A GST demand notice needs an issue-by-issue reply filed by its deadline — each allegation answered with its own evidence, fraud charges handled under their own provision, and limitation tested before merits. This page builds the notice-specific issue, evidence and reply matrix: grounds split, invoices reconciled, reply filed with hearing sought under the Central Goods and Services Tax Act, 2017, Sections 73 to 75.
The summary is not the notice
The confusion this page corrects: teams reply to the DRC-01 summary and ignore the show-cause notice behind it. The summary states demands; the notice states grounds — and only the grounds can be answered. A reply addressing amounts without touching the allegations concedes everything disputed while disputing only arithmetic.
Notice files fail three predictable ways. The reply answers the summary figure instead of the notice's grounds, so the real allegations go unanswered by default. Fraud and non-fraud periods share one undifferentiated reply, so the harsher provision's consequences attach to the whole demand. Or limitation goes untested — answering a possibly time-barred demand on merits alone risks leaving the limitation plea unraised.
The output is a reply matrix with its filing: each issue rowed with its evidence and answer, fraud rows segregated, limitation tested first, DRC-06 filed with hearing requested.
Check your position first
Enter these inputs before opening the notice.
Note: the table above is read with the Central Goods and Services Tax Act, 2017, Sections 73 to 75 as the governing provisions for demands; the notice is served with a summary in FORM GST DRC-01 and the reply to it is furnished in FORM GST DRC-06 (Central Goods and Services Tax Rules, 2017, Rule 142(1)(a) and Rule 142(4)).
Period selects the provision
Sections 73 and 74 now cover tax pertaining to periods up to Financial Year 2023-24; demands for Financial Year 2024-25 onwards fall under Section 74A, inserted by the Finance (No. 2) Act, 2024 with effect from 1 November 2024 (Central Goods and Services Tax Act, 2017, Sections 73, 74 and 74A). Allocate each disputed year to its provision before choosing reply grounds. Replying under the wrong provision answers under law that does not govern.
Do it in order
- Read the notice, not the summary — extract each ground with its period, amount and evidence cited.
- Test limitation first — notice date against each period's time bar before touching merits.
- Segregate fraud rows — allegations with fraud or suppression go under their own provision with their own evidence standard under the Central Goods and Services Tax Act, 2017, Section 74 (periods up to FY 2023-24) or the fraud limb of Section 74A(5)(ii) (FY 2024-25 onwards).
- Reconcile disputed invoices — each demand line matched to books, returns and portal data with differences documented.
- Draft the reply ground by ground — admitted, denied with evidence, or legally objected — with payments adjusted.
- File DRC-06 and seek hearing — reply filed by the notice deadline with oral hearing requested and the acknowledgement preserved under the Central Goods and Services Tax Act, 2017, Section 75.
Worked example: ₹5 lakh ITC mismatch
Take a demand of computed ₹5,00,000 framed as one ITC mismatch. The matrix splits it into timing, missing-invoice and ineligible-credit rows with different answers.
Note: each row's outcome follows its own evidence.
The lesson: one ₹5,00,000 demand becomes three different replies — defended, cured with documents, and admitted with payment. A single blended reply would have conceded the defensible rows while weakly contesting the admitted one.
Limitation kills silently
Time-barred demands need no merits defence — the reply pleads limitation with the notice date, period dates and the applicable bar computed openly. Pleading merits alongside limitation is fine; pleading merits instead of limitation abandons the strongest ground. Compute the bar per period, since multi-period notices time-bar unevenly.
For periods up to Financial Year 2023-24, a fraud allegation extends limitation: the order is due within five years of the annual-return due date under Section 74(10), against three years under Section 73(10). An extension invoked without the fraud facts proved is an extension to challenge, not to accept — test its factual foundation before conceding its calendar. For Financial Year 2024-25 onwards there is no such extension at notice stage: Section 74A(2) sets one window of forty-two months from the annual-return due date, whether or not fraud is alleged (Central Goods and Services Tax Act, 2017, Sections 73(10), 74(10) and 74A(2)).
