Start with the notice itself: identify its type, cited section, tax period, issuing authority, allegations and stated response date before choosing a reply format or assembling documents. GST show-cause notices do not all follow one deadline or procedure. For demand proceedings covered by Rule 142(4), the reply is furnished in Form GST DRC-06; the underlying notice and its annexures still need to be read in full.
This is general information about Indian GST procedure, not an assessment of a particular notice or taxpayer’s deadline. If the amount is significant, the facts are disputed, or the response date is close, consult a qualified GST practitioner or tax adviser promptly.
What to check before drafting a reply
Save the complete notice, every annexure, related portal communication and proof of service. The summary shown on the GST portal may not contain all the reasoning or calculations in the underlying notice.
- Issuing authority and officer, GSTIN, notice reference number and issue date.
- Tax period and statutory section cited.
- Each allegation, the amount attributed to it, and the tax, interest and penalty calculations.
- Any hearing information and the response date or filing instructions stated in the notice.
- The service record and any access or technical problems that could affect your ability to respond.
Under Rule 142, covered notices have an electronic summary in Form GST DRC-01. A statement in covered demand proceedings may have a summary in Form GST DRC-02. Treat these as summaries: compare them with the complete notice and annexures, and flag any difference in allegations, period or amounts.
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Which section applies to the tax period?
For a demand notice, check the section and the period before using a template. The relevant framework has changed, so a reply drafted for an earlier period may not fit a later one.
| Framework to check | What the cited provision concerns | Practical caution |
|---|---|---|
| Section 73 | Tax not paid or short paid, an erroneous refund, or input tax credit wrongly availed or utilised for reasons other than fraud, wilful misstatement or suppression to evade tax. | Check that the provision applies to the notice’s tax period and allegations; do not assume an old section 73 template is suitable for a later period. |
| Section 74 | The section 73-type demand issues where fraud, wilful misstatement or suppression to evade tax is alleged. | Read how the notice frames the allegation and verify the applicable statutory text and consequences for the period. |
| Section 74A | Relevant to demand proceedings for FY 2024-25 onward. | Its framework differs from the earlier section 73/74 regime. Verify the operative law and amendments for the specific notice rather than transplanting an earlier-period reply. |
The Central Goods and Services Tax Act and amendments should be checked in their current consolidated form. An older presentation of the Act or a prior form compilation may not reflect every later change.
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How to work out the response deadline
There is no single filing deadline that applies to every GST show-cause notice. Read the response date and instructions on the actual notice, then check the provision and tax period. If the notice, portal date, service record or calculation creates uncertainty, get advice promptly rather than relying on a general online deadline.
| Clock | What it governs | What to do |
|---|---|---|
| Representation or reply date | The date or period stated for responding to this particular notice. | Record it from the notice and portal, and confirm the applicable procedure and filing channel. |
| Payment option | A statutory payment window that may have specified consequences for a demand proceeding. | Do not treat it as the reply deadline. Check the section, trigger, conditions and consequences before making a payment election. |
| Issuance or adjudication limit | A statutory outer limit relevant to when a notice may be issued or an order made. | Assess it separately against the tax period and applicable provision; it is not a substitute for the response date. |
The 30-day periods in sections 73 and 74 relate to specific payment options and their stated consequences; they are not a universal deadline to file a representation. Section 74A has a different statutory framework. Do not calculate a personal due date from these general descriptions: it depends on the notice, service, period and operative law.
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How to assemble supporting documents
There is no official attachment checklist that fits every notice. Build an allegation-by-allegation schedule so the officer can see the issue, your position and the record supporting it. Reconcile your figures to the notice rather than simply uploading a large bundle of records.
| For each allegation, record | What to include |
|---|---|
| Issue and period | A short description of the allegation and the financial year or tax period involved. |
| Your position | What you admit, dispute or cannot verify, with the reason stated clearly. |
| Amount | The amount in dispute and how it relates to the officer’s calculation. |
| Supporting evidence | Document name, date and a precise page or annexure reference. |
Depending on the issue, useful records may include GST returns, invoices, ledgers, credit notes, contracts, e-way or transport records, payment challans, reconciliation schedules, prior correspondence or earlier orders. Attach only material that supports a point in the reply. Make scans legible, label files consistently, and index multi-page records. If a calculation is disputed, show the figures and reconciliation rather than relying on a general denial.
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How to draft and file the response
- Identify the proceeding. State the notice reference, issue date, GSTIN, relevant tax period and cited section. Make clear which notice and allegations the submission addresses.
- Answer each allegation in order. Set out the relevant facts, your position and the legal point where applicable. Avoid a blanket denial that leaves individual issues unanswered.
- Reconcile the amounts. Separate admitted from disputed amounts, address the officer’s arithmetic and explain any difference with a supporting schedule. Do not make admissions or choose a payment option before checking the figures and applicable section.
- Reference the evidence. Cite each relevant attachment by its label and page or annexure number. Ensure the figures in the reply match the supporting records.
- State the requested outcome. Explain what you want the authority to do about each disputed issue, such as drop or revise the proposed demand, to the extent supported by your facts and law.
- Use the prescribed route where it applies. For replies covered by Rule 142(4), furnish the representation in Form GST DRC-06, using the portal instructions and any permitted attached submission.
Form GST DRC-06 requests the GSTIN and name, notice reference and date, financial year, reply, uploaded documents, hearing choice and authorized-signatory verification. Those fields are a useful minimum drafting check when the form applies; they do not replace the notice-specific requirements.
Whether to request a personal hearing
DRC-06 provides a choice about seeking a personal hearing. Request one explicitly when oral clarification would help explain the facts, records or calculation, and retain proof of the request. The presence of a checkbox alone does not establish the hearing entitlement in every kind of proceeding.
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Check the verification before submission
Form GST DRC-06 states: “I hereby solemnly affirm and declare that the information given hereinabove is true and correct to the best of my knowledge and belief and nothing has been concealed therefrom.” The authorized signatory should check that the reply and attachments are accurate and complete before making this declaration.
What to retain after filing
- A copy of the submitted DRC-06 or attached reply and every uploaded document.
- The portal acknowledgement or reference showing the filing and its date.
- Proof of any hearing request and records of later hearing communications.
- Evidence of portal errors or access problems, including dates and any available acknowledgements or correspondence.
Keep the complete filed version, not just the draft. If a technical problem threatens a deadline, document it and seek advice on the appropriate immediate steps rather than assuming that an attempted upload counts as a filed reply.
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