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Freedom251 › Blog › DRC-06

How to Respond to a GST Show-Cause Notice and Meet the Reply Deadline

By Freedom251 Team · · 5 min read

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There is no single reply deadline or filing route for every Indian GST show-cause notice. Start by identifying the statutory section, proceeding, issuing authority, date and method of service, and reply date stated in your notice. Then answer each allegation with supporting records, file through the procedure that applies to that notice, and keep proof of submission.

First, identify exactly what kind of notice you received

Read the entire notice and every attachment before deciding how to respond. A demand notice and a registration-cancellation notice are different proceedings, with different forms and rules. The deadline printed on one type of notice should not be applied to another.

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Record the key details

  • GSTIN, notice or reference number, issuing authority and statutory section.
  • Tax period or financial year covered, issue date, and the date and method by which the notice was served.
  • The stated reply-by date and any hearing date or instructions for making a representation.
  • The amount claimed, its tax, interest and penalty components, and the calculation or evidence relied on.

Check that the notice and attachments are complete and that the details match your records. The CGST Act includes more than one legally recognized method of service, so do not assume the issue date is necessarily the service date. For the applicable service rule, see section 169 of the Central Goods and Services Tax Act, 2017.

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How to prepare a point-by-point reply

Build the reply around the allegations in the notice rather than sending a general denial or a bundle of unexplained documents. The goal is to make clear what you agree with, what you dispute, why, and which records support your position.

  1. Break the notice into issues. List each factual allegation, calculation, or legal point separately.
  2. State your position on each issue. Explain the relevant facts and, where applicable, identify a factual error, missing context, or disputed calculation. Do not make assertions you cannot support.
  3. Match evidence to the issue. Use relevant returns, invoices, ledgers, reconciliations, earlier correspondence, or other records. Identify each attachment in the reply and explain what it demonstrates.
  4. Check the figures. Reconcile amounts in the notice against your records. If you dispute a calculation, show the basis of the difference clearly.
  5. Review the complete submission. Confirm that your response addresses every allegation and that the cited documents are attached and readable.

Which form should you use?

The form depends on the proceeding. For the demand-notice circumstances covered by Rule 142 of the CGST Rules, DRC-01 is the electronic summary associated with specified notices, and DRC-06 is the reply or representation form in the circumstances set out by that rule. DRC-06 provides fields for notice details, the reply, uploaded documents and a personal-hearing choice. It is not a universal reply form for every GST notice.

Use the filing route identified in your notice and the governing rule. For a covered Rule 142 demand proceeding, follow the applicable DRC-06 process. For another kind of notice, check its prescribed form and instructions instead of assuming DRC-06 applies. Keep a copy of the filed reply, every uploaded document and the filing acknowledgement or other proof of submission.

How many days do you have to reply?

Use the deadline stated in the notice, checked against the rules for the specific proceeding and the date of service. The legal framework covers multiple kinds of proceedings; the available procedural sources do not support one universal reply period for all GST show-cause notices.

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For example, the cited registration rules set a seven-working-day response period for the specified REG-16 procedure concerning a registration-cancellation notice. That period is specific to that procedure; it is not the default deadline for a demand notice or every other GST notice.

Do not confuse three different time periods

  • Your reply deadline: the time allowed to respond to the particular notice under its applicable procedure.
  • The department’s order deadline: a separate period governing when an adjudication order must be issued under the applicable law.
  • A conditional payment period: a period that may apply to a specified payment route, not automatically to the time allowed to file a reply.

In particular, Rule 142’s provision for qualifying payment within thirty days of service in specified circumstances does not create a general thirty-day reply deadline. Check the section and circumstances that apply to your notice before relying on any period.

Can you ask for a personal hearing or more time?

Requesting a hearing

Section 75(4) of the CGST Act provides for a hearing when the person makes a written request or when an adverse decision is contemplated. For a proceeding using DRC-06, the form includes a personal-hearing option. If a hearing is appropriate, make the request through the method applicable to your notice and retain a copy of it.

Requesting an adjournment

Section 75 allows an adjournment when sufficient cause is shown, with reasons recorded, and limits the number of adjournments during the proceeding. If you genuinely need more time, request it promptly and explain the reason. Do not treat a request as an extension: continue to regard the stated deadline as operative unless an adjournment is granted.

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Should you pay the amount in the notice?

Payment is not a substitute for confirming the correct legal route or understanding the consequences. Rule 142 provides for reporting certain payments in DRC-03 and describes a conditional process under which qualifying payment within thirty days of service can conclude a proceeding in specified circumstances. Whether that route is available or advisable depends on the notice, the applicable section and the facts.

Before paying, verify how the payment would affect the specific proceeding and what, if anything, remains to be filed. Do not assume that paying a stated amount automatically answers every allegation or ends every kind of notice.

Before filing: a practical checklist

  • Have you identified the statutory section, proceeding, authority, service date and actual reply deadline?
  • Have you read the full notice and all attachments, including the evidence and calculations cited?
  • Does the reply address each allegation and explain each disputed fact or amount?
  • Are the supporting records relevant, clearly identified and attached?
  • Are you using the form and filing route that apply to this notice?
  • Have you requested a hearing if appropriate, and made any adjournment request promptly if needed?
  • Have you saved the filed reply, uploaded records and acknowledgement?

For a substantial demand, a fraud allegation, complex evidence, or uncertainty about limitation or jurisdiction, have a qualified GST practitioner or Indian tax lawyer review the notice and proposed response. The CGST Act and Rules may have been amended; verify the law applicable to your notice as well as the notice, attachments and portal status.

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DRC-06GSTGST noticeIndia TaxTax compliance

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