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FORM GST DRC-07 is the electronic summary of a GST adjudication order that creates a demand. It records the tax, interest, penalty and other amounts payable, and under Rule 142(6) of the Central Goods and Services Tax Rules, 2017, the underlying order is treated as the notice for recovery. It is therefore not a harmless portal entry: a taxpayer must read the complete reasoned order, verify the demand and either pay, seek correction where available, or file a first appeal.
A first appeal normally goes to the Appellate Authority under section 107 of the CGST Act within three months from the date the order is communicated. The authority may allow one additional month for sufficient cause. Recovery of the balance is deemed stayed only after the statutory payment and a validly acknowledged appeal—not merely because an appeal document was uploaded.
What GST DRC-07 is
DRC-07 is an electronic summary generated for an order that creates a GST demand. Rule 142(5) of the CGST Rules covers orders made under sections 52, 62, 63, 64, 73, 74, 75, 76, 122, 123, 124, 125, 127, 129 and 130 of the CGST Act. The summary states the amounts payable and links the demand to the adjudication order for a particular financial year or tax period.
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In practical terms, DRC-07 signals that the department has moved from an allegation or proposed demand to an enforceable adjudicated demand. The exact section, period, issue and reasoning in the signed order determine what is actually payable and what challenge is available.
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Is DRC-07 itself the order?
The form is a summary, not a replacement for the complete reasoned adjudication order and its annexures. It may show the order number and date, financial year or tax period, issue category, description of goods or services, statutory section and a demand table. The table can contain tax, interest, penalty, fee, other amounts and a total, depending on the version of the form used.
Read the order that supports the summary. A DRC-07 screen can omit factual analysis, calculations, relied-upon documents and the response made to the notice. If the summary and the reasoned order appear inconsistent, preserve both versions and obtain advice on which document controls the appeal and recovery analysis.
Why the form deserves immediate attention
Three details control most response decisions:
- Communication date: the first-appeal clock generally runs from the date the decision or order is communicated, not simply the date printed on the order.
- Statutory section: the section identifies the legal route and often affects the factual issues, limitation arguments and documents needed.
- Demand composition: admitted tax, disputed tax, interest, penalty, fine and fees are treated differently when calculating the appeal payment.
The portal entry may also be the point at which recovery activity becomes visible. Do not wait for a separate collection letter before checking limitation, the demand arithmetic and the appeal route.
What appears in a DRC-07 summary
Use the form as an index to the order. Confirm each of these fields against the underlying documents:
- Order number and order date.
- Financial year or tax period covered.
- The issue or issues selected in the form.
- Description of the goods or services involved.
- The statutory section under which the order was made.
- Tax, interest, penalty, fee, other amounts and the total demand, where applicable.
The issue list can include classification, valuation, rate of tax, suppression of turnover, excess input tax credit, excess refund and place of supply. A single order may involve more than one issue, so reconcile each line rather than treating the total as one unexplained figure.
What to do as soon as DRC-07 appears
- Download the complete record. Save the DRC-07 summary, the signed or reasoned order, every annexure and the portal communication or acknowledgement showing when the order was made available or otherwise communicated.
- Build a period-by-period reconciliation. Match every demand line to returns, invoices, credit notes, e-way or other transaction records used in your business, payment challans and earlier submissions. Keep the department’s calculation beside your recalculation so differences are visible.
- Locate the notice and response history. Preserve the notice, DRC-01 and DRC-06 material where present, your written reply, hearing submissions, adjournment requests and portal acknowledgements. The order should be checked against what you actually submitted.
- Mark the legal section and issue. Record whether the order cites section 52, 62, 63, 64, 73, 74, 75, 76, 122, 123, 124, 125, 127, 129 or 130, and note each issue category selected in the form.
- Separate admitted and disputed amounts. Prepare separate totals for tax you accept, tax you contest, interest, fine, fee and penalty. Section 107’s first-appeal payment depends on this split, not merely on the DRC-07 grand total.
- Calendar the filing date. Use the communication date, calculate three months, and preserve evidence of that communication. If circumstances may justify delay, document them immediately rather than assuming a late filing will be accepted.
Appeal deadline for a DRC-07 order
Section 107(1) of the CGST Act permits an aggrieved taxpayer or unregistered person to appeal an adjudicating authority’s decision or order to the Appellate Authority within three months from the date the order is communicated. Section 107(4) allows the Appellate Authority to admit an appeal filed up to one further month when sufficient cause prevented filing within the original period.