Fraud rows stand apart
Fraud, suppression and wilful-misstatement allegations carry higher penalties and, for periods up to Financial Year 2023-24, longer limitation — they must never share rows, evidence or arguments with ordinary non-payment issues. Segregate them physically in the matrix with separate counsel review; the reply's tone, proof and relief strategy differ fundamentally under the Central Goods and Services Tax Act, 2017, Section 74.
Payments against fraud rows need staged strategy — pre-notice, post-notice and appellate payments each carry different relief consequences. Compute each stage's outcome before paying a rupee, since payment timing under the fraud provision decides penalty survival under the Central Goods and Services Tax Act, 2017, Section 74.
Invoices reconcile line by line
Every disputed invoice gets matched across books, returns and portal data — present in all three, missing in one, or mismatched in value or period. The reconciliation with difference flags is the reply's backbone; assertions about invoices without the three-way match persuade nobody.
Produce missing documents with the reply rather than promising them later — invoices, e-way bills, transport proof and payment trails attached issue-wise. Later production needs adjournments the deadline may not grant; the complete first reply sets the adjudicator's first impression under the Central Goods and Services Tax Act, 2017, Section 75.
Hearing is a right to use
Written replies alone surrender the adjudicator's questions unanswered — the hearing request converts the file into a conversation where weak allegations collapse under questioning. Seek oral hearing in every substantive reply as routine, prepare issue-wise speaking notes from the matrix, and attend with the evidence indexed under the Central Goods and Services Tax Act, 2017, Section 75.
Record the hearing with minutes of what was asked and answered, filed the same day. Post-hearing written submissions close open questions within the granted time — the hearing without follow-up leaves the adjudicator with the department's last word under the Central Goods and Services Tax Act, 2017, Section 75.
If the deadline is near
A notice deadline days away prioritises ruthlessly: limitation plea drafted first, admitted rows computed with payment, extension sought in writing where genuinely needed. Interim replies preserve rights while the full matrix builds — file something substantive by the date, never silence, since default orders follow non-response under the Central Goods and Services Tax Act, 2017, Section 75.
Extensions of the reply window are requested before expiry with reasons, not assumed. An extension sought late reads as an afterthought; the diary from service date should have flagged the deadline with buffer weeks, not days, under the Central Goods and Services Tax Act, 2017, Section 75.
FAQ
Reply to summary or notice?
The notice — the summary states demands while only the notice states answerable grounds.
One reply for all periods?
No. Test limitation and provision per period — multi-period notices bar unevenly.
Fraud alleged — same reply?
Never blended. Fraud rows segregate with separate proof and strategy under the Central Goods and Services Tax Act, 2017, Section 74.
Missing invoices — promise later?
No. Produce with the reply — later needs adjournments the deadline may not grant under the Central Goods and Services Tax Act, 2017, Section 75.
Skip the hearing?
Never in substance. Hearings collapse weak allegations under questioning — request routinely under the Central Goods and Services Tax Act, 2017, Section 75.
Deadline days away — what first?
Limitation plea, admitted-row payments, interim substantive filing — never silence under the Central Goods and Services Tax Act, 2017, Section 75.
Sources
- Central Goods and Services Tax Act, 2017, Sections 73, 74, 74A and 75 (demands, limitation and adjudication; Section 74A inserted by the Finance (No. 2) Act, 2024 w.e.f. 1 November 2024)
- Central Goods and Services Tax Rules, 2017, Rule 142 (FORM GST DRC-01 summary; FORM GST DRC-06 reply)
- The company's notice, summary, service proof, reconciliations, payments and hearing record under the Central Goods and Services Tax Act, 2017, Sections 73 to 75
Related reading: https://www.harunraaj.com/blog/drc-01-not-show-cause-notice-gstat-2026-ruling-fy-2022-23. Tool: https://www.pvtltd.co/tools/compliance-calendar
What to send for a review
Send the notice with grounds, summary with service date, disputed periods, payments made and hearing preference. The review returns your issue-wise matrix with the reply skeleton and deadline plan.
Next steps on GST returns
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