable correction, review or appeal route and deadline with a qualified adviser.

Check that the rules and notice are current

The CBIC rules PDF described here identifies amendments through 1 January 2022. Later amendments or notifications may affect forms or procedure, so confirm the current consolidated law and the exact notice before acting. This is general information, not individualized legal or tax advice.

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