GST Notice Reply in Delhi
Reading, answering and following up GST notices: ASMT-10 scrutiny, DRC-01A, DRC-01B and DRC-01C intimations, DRC-01 show cause notices, registration notices and appeals.
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Quick answers
How many days do I get to reply to a GST notice?
It depends on the form. ASMT-10 (scrutiny of returns) and REG-31 (suspension) allow 30 days; DRC-01B and DRC-01C allow 7 days; REG-17 (cancellation show cause) allows 7 working days. A DRC-01 show cause notice states its own date, usually 30 days. The date in the notice itself governs.
Should I pay or contest a GST notice?
Pay the part that is correct and contest the rest. Tax paid with interest through DRC-03 before a show cause notice, or soon after it, reduces or removes the penalty. A demand that is wrong on facts or law is answered point by point with documents, and the officer must give a personal hearing before an adverse order.
Which notice is issued under Section 74A?
Show cause notices for FY 2024-25 onwards. Section 74A, in force from 1 November 2024, replaces Sections 73 and 74 for those years, with one time limit of 42 months from the annual return due date.
What our GST Notice Reply service covers
How the engagement works
How to start
Send these three things first:
- The notice or intimation as downloaded from the GST portal (with its reference number and date)
- GSTR-1, GSTR-3B and GSTR-2B for the period in question, or portal access through a GST practitioner login
- Purchase and sales registers, and the ledger for the tax period concerned
What happens next: Once the papers are reviewed, the scope of work and the information still needed are confirmed in an engagement letter before the reply is drafted.
Documents required
- → Copy of the notice / intimation and any earlier correspondence
- → GSTR-1, GSTR-3B, GSTR-2A/2B and GSTR-9 / 9C for the year
- → Sales and purchase registers and the GST ledgers
- → Invoices, debit and credit notes for the items in dispute
- → E-way bills and transport documents (for movement of goods)
- → Bank statements showing payment to suppliers
- → Earlier orders, replies and DRC-03 payment challans
For a specific GST Notice Reply matter, you may send the details through the contact form, call +91 88022 54567 or write on WhatsApp (Mon–Sat, 10:00 AM–7:00 PM). Please do not send passwords or OTPs.
GST notices, time limits and how to respond
Which GST notice have you received?
Time limits are those in the CGST Rules unless the notice gives a longer date.
| Notice | Provision | What it means | Reply form and time |
|---|---|---|---|
| ASMT-10 | Section 61, Rule 99 | Discrepancies found on scrutiny of returns. | ASMT-11 within 30 days (or as allowed). Accepted by ASMT-12; if not, proceedings under 73/74/74A may follow. |
| DRC-01A | Rule 142(1A) | Pre-show-cause intimation of tax, interest and penalty the officer has worked out. Issuing it is now discretionary. | Pay through DRC-03, or reply in Part B with submissions, by the date given. |
| DRC-01B | Rule 88C | Tax in GSTR-1 exceeds tax paid in GSTR-3B beyond the set limit. | Pay the difference through DRC-03 or explain in Part B within 7 days. Unanswered, it blocks the next GSTR-1. |
| DRC-01C | Rule 88D | ITC claimed in GSTR-3B exceeds ITC available in GSTR-2B beyond the set limit. | Pay or reverse through DRC-03, or explain in Part B within 7 days. Unanswered, it blocks the next GSTR-1. |
| DRC-01 with show cause notice | Section 73, 74 or 74A, Rule 142(1) | Formal demand proceedings. | Reply in DRC-06 by the date given; personal hearing; order in DRC-07. |
| REG-31 | Rule 21A(2A) | Registration suspended because of differences between returns, or non-compliance with Rule 10A (bank details). | Reply within 30 days. Filing pending returns can lift a suspension made for non-filing. |
| REG-17 | Section 29, Rule 22 | Show cause why registration should not be cancelled. | REG-18 within 7 working days. |
Reply templates: reply to GST notice (ASMT-11 / DRC-06) and GST demand notice reply. For ITC reversals, see the ITC reversal letter.
Section 73, Section 74 and Section 74A
| Point | Section 73 (FY 2017-18 to 2023-24) | Section 74 (FY 2017-18 to 2023-24) | Section 74A (FY 2024-25 onwards) |
|---|---|---|---|
| When used | No fraud, wilful misstatement or suppression | Fraud, wilful misstatement or suppression alleged | Both kinds of case, with different penalties |
| Time limit for the order | 3 years from the due date of the annual return; notice at least 3 months earlier | 5 years from the due date of the annual return; notice at least 6 months earlier | Notice within 42 months of the annual return due date; order within 12 months of the notice (extendable by 6 months) |
| Penalty | 10% of tax or Rs 10,000, whichever is higher | Equal to the tax | Non-fraud: 10% of tax or Rs 10,000, whichever is higher. Fraud: equal to the tax |
| Paying early | No penalty if tax and interest are paid before the notice or within 30 days of it | 15% before the notice; 25% within 30 days of it; 50% within 30 days of the order | Non-fraud: no penalty if paid before or within 60 days of the notice. Fraud: 15% before the notice, 25% within 60 days of it, 50% within 60 days of the order |
Check the year against the section first: a notice for FY 2023-24 or earlier must be under Section 73 or 74, and one for FY 2024-25 onwards under Section 74A; a mismatch, or a notice issued after the time limit, is a ground on its own. For example, the annual return for FY 2024-25 was due on 31 December 2025, so a Section 74A notice for that year can be issued up to 30 June 2029. Interest under Section 50 applies to late tax in every case. The GST late fee calculator and the ITC calculator help check the figures before replying.