The extra month is not an automatic extension. A late appellant should state the cause, support it with records and ask for condonation. Once the additional period has expired, do not assume that the Appellate Authority can overlook the limitation problem; obtain professional advice on any alternative remedy before recovery steps escalate.
How to calculate your last day
- Identify the date on which the order was communicated to you, using the portal record, email or other reliable proof.
- Count three months from that date and record the resulting last day for an ordinary appeal.
- If filing after that date but within the possible one-month condonation window, prepare a separate explanation of sufficient cause and supporting evidence.
- Allow time for payment, document certification, portal submission and any technical failure. A draft appeal that is not validly acknowledged does not protect the limitation position.
How to file the first appeal on the GST Portal
The GST Portal FAQ directs taxpayers to the following route for an appeal against a demand order:
- Sign in to the GST Portal.
- Open
Services > User Services > My Applications. - Set
Application TypetoAppeal to Appellate Authority. - Select
New Application. - Choose
Demand Orderwhen the portal asks for the type of order. - Complete the appeal in FORM GST APL-01, identify the challenged order and enter the amounts required by section 107.
- Upload the relevant order, grounds, statement of facts, reconciliation and supporting records in the formats and size limits shown by the portal.
- Make the required payment of admitted dues and the disputed-tax pre-deposit, then submit using the permitted authentication method.
- Save the provisional acknowledgement, payment reference and every submission receipt.
Rule 108 of the CGST Rules requires the relevant documents and a certified copy of the decision or order. The certified copy is to be submitted within seven days. The rule explains when the provisional acknowledgement date or a later date tied to the certified copy governs filing; the final acknowledgement carries the appeal number. Follow the portal’s current instructions and do not treat a provisional screen message as the final acknowledgement until the required documents have been accepted.
Documents to prepare before opening APL-01
- The complete adjudication order and DRC-07 summary.
- The notice and your reply, including DRC-01/DRC-06 material where part of the case record.
- Return extracts, invoice registers, ledgers, credit notes and payment challans relevant to each disputed line.
- A concise statement separating admitted tax, disputed tax, interest, fine, fee and penalty.
- Proof of the communication date and any evidence supporting a request for condonation.
- A certified copy in the manner required by Rule 108, plus a copy of the portal acknowledgement after submission.
How much pre-deposit is required
Section 107(6) requires two components for a first appeal:
- Payment of all admitted tax, interest, fine, fee and penalty; and
- Payment of 10% of the remaining amount of tax in dispute.
The 10% calculation is tied to the disputed tax component. It is not described as 10% of the entire DRC-07 total, so do not include disputed interest or penalty in that percentage unless a professional adviser identifies a specific statutory reason to do so. The order, your admission position and the wording of the payment requirement must be reconciled before submission.
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|---|---|---|---|
| Admitted tax ₹40,000; disputed tax ₹100,000; admitted interest ₹5,000 | ₹45,000 | ₹100,000 | ₹10,000 |
| Admitted tax ₹0; disputed tax ₹250,000; admitted penalty ₹8,000 | ₹8,000 | ₹250,000 | ₹25,000 |
| All tax and other amounts admitted | All admitted tax, interest, fine, fee and penalty | ₹0 disputed tax | ₹0 under the 10% disputed-tax component |
The figures in the table are arithmetic illustrations of the statutory formula, not a calculation of any particular taxpayer’s liability. Use the amounts in your order and obtain a checked computation where the order contains multiple periods, cross-utilised credits or overlapping penalties.
Will an appeal stop GST recovery?
Section 107(7) provides that, after the payment required by section 107(6), recovery of the balance is deemed stayed. The GST Portal FAQ similarly explains that an admitted appeal flags the disputed balance as non-recoverable. This protection depends on the statutory payment and a valid appeal process.
Uploading a form without paying the required amount, omitting the certified copy, missing the acknowledgement stage or filing outside the permitted period can leave the demand exposed. Keep the payment challan, appeal number and final acknowledgement together and check the portal demand status after submission. If recovery action continues despite a properly completed appeal, give the officer the acknowledgement and payment evidence promptly and seek advice on the appropriate representation or remedy.
How to develop grounds against the order
A strong appeal responds to the reasoning in the order, not just to the total in DRC-07. Organise grounds by the issue actually decided and cite the page, annexure or calculation that is wrong.
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Compare the order’s classification with product or service descriptions, contracts, technical literature, tariff material and the rate applicable to the relevant period. Identify whether the authority relied on facts that do not match the supplies actually made. Keep the period and rate notification version tied to each disputed invoice set.
