GST NOTICES & APPEALS

GST notices run on forms
and clocks. We know both.

From a scrutiny mismatch to the Appellate Tribunal, every stage below has a form number, a deadline and a right way to respond. All of it runs under the founder’s personal sign-off, and nothing is filed without your written go-ahead.

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First read the same working day Written way forward within one working day Fees fixed in writing before work begins

The journey, stage by stage

Tap any stage to see what happens, which forms are in play, and what the clock says.

1

The notice arrives — read the form number first

ACT WITHIN: the date printed on the notice

GST notices announce themselves by form number, and the form tells you the stakes. ASMT-10 is a scrutiny of your returns pointing at mismatches. GSTR-3A chases unfiled returns. DRC-01A is the department’s intimation before a show-cause. DRC-01 is the show-cause itself, under section 73 where no fraud is alleged, under section 74 where it is; for periods from FY 2024-25 onwards, both situations travel under one common provision, section 74A. REG-17 threatens your registration. ADT-01 opens a departmental audit.

  • Find it on the portal first: every genuine notice appears under View Notices and Orders against your GSTIN. Verify the reference number before acting on anything that arrives by mail alone.
  • Check the GSTIN and the period. Groups with multiple registrations regularly answer for the wrong one, and a reply on the wrong GSTIN helps nobody.
  • Note which Act and which officer: Centre and State both issue notices, and the reply goes to the authority that asked.
ASMT-10GSTR-3ADRC-01ADRC-01 · s.73/74 · s.74AREG-17ADT-01
FROM PRACTICE

The section number changes everything. A section 73 notice is a conversation about tax; a section 74 notice is an allegation of fraud. The reply strategy, the penalty exposure and the settlement windows are all different. Identify before you draft.

2

Replying — scrutiny, intimations and show-cause

ASMT-10: 30 DAYS · SCN: AS STATED

An ASMT-10 is answered in ASMT-11, and the answer that works is a reconciliation: your books, your returns and the department’s figures in one table, with every difference explained and documented. A DRC-01A intimation is the chance to settle or contest before a show-cause is born. A DRC-01 show-cause is answered in DRC-06, and where anything adverse is proposed, you are entitled to a personal hearing and should take it.

  • Agree with part of it? Tax can be paid voluntarily in DRC-03, which narrows the dispute to what is genuinely contested.
  • Section 73 rewards early resolution: settle at the right stage and penalty falls away entirely. Section 74 has its own graded ladder where early payment caps the penalty. Which window you are in decides the strategy.
  • Ask for the hearing in writing, attend it, and file a written submission recording what was argued.
ASMT-11DRC-01A Part BDRC-06DRC-03Personal hearing
FROM PRACTICE

Most ASMT-10s are born from one habit: 3B filed without reconciling against 2B and books. The reply is a reconciliation table; the cure is doing that table monthly, before the department does it for you.

3

The order — and the demand behind it

DEMAND: PAYABLE WITHIN 3 MONTHS

The proceeding ends in an order with a DRC-07 summary, and the demand becomes recoverable if unpaid within three months. As with income tax, read the computation before reacting: ITC credited wrongly reversed, a period double-counted, interest computed on the gross instead of the net. Obvious errors go back to the same officer for rectification; real disputes go up in appeal.

  • Rectification of errors apparent on the record has its own window, far shorter than people assume. Move fast or lose the cheap remedy.
  • Paying under protest through DRC-03 is sometimes the right commercial call while the appeal runs. It stops interest without conceding the issue.
Order-in-OriginalDRC-07s.161 rectificationDRC-03
FROM PRACTICE

Interest arithmetic is the most commonly wrong line in GST orders. Recompute it independently every single time before deciding what to appeal.

4

First appeal — APL-01 with pre-deposit

3 MONTHS + 1 MONTH CONDONABLE

The first appeal goes to the Appellate Authority in Form APL-01 within three months of the order, with one further month condonable for sufficient cause. Filing needs a pre-deposit: the admitted amounts in full, plus a fixed percentage of the disputed tax, after which recovery of the balance stays. The appeal itself is won on grounds, drafted as independent attacks on each demand component: tax, interest and penalty each on their own feet.