Pay or contest
An honest reconciliation usually splits a notice into items that are correct and items that are not. Admitted tax and interest are paid through DRC-03 (from the electronic cash or, where allowed, credit ledger) and the payment is shown in the reply; this caps or removes the penalty as the table shows. Disputed items are answered with the reason and the evidence: the invoice, the e-way bill, the supplier’s GSTR-1, the bank payment, or the provision relied on.
Personal hearing
Under Section 75(4), an opportunity of personal hearing must be given where the person asks for it in writing or where an adverse decision is contemplated. Adjournments may be granted for sufficient cause, but not more than three times (Section 75(5)). The order cannot confirm an amount higher than, or on grounds other than, those in the notice (Section 75(7)).
Appeal after an adverse order
- First appeal: to the Appellate Authority in APL-01 within three months of the order being communicated; a further one month can be allowed for sufficient cause (Section 107). The admitted amount must be paid in full, plus a pre-deposit of 10% of the disputed tax (capped at Rs 20 crore under the CGST Act). For an order that only levies a penalty, the pre-deposit is 10% of the penalty.
- Second appeal: to the GST Appellate Tribunal in APL-05 under Section 112, with a further pre-deposit of 10% of the tax still in dispute. Its Principal Bench sits in New Delhi. Under the notification of 30 June 2026 under Section 112, orders communicated before 1 May 2026 could be appealed until 31 July 2026; orders communicated on or after 1 May 2026 follow the normal three-month limit (GSTAT due date notification). The Tribunal can admit an appeal up to three months late for sufficient cause (Section 112(6)).
Delhi: State or Centre jurisdiction
Every GSTIN in Delhi is assigned either to the Department of Trade and Taxes, Government of NCT of Delhi (Delhi State GST, organised in wards) or to the Central Tax (CGST) Delhi Zone. The assignment appears on the registration certificate and in the taxpayer profile on the portal. A notice can lawfully come from the authority that initiated proceedings on that subject, and Section 6(2)(b) of the CGST Act bars the other authority from starting proceedings on the same subject matter.
See also income tax notice reply and GST registration cancellation and revocation.
Official sources
- CGST Act, Section 73 and Section 74 (CBIC)
- CGST Act, Section 74A (demands for FY 2024-25 onwards: time limits and penalties)
- Notification 17/2024-Central Tax (Section 74A in force from 1 November 2024)
- CGST Act, Section 75 (hearing, adjournments, limits of the order)
- CGST Rules, Rule 99 (ASMT-10 / ASMT-11)
- CGST Rules, Rule 142 (DRC-01, DRC-01A, DRC-03)
- CGST Rules, Rule 88C (DRC-01B)
- CGST Rules, Rule 88D (DRC-01C)
- CGST Rules, Rule 21A (REG-31) and Rule 22 (REG-17 / REG-18)
- CGST Act, Section 107 (APL-01) and Section 112 (Appellate Tribunal)
GST Notice Reply for clients in New Delhi & Delhi NCR
SKAG and Associates is a firm of Chartered Accountants based at Kh.No-84, Plot No -RZ-I-1, F/Floor, 12/2, Main Rd, opposite Yammaha Showroom, Mahavir Enclave, New Delhi – 110045. The firm handles GST Notice Reply work and allied compliance for individuals, professionals, firms and companies across New Delhi, South West Delhi and the wider Delhi NCR region, as well as clients elsewhere in India who engage it remotely.
Engagements are conducted strictly in accordance with the Chartered Accountants Act, 1949 and the ICAI Code of Ethics. To discuss your requirement, you are welcome to contact the office or call +91 88022 54567 during working hours (Mon–Sat, 10:00 AM–7:00 PM).
Frequently asked questions
What is the difference between ASMT-10 and DRC-01? +
ASMT-10 is a scrutiny notice under Section 61 pointing out discrepancies in returns; it is answered in ASMT-11 and can be closed if the explanation is accepted. DRC-01 is the summary of a formal show cause notice under Section 73, 74 or 74A demanding tax, interest and penalty; it is answered in DRC-06 and ends in an order.
I received DRC-01C. What should I do? +
It means ITC claimed in GSTR-3B is more than ITC in GSTR-2B for the period, beyond the limit set. Within 7 days, either pay or reverse the excess through DRC-03 and give the details in Part B, or explain in Part B why the claim is correct (for example, a supplier filed late and the invoice appears in a later GSTR-2B). Until you respond, your next GSTR-1 can be blocked.
Can I get more time to reply to a show cause notice? +
You can ask the officer in writing, with reasons, before the reply date. Whether time is given is the officer’s decision. Separately, at the hearing stage, adjournments can be given for sufficient cause up to three times under Section 75(5).
Is DRC-01A compulsory before a show cause notice? +
No. Rule 142(1A) now says the officer may communicate the proposed liability in DRC-01A before the notice. When one is issued, it is a chance to pay the admitted amount or put your view on record before formal proceedings start.
What penalty applies under Section 74A? +
Where fraud, wilful misstatement or suppression is not alleged, 10% of the tax or Rs 10,000, whichever is higher, and nil if the tax and interest are paid within 60 days of the notice. Where it is alleged, a penalty equal to the tax, reduced to 15%, 25% or 50% depending on when the tax, interest and penalty are paid.
How much do I have to deposit to file a GST appeal? +
For the first appeal in APL-01, the admitted amount in full and 10% of the disputed tax, capped at Rs 20 crore under each of the CGST and SGST Acts. For an appeal against a penalty-only order, 10% of the penalty. A further 10% of the tax in dispute is deposited for an appeal to the Appellate Tribunal.
Questions about GST Notice Reply?
You may contact CA Gaurav Singh to discuss your specific facts and requirements.
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