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Random freezes, missing sound and display glitches usually trace back to one bad driver. Find and replace yours safely.Free scan · under a minuteChallenge the demand on the record: answer each allegation with relevant documents, identify what the officer relies on and what is missing, and request a written hearing. If a third-party statement matters to the case, identify it and explain why you need to question its maker. Suspicion or third-party evidence does not automatically invalidate a demand; the notice, evidence, statutory provision, and procedure all matter.
First, confirm which GST law and demand process applies
This article concerns India’s Goods and Services Tax, particularly the Central Goods and Services Tax Act, 2017 (CGST Act). State GST and Union Territory GST laws may operate alongside it. Check the notice for the issuing authority, applicable enactment, tax period, demand provision, and forum before relying on a procedural point.
The distinction between sections 73 and 74 described below concerns tax periods through FY 2023–24. For later periods, check the law and amendments applicable to the relevant tax period, including whether section 74A or another provision governs. Do not calculate a deadline or assume a provision applies based on the notice date alone.
Check the statutory basis: section 73 or section 74
For the covered periods, both provisions address tax not paid or short paid, erroneous refunds, and wrongly availed or utilised input tax credit. The key distinction is whether the department alleges the specified culpable conduct.
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| Question | Section 73 | Section 74 |
|---|---|---|
| What is alleged? | The matter is for a reason other than fraud, wilful misstatement, or suppression of facts to evade tax. | The department alleges fraud, wilful misstatement, or suppression of facts to evade tax. |
| What should you examine? | Whether the notice identifies the alleged non-compliance and explains the amount and grounds. | Whether the notice identifies facts supporting the culpable ground, rather than relying on a label or suspicion alone. |
| What if the culpable ground is not established? | Section 75(2) directs determination as if the notice had been issued under section 73. | Section 75(2) provides for determination as if the notice had been issued under section 73 if the fraud, wilful-misstatement, or suppression charge is not established. |
These are not options a taxpayer can elect between. The authority’s legal basis and the facts determine the applicable track. Limitation periods and potential penalty consequences also depend on the provision, tax period, dates, and procedural history; verify them against the actual file and current law.
Build a point-by-point reply to the notice
A show-cause notice gives the taxpayer an opportunity to represent their position before the officer determines the demand. The notice should state the amount and grounds relied on. A useful reply makes it possible to trace each disputed amount from the allegation to the supporting evidence and the answer.
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- Read the full notice and annexures. Identify every allegation, calculation, period, statutory provision, and document or statement said to support the demand.
- Make an allegation-to-evidence table. For each point, record what the notice asserts, what material supports it, what you admit, deny, or cannot confirm, which records answer it, and what finding or procedural step you seek.
- Reconcile the figures. Compare the proposed amounts with relevant returns, invoices, ledgers, contracts, bank entries, delivery or transport records, stock records, correspondence, and accounting records. Which records matter depends on the allegation; no single document proves entitlement in every case.
- Identify what you need from the department. Specify the particular statement, report, third-party record, relied-upon document, or computation you seek, and explain how it affects your response. A request for material is stronger when it identifies the item and its relevance rather than asking generally for every investigative document.
- File the reply through the applicable channel. Retain the filed copy, acknowledgement, attachments, proof of service, and any hearing notes.
Do not assume that every investigative document must always be disclosed. Whether a particular item must be provided, or is subject to a restriction, depends on the circumstances and applicable law.
Challenge third-party evidence by identifying its weaknesses
For each third-party statement or report, identify its maker, date, subject, connection to your business, and the specific proposition for which the department relies on it. Then explain what is uncertain or disputed and why that matters to the demand.
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- Does the maker appear to have firsthand knowledge of the transaction or event?
- Is the statement complete and in context, and have you received the material needed to understand it?
- Does it conflict with contemporaneous business records or other independent evidence?
- Has the maker’s account been corroborated, or is it the main support for the allegation?
- What practical prejudice would follow if the statement were accepted without an opportunity to test its accuracy?
If the statement is materially relied upon, request a copy and make a specific written request to question its maker. Name the person where known, or identify them by role, and explain which disputed issues or questions require testing. Preserve the request and the department’s response in the record.
In W.P.(C) 4853/2025, the Delhi High Court discussed cross-examination of persons whose statements were relied upon against the petitioner and connected the issue to the hearing under section 75(4). The court stated: “Basic requirement of the rule of law is that before condemning a person that too on the basis of a statement of third party, the party against whom such statements have been relied upon is to be granted an opportunity to cross examine the person who gave that statement.” This was a ruling in the circumstances before that court, not a guarantee that every request in every GST proceeding will be granted. Its application depends on the facts, procedural posture, jurisdiction, and subsequent precedent.
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Request a hearing and preserve procedural objections
Under section 75(4), an opportunity of hearing must be granted if the person chargeable with tax or penalty requests it in writing, or if an adverse decision is contemplated. Include an express written request in the reply. State which factual or evidentiary disputes need to be addressed and ask that the request and any decision on it be recorded.
Section 75(5) permits an adjournment for sufficient cause, with reasons recorded, and limits adjournments to three during the proceedings. If you need one, explain the cause and make the request promptly.
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Keep the notice, reply, hearing record, and final order together. The order must state the relevant facts and basis for its decision; it cannot demand more than the amount specified in the notice or confirm a demand on grounds outside the notice. Compare the documents for a changed theory, new ground, unexplained rejection of material evidence, arithmetic mismatch, or reliance on a statement you had no meaningful opportunity to address. Whether a defect warrants setting aside an order depends on its significance and the record.
Preserve evidence and issues for an appeal
CBIC appeal rules provide for an appeal to the Appellate Authority in Form GST APL-01. Rule 5 restricts additional oral or documentary evidence at appeal, subject to specified exceptions. These include circumstances where the adjudicating authority refused evidence that should have been admitted, sufficient cause prevented its production, or the order was made without sufficient opportunity to adduce relevant evidence. The appellate authority must record written reasons for admitting additional evidence and give the department an opportunity to examine or rebut it.
For that reason, submit relevant evidence during adjudication where possible. If you cannot, explain why in the reply or hearing record and preserve evidence of the attempt. After an adverse order, check the current appeal deadline, pre-deposit, filing method, and applicable form against the order and governing law. The correct calculation depends on the tax period, order and service dates, and procedural history.
Quick Recap
Use this checklist before filing
- Obtain the complete notice, annexures, calculation, relied-upon material, and electronic service details.
- Confirm the GSTIN, issuing officer, governing CGST, SGST, IGST, or other law, tax period, demand section, and whether fraud or suppression is alleged.
- Map each allegation to the evidence cited, your response, relevant business records, and the specific relief or procedural step requested.
- Request missing relied-upon material and a written hearing; if third-party statements are material, identify them and explain a focused cross-examination request.
- Review limitation, jurisdiction, proper officer, notice specificity, statutory elements, computation, interest, penalty, and any applicable circular or precedent against the actual file.
- Retain the filed response, acknowledgement, attachments, service proof, hearing notes, and evidence submitted or requested.
- If an order is issued, compare it with the notice and reply, then promptly calendar the appeal deadline under the applicable law.
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