  • The pre-deposit percentage and its caps are set by statute and have been revised in recent Finance Acts; we compute the exact figure for your order before filing.
  • Certified copies, the DRC-07 reference and payment proofs travel with the appeal; defects bounce filings and burn limitation days.
  • A well-run first appeal is also the record for everything after it. Every document you will ever need goes in now.
APL-01Pre-deposit challanCondonation application
FROM PRACTICE

Appeal tax, interest and penalty as separate grounds even when they rise from one addition. Appellate authorities routinely sustain one and drop another, but only if you asked separately.

5

Second appeal — the GST Appellate Tribunal

WITHIN THE NOTIFIED TRIBUNAL WINDOW

The GST Appellate Tribunal is now functioning, and orders of the Appellate Authority travel to it in Form APL-05 with a further pre-deposit on the disputed tax. Because the Tribunal is new, limitation windows for older orders run from notified dates rather than the order itself, which is a trap and an opportunity: some long-pending matters are still in time.

  • Tribunal practice is record-driven: the reconciliations, hearing submissions and evidence from stages two and four are what get argued.
  • Beyond the Tribunal lie the High Court on questions of law, and that is a different engagement entirely.
APL-05Additional pre-depositPaper book
FROM PRACTICE

If you hold an old unfavourable appellate order you thought was dead, have its Tribunal limitation checked against the notified dates before assuming anything.

6

Registration, refunds and the side-tracks

REG-18: 7 WORKING DAYS · REFUND SCN: AS STATED

Not every GST notice is about a demand. REG-17 proposes cancelling your registration and allows seven working days to reply in REG-18, with revocation routes if cancellation has already struck. RFD-08 proposes rejecting a refund and is answered in RFD-09. Each side-track has its own tight clock, and each can quietly strangle a business while the main dispute gets all the attention.

  • A cancelled registration stops your customers’ input credit the day it bites. Treat REG-17 as the most urgent paper on the desk.
  • Refund rejections are frequently cured by documentation the officer never saw. Ask what was missing before assuming the claim failed on law.
REG-17 / REG-18RFD-08 / RFD-09Revocation application
FROM PRACTICE

Seven working days means seven working days. Registration notices are the one category where we drop everything, because the commercial damage of missing them is immediate and spreads to your customers.

What GST disputes teach

The patterns repeat. The preparation is the advantage.

1

Reconcile monthly, dispute never

Books to 2B to 3B, every month. Firms that do this read ASMT-10s with boredom instead of fear.

2

The section number is the strategy

Section 73 invites settlement windows; section 74 demands a fight on the fraud allegation itself. Never reply before classifying.

3

Take the hearing

A personal hearing is a right where anything adverse is proposed. Orders passed without granting one have been set aside for that alone.

4

Pay the undisputed, fight the rest

DRC-03 on what you accept shrinks interest and shows good faith. Fighting everything weakens the parts worth fighting.

5

Recompute the interest

It is the most frequently wrong figure in orders, and nobody checks it. We do, every time, before anything is paid or appealed.

6

Protect the registration first

Demands take months to hurt. A cancelled GSTIN hurts tomorrow morning, you and every customer who claims your credit.

The forms, in one table

Form / provisionWhat it isThe clock
ASMT-10 / ASMT-11Scrutiny of returns / your replyReply within 30 days of the notice
GSTR-3ANotice to a non-filerFile within the period stated or face best-judgment assessment
DRC-01APre-show-cause intimationRespond in Part B; the settle-early windows live here
DRC-01 / DRC-06Show-cause under s.73 or s.74, s.74A from FY 2024-25 / your replyAs stated in the notice; personal hearing on request
DRC-03Voluntary paymentAny time; timing decides the penalty consequence
DRC-07Summary of the orderDemand recoverable if unpaid within 3 months
s.161Rectification of apparent errorsShort statutory window from the order; move immediately
APL-01First appeal, with pre-deposit3 months from the order, +1 month condonable
APL-05Appeal to the GST Appellate TribunalPer the notified limitation; older orders have special start dates
REG-17 / REG-18Registration cancellation show-cause / reply7 working days, the shortest clock in this table
RFD-08 / RFD-09Refund rejection show-cause / replyAs stated in the notice

References are to the Central Goods and Services Tax Act, 2017 and the rules thereunder; parallel State GST provisions correspond. Pre-deposit percentages and caps are as revised from time to time and are computed for your specific order before filing. This page explains process and is not advice on any specific notice. The timeline printed on your notice always prevails.

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© 2026 Vijay R Singh & Co., Chartered Accountants · FRN 136869W · ICAI M.No. 153926 · Practising since 2013

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