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Start by identifying the notice’s statutory provision, response date and filing instructions. GST notices do not all use the same reply form or deadline. For demand notices covered by rule 142 of the CGST Rules, the electronic notice summary is in FORM GST DRC-01 and the prescribed representation or reply is FORM GST DRC-06. Other notice types may follow different procedures, so do not assume DRC-06 applies just because a document is called a show-cause notice.
1. Identify which notice procedure applies
Before drafting, read the complete notice and any summary or annexures. Record its issuing authority, GSTIN, reference number, issue date, cited section or rule, tax period, allegations, amount claimed, response date and filing instructions. Keep the notice and attachments as received, along with any available proof and date of service.
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Check the cited provision and form rather than relying on the document’s heading alone. Rule 142 covers specified demand-notice procedures; it does not establish one process for every GST notice. The response route, time limit and consequences depend on the provision and the facts. If the notice does not clearly state a response period, or its date appears inconsistent with the provision it cites, seek clarification or qualified advice promptly rather than assuming you have extra time.
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2. Match every allegation to evidence
Build the reply around the allegations in the notice, not a generic document bundle. For each point, identify the relevant period and amount, check the department’s stated basis, and compare it with the records that bear on that issue. Depending on the allegation, those may include returns, invoices, ledgers, reconciliations, payment records, contracts, earlier correspondence or other supporting material.
If you dispute a calculation, prepare a schedule showing how the notice’s figure differs from your figure. Tie each amount to the relevant return, account record or other source document, and explain any adjustment or difference. The records needed depend on the case; there is no universal statutory evidence checklist for every reply.
Working document checklist
Use this as a preparation aid and select only material that supports or explains a point in dispute:
- The complete notice, electronic summary, annexures, relied-upon documents and available proof or date of service.
- Relevant GST returns and reconciliations for the tax periods cited.
- Tax invoices, credit or debit notes, purchase or sales registers, and contracts or delivery evidence where relevant.
- Electronic liability, credit and cash ledger extracts, and payment challans if payment or credit is in issue.
- Earlier replies, departmental letters, audit material or orders relevant to the same issue.
- A calculation schedule mapping the department’s figures to the source records.
- An indexed list of attachments that matches the documents uploaded and the references used in the reply.
3. Draft the FORM GST DRC-06 reply
For a notice covered by rule 142, use the prescribed representation route in FORM GST DRC-06. The CBIC-hosted form, titled “Reply to the Show Cause Notice,” requests the GSTIN and name, notice reference number and issue date, financial year, reply text, list of uploaded documents, personal-hearing preference, and verification and authorized-signatory details.
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Name attachments consistently and cite each one where it supports a statement in the reply. Avoid uploading unrelated records: the form asks for a list of documents uploaded, but it does not prescribe one evidence set for every case. Have the reply verified by an authorized signatory.
4. File through the route stated for your notice
Follow the filing instructions in the notice and the applicable current rules. The CBIC-hosted ACES page describes online filing of show-cause notice replies as a system capability, but that description alone does not establish the current portal steps for every GST notice. Confirm the route that applies to your notice before submitting.
- Complete the required reply form for the applicable procedure, including the notice identifiers, reply and verification details.
- Upload the supporting documents and ensure the attachment list matches the files submitted.
- Submit through the applicable route and retain the filed reply, uploaded attachments, acknowledgement, portal reference or other delivery proof.
Allow time before the stated response date to address document or portal problems. Keep the submission records with the notice and the working file used to prepare the response.
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FORM GST DRC-06 provides a yes-or-no option for a personal hearing. If a hearing is appropriate, select the request in the form and state it clearly in the written reply. Keep a copy of the request and any subsequent hearing notice.
The retrieved CBIC-hosted text of sections 73 and 74 provides for an opportunity of hearing when a written request is received or when an adverse decision is contemplated. It also describes adjournment for sufficient cause subject to a limit of up to three adjournments in the covered hearings. Confirm the current applicable provision for your case; repeated extensions are not automatic.
6. Treat the response date as notice-specific
There is no safe single reply deadline for every GST show-cause notice. The applicable period can depend on the statutory provision, form, tax period, wording of the notice, and amendments or extensions that apply. Use the response date in the notice as an immediate filing target, then verify it against the current official law for the provision cited. If the period is unclear or appears inconsistent, seek clarification or qualified advice promptly.
A separate, conditional payment route appears in the retrieved rule 142 text for specified qualifying demand cases. In the circumstances described there, where the relevant tax and interest—and any penalty required by the cited statutory route—are paid within thirty days of service, the person intimates payment in FORM GST DRC-03 and the officer issues FORM GST DRC-05 to conclude proceedings. This is not a general reply deadline or recommendation to pay. Before using that route, check that the applicable section and facts qualify, verify the amount and consequences, and consider how payment affects your position.
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Consider having a qualified GST practitioner or indirect-tax lawyer review the notice and proposed response where it alleges fraud or suppression, involves a large or multi-period demand, disputes input tax credit, relies on extensive third-party records, raises limitation or jurisdiction questions, or may affect appeal strategy. Before engaging someone, check their qualifications and experience with the notice type, agree the scope of work and fees, and make sure the response date is understood.
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