GST & Indirect Tax · Notices, DRC-01 & Appeals
A GST notice has a clock on it. Most demands grow not because the case is weak, but because the reply was late, generic, or missed the one ground that mattered. We read the notice, build the reply on the law and your records, and carry it through appeal if the order still goes against you.
Reminder for returns not filed. File the pending returns fast, this is the cheapest stage to fix.
Scrutiny: the officer found a discrepancy (often GSTR-3B vs 2B vs 1). Reply in ASMT-11.
Pre-show-cause intimation of tax ascertained. A chance to explain or pay before a formal SCN.
Show-cause notice under Section 73 (non-fraud) or 74 (fraud). Reply in DRC-06 within the time given.
Show cause for cancellation of registration. Reply in REG-18 before the GSTIN is cancelled.
Departmental audit under Section 65 (or special audit under Section 66). We manage the audit and findings.
| Stage | What it is | Your window |
|---|---|---|
| Scrutiny (ASMT-10) | Discrepancy flagged; reply with reconciliation and records (ASMT-11). | As stated, usually 30 days |
| Intimation (DRC-01A) | Tax ascertained before SCN; pay or explain in Part B. | As stated |
| Show-cause notice (DRC-01) | Formal demand under Section 73/74 (74A from FY 2024-25). Reply in DRC-06. | Per notice, often 30 days |
| Personal hearing | We appear and argue the reply on record. | As scheduled |
| Order (DRC-07) | Adjudication order confirming or dropping the demand. | , |
| First appeal (APL-01) | Appeal to the Appellate Authority with 10% pre-deposit of disputed tax. | 3 months (+1 condonable) |
| Tribunal (APL-05) | Appeal to the GST Appellate Tribunal where the first appeal fails. | Per GSTAT timeline |
Ordinary short-payment or wrong credit. Lower penalty, and nil penalty if you pay tax with interest before the SCN.
Alleges suppression or wilful misstatement. Much higher penalty and a longer time limit, worth contesting the very allegation.
A single, common time-limit provision now replaces the 73/74 split for newer periods. We apply the right one to your period.
Government / statutory cost
Professional fees depend on the stage, the amount in dispute and the volume of records. You get a clear written quote after reading the notice on a short call, no hidden charges.
Send us the notice, book a 15-minute callIt depends on the notice. A scrutiny notice (ASMT-10) and a show-cause notice (DRC-01) usually give 30 days, but the exact period is stated on the notice itself and is strict. The safest step is to send us the notice the day it arrives so the reply is built well before the deadline.
Section 73 covers ordinary short-payment or wrong credit without any fraud, carries a lower penalty, and the penalty is nil if you pay the tax with interest before the show-cause notice. Section 74 alleges fraud, suppression or wilful misstatement, carries a much higher penalty and a longer time limit. For periods from FY 2024-25, a common Section 74A replaces the 73/74 split. Which provision applies materially changes your exposure, so it is worth contesting a wrongly-invoked Section 74.
No. DRC-01A is a pre-show-cause intimation telling you the tax the officer proposes to demand, giving you a chance to explain or pay before a formal notice. Handling it well often closes the matter before it becomes a DRC-01 show-cause notice.
Often, yes, and sometimes it is the cheaper choice. Paying voluntarily through Form DRC-03 before the show-cause stage can reduce or eliminate penalty. We give you an honest pay-versus-contest view based on the strength of the demand and the cost of disputing it.
To admit a first appeal before the Appellate Authority in Form APL-01, you must pre-deposit 10% of the disputed tax amount. This is your own tax held on deposit, not a fee, and it is adjusted against the final liability. The appeal must be filed within three months of the order, extendable by one month for sufficient cause.
The officer proceeds ex-parte and passes an order (DRC-07) on the basis available, usually confirming the full demand with interest and penalty. Recovery can then follow, including attachment of bank accounts. Replying on time, even to seek more time, keeps your position open.
Usually yes, if you act within the window. We file the reply in REG-18 addressing the ground for cancellation, commonly non-filing of returns, and, where registration is already cancelled, apply for revocation within the permitted period.
Both. We handle the reply at scrutiny and show-cause stages, appear at the personal hearing, and if the order still goes against you, file and argue the first appeal before the Appellate Authority and represent you up to the GST Appellate Tribunal.
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Vijay R Singh & Co., Chartered Accountants · FRN 136869W · ICAI M.No. 153926 · Andheri East, Mumbai, in practice since 2013. References are to the CGST Act 2017. Outcomes depend on the facts and records of each case; nothing here is a representation of result. General information, not tax advice until engaged.
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