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If your notice is accompanied by an electronic summary in FORM GST DRC-01, rule 142(4) of the CGST Rules specifies FORM GST DRC-06 for your reply. Address each allegation in the notice, support factual statements with clearly labelled records, and check the notice and current applicable law for the response deadline and filing instructions. Not every document called a GST show-cause notice necessarily follows this route.
First, identify the notice and the process that applies
Read the complete notice, its annexures and any documents it relies on—not only the electronic summary. Rule 142 describes DRC-01 as the summary accompanying certain notices and refers to DRC-02 for certain statements. For notices whose summary is uploaded electronically in DRC-01, rule 142(4) specifies DRC-06 as the reply form. The rule text is available in the CBIC-hosted CGST Rules, 2017; that copy is dated 2021, so check for later amendments before relying on it.
Before drafting, make a working record of the notice number, issue and service dates shown, tax period or financial year, statutory section, allegations, proposed tax, interest and penalty, response date, and hearing details. Follow the actual notice for case-specific instructions.
Check the provision and the version of the law
The cited CGST Act text distinguishes sections 73 and 74: section 73 concerns cases other than fraud, wilful misstatement or suppression to evade tax, while section 74 concerns those specified fraud-related grounds. The applicable section can affect the legal issues and potential consequences, so do not copy a deadline, payment option or argument from another kind of notice. The CBIC-hosted CGST Act page is older and does not establish the current provisions or consequences for section 74A. The GST Portal’s appeal FAQ references section 74A among demand-order categories, but does not explain how to reply to a notice under it. Verify the current provision, effective date and any applicable notification using authoritative, updated material.
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Use the notice’s numbering as the backbone of your response. For every allegation, make clear whether you admit it, dispute it, or need clarification; then connect the explanation to the records that support it. This makes it easier to see what is contested and where the supporting evidence can be found.
Build an allegation-to-evidence schedule
Before writing the final reply, make a private schedule with one row for each allegation. Include the issue, your position, the relevant period and amount, the supporting record, and the attachment label you will cite in the reply. Depending on the allegation, useful records may include returns, invoices, ledgers, contracts, proof of payment, reconciliations or earlier correspondence. This is a practical organizing method, not a statutory exhaustive checklist.
For a reconciliation difference, show the period, the amount at issue, the source records and how you calculated the figure. If a record does not support a point, do not present it as proof; explain what the document does establish and identify any unresolved fact plainly.
Separate facts, evidence and legal submissions
Keep the reply concise and arrange it so each answer can be checked against its evidence. State the facts first, cite the labelled attachment, and then explain the legal position where needed. Do not answer only the summary if the full notice or relied-upon documents contain additional grounds or detail. The prescribed form provides a reply field and a list of documents uploaded, but the sources do not prescribe a universal argument template.
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Complete FORM GST DRC-06
The CBIC-hosted FORM GST DRC-06 is titled “Reply to the Show Cause Notice.” Its fields include the taxpayer’s GSTIN and name, notice reference and issue date, financial year, reply, list of uploaded documents, personal-hearing option and authorised-signatory verification. The form PDF is dated 2019; check the live portal for the current process and interface.
Use consistent attachment labels in the uploaded-document list and in the body of your reply. Before filing, check that each file is readable, corresponds to the label used, and supports the point for which you cite it. The sources cited here do not establish current upload-size limits or every portal screen.
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Whether to request a personal hearing
DRC-06 includes a personal-hearing option. Section 75 of the CGST Act addresses an opportunity of hearing where it is requested in writing or where an adverse decision is contemplated. If you want a hearing, make the request explicitly in writing and preserve it with your filed reply. See the CGST Act text, while keeping in mind that the cited page is not a current amendment check.
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- Follow the notice’s filing instructions. Use the applicable GST Portal process for the proceeding; do not assume every GST notice has the same form or route.
- Review the final reply and attachments. Check that each allegation is addressed, attachment labels match the files, and the documents are legible.
- Submit and save proof. Retain a copy of the filed reply and attachments, the ARN, acknowledgement or other portal receipt, and any written hearing request.
The official materials cited above establish the DRC-06 route for the notices covered by rule 142(4), but do not verify every current portal screen, upload limit or case-specific deadline. Treat the response date in your notice as a matter to check promptly against the applicable current rules and instructions.
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When to get professional help
Consider review by a qualified GST practitioner or indirect-tax lawyer if the notice alleges fraud, wilful misstatement or suppression; involves substantial liability; raises a complex input tax credit or reconciliation issue; or has a near response deadline. Professional review is particularly useful when the legal classification itself is disputed or the notice relies on documents you do not understand.
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