Valuation
Reconcile the declared value with invoices, debit or credit notes, discounts, reimbursements and related-party or bundled-supply records that the order discusses. Show the department’s method and your alternative calculation line by line rather than offering only a lower total.
Suppression of turnover
Match the alleged suppression to sales registers, returns, bank records and reconciliation statements. If the order treats a timing difference, cancelled invoice or duplicate entry as unreported turnover, identify the original record and the period in which it was reported.
Excess input tax credit
Prepare an invoice-level schedule linking the credit claimed to purchase records, supplier data available to you, tax invoices, receipt of goods or services and reversals already made. Separate a documentation defect from a disagreement about eligibility; they require different evidence and arguments.
Excess refund
Reconcile the refund application, supporting statements, export or supply records, credit ledger entries and any subsequent adjustment. Identify whether the challenged amount is a calculation error, a duplicate claim or a substantive eligibility finding.
Place of supply
Set out the customer location, supplier location, movement of goods or performance facts and the documents used to establish them. Explain how the place-of-supply conclusion changes the tax charged and why the order’s facts do not support its result.
Procedural and reasoning defects
Check whether the order identifies the material relied upon, addresses your reply and evidence, gives a comprehensible calculation and stays within the issue and period stated in the proceedings. Preserve hearing records and portal submissions. A claim that the order ignored a response should point to the exact response and the omission in the order.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Section-specific checks before choosing your response
DRC-07 can summarize orders made under several different provisions. The section printed on your form should drive the review:
- Sections 52, 62, 63 and 64: verify the statutory trigger, the period covered and the figures used when the department proceeded on a special assessment or return-related basis.
- Sections 73, 74, 75 and 76: examine the tax determination, interest and penalty reasoning, the notice and reply history, and whether the order answers the evidence filed.
- Sections 122 through 127: map each alleged contravention to the person, transaction and penalty provision actually cited.
- Sections 129 and 130: preserve detention, seizure, release and confiscation documents and check how the goods, conveyance and tax computation are connected to the demand.
This list does not replace a section-by-section legal opinion. Limitation, jurisdiction, classification, input-tax-credit, fraud and constitutional arguments can turn on facts that a short summary cannot show.
Common mistakes and how to avoid them
- Using the order date instead of the communication date: retain the portal or email evidence that establishes when the order was communicated.
- Appealing only the DRC-07 screen: attach and analyse the reasoned order and annexures; the summary alone may not reveal the disputed calculation.
- Calculating 10% on the grand total: separate admitted dues and the disputed tax component before making the payment.
- Assuming upload equals stay: confirm payment, certified-copy compliance and final acknowledgement before treating recovery as protected.
- Ignoring the seven-day certified-copy requirement: prepare the certified copy before filing and calendar the submission deadline under Rule 108.
- Submitting a generic objection: tie every ground to a tax period, invoice group, paragraph of the order and supporting document.
- Waiting for recovery to start: limitation continues while you wait, so begin the reconciliation and payment calculation as soon as DRC-07 appears.
A practical decision framework
Use this sequence to choose the next action without confusing payment, correction and appeal:
- Is the demand accepted? If yes, verify the payment requirement and retain proof. If only part is accepted, quantify the admitted portion separately.
- Is the order factually or legally wrong? Identify the precise line, issue and reason before drafting grounds.
- Are you within three months of communication? Prepare APL-01 and the statutory payment immediately. If not, assess whether a sufficient-cause request can fit within the additional one-month period.
- Can you prove the case? Gather the order, notices, replies, returns, invoices, challans and reconciliations before finalising the statement of facts.
- Has recovery begun? Provide the valid acknowledgement and payment evidence, and obtain professional assistance if the department does not recognise the statutory stay.
When professional advice is especially important
Obtain a GST practitioner or tax lawyer’s advice where the order involves alleged fraud or suppression, large or multi-year input-tax-credit reversals, place-of-supply disputes, confiscation, competing registrations, disputed communication dates, limitation, jurisdiction or a constitutional challenge. The first appeal is document-driven and time-limited; an incomplete record can be harder to repair after filing.
Key takeaway
DRC-07 is the portal summary of a GST demand order with recovery significance. Download the complete order, verify every period and issue, record the communication date, separate admitted and disputed tax, and file APL-01 through the GST Portal’s Appellate Authority workflow within the statutory period. Pay admitted dues plus 10% of the remaining disputed tax and complete the Rule 108 certified-copy and acknowledgement requirements; only then does section 107(7)’s deemed stay of the balance apply.
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