GST Notice Reply Drafter (India)

About the GST Notice Reply Drafter (India)

A GST notice has to be answered in its own form, within its own time, on its own page of the portal — and the difference between ASMT-11 and DRC-06, or between seven days and thirty, is the difference between a case that closes and a demand that becomes an order. This drafter names the notice, says what it asks, which form the reply goes in, where on the portal to file it, what happens if nobody answers, and when the reply is due.

It covers the scrutiny notice in ASMT-10 (reply in ASMT-11), the pre-show-cause intimation in DRC-01A (Part B), the show cause notice under s.73, s.74 or s.74A (reply in DRC-06), the two return-mismatch intimations DRC-01B (GSTR-1 against GSTR-3B) and DRC-01C (GSTR-2B against GSTR-3B), the registration query in REG-03 (REG-04) and the show cause before cancellation in REG-17 (REG-18).

Paste the notice and it picks out the form, the reference number, the GSTIN, the financial year and the amounts in this browser. Then choose what you are doing, tick the grounds — each with the section or rule behind it — add a reconciliation row for every figure that differs, quote the DRC-03 for anything paid, and the reply writes itself: a formal submission with the facts, numbered grounds, a reconciliation annexure with totals, the enclosures, the hearing request and the verification, plus the shortened text for the portal’s own box (500 characters for a mismatch Part B, longer for a case reply).

The free preview shows every page with your details and the first part of the wording, and hides the rest; a Premium pass unlocks the full reply, the annexure and the text for the portal to download, copy or print.

Common uses

• Answering an ASMT-10 scrutiny notice within the thirty days with a reconciliation.
• Filing Part B of DRC-01B or DRC-01C so GSTR-1 for the next period is unblocked.
• Replying to a show cause notice in DRC-06 with the grounds, the hearing request and the limitation point.
• Taking the no-penalty route in DRC-01A by paying in DRC-03 and recording the ARN.
• Saving a registration from cancellation with a REG-18 reply after filing the pending returns.

Every notice, its reply form and its clock

• ASMT-10 (s.61 with rule 99) — discrepancies found on scrutiny of the returns. Reply in ASMT-11 within 30 days, or such further period as the officer allows. If the explanation is accepted you are told so in ASMT-12; if not, the officer can move to audit, inspection or a demand under s.73, s.74 or s.74A.
• DRC-01A (rule 142(1A)) — the tax ascertained before a show cause notice. Reply in Part B, and pay in DRC-03 if you accept it. This is the cheapest moment there is.
• DRC-01 (rule 142(1) with s.73, s.74 or s.74A) — the summary of a show cause notice. Reply in DRC-06, with the hearing question answered and the documents attached.
• DRC-01B (rule 88C) — the liability in GSTR-1 exceeds the tax paid in GSTR-3B. Part B within 7 days: the DRC-03 ARN, or the reason, or both.
• DRC-01C (rule 88D) — the credit taken in GSTR-3B exceeds the credit in GSTR-2B. Part B within 7 days, in the same way.
• REG-03 (rule 9(2)) — a query on a registration application. Clarify in REG-04 within 7 working days, or the application is rejected in REG-05.
• REG-17 (s.29 with rule 22) — show cause before cancelling the registration. Reply in REG-18 within 7 working days; if the notice is for returns not filed, filing them all with tax, interest and late fee lets the officer drop the proceedings in REG-20.

Which provision your demand falls under, and the time limits

For periods up to FY 2023-24 a demand is made under s.73 where there is no fraud, and s.74 where fraud, wilful misstatement or suppression is alleged. Both run from the due date of the annual return — 31 December after the financial year under rule 80(1):

• s.73: order within 3 years, notice at least 3 months before it.
• s.74: order within 5 years, notice at least 6 months before it.

From FY 2024-25 both cases are merged into s.74A: the notice within 42 months of the annual return due date, and the order within 12 months of the notice, which the Commissioner may extend by up to 6 months. Section 74A also says no notice is to be issued where the tax is less than ₹1,000.

The drafter prints these dates for your year and warns you when the notice itself looks late — limitation is one of the strongest grounds there is, and one of the easiest to miss.

The cheapest moment to pay

The Act rewards paying early, and the amounts are fixed by statute:

• s.73: tax and interest paid before the notice — no penalty, and no notice at all for that amount. Paid within 30 days of the notice — still no penalty, and the proceedings are deemed concluded. After the order: 10% of the tax or ₹10,000, whichever is higher.
• One exception to the no-penalty route: where the amount is self-assessed tax, or tax collected as tax, that was not paid within thirty days of its own due date, the 10% penalty applies however early you pay (s.73(11), s.74A(11)).
• s.74: 15% of the tax as penalty if paid before the notice, 25% within 30 days of the notice, 50% within 30 days of the order; otherwise the penalty equals the tax.
• s.74A: the window is 60 days instead of 30. Without fraud, tax and interest within 60 days of the notice means no penalty; with fraud, 15% before the notice, 25% within 60 days of the notice and 50% within 60 days of the order. The penalty otherwise is 10% or ₹10,000 without fraud, and 100% of the tax with it.

Interest under s.50 runs in every case. Payment is made in DRC-03, and its ARN goes into the reply — for DRC-01B and DRC-01C the portal checks that the ARN is for the same GSTIN, filed on or after the intimation, for the right period and under the matching cause of payment.

What a GST reply must contain

• The reference number and the right form. A reply filed in the wrong form, or outside the case, can simply not be seen by the officer.
• A reconciliation, not an argument. Most notices are machine-made comparisons: GSTR-1 against GSTR-3B, GSTR-2B against GSTR-3B, GSTR-9 against the books. A table that shows each figure, its source and the reason for the gap answers the notice on its own terms.
• The documents. Invoices, e-way bills, credit notes, shipping bills, the letter of undertaking, the ledger extracts. The reply screen on the portal states how many attachments it takes and how large each may be.
• A request for a personal hearing. It must be granted when asked for in writing, or before any adverse decision (s.75(4)). DRC-06 asks the question directly.
• Two limits on the officer. The order cannot go beyond the grounds or the amount of the notice (s.75(7)), and the demand must be within time.
• The appeal, if it comes to that. An appeal against the order lies to the Appellate Authority within three months of its communication, with 10% of the disputed tax paid up front (capped at ₹20 crore of central tax), in APL-01.

A word about what this tool is not

It is a drafting tool. It does not log in to the GST portal, file anything, or look at your returns — you file the reply yourself and attach the draft. The grounds are standard ones with the section or rule behind them, written to be read and edited, not signed blind. A show cause notice alleging fraud, a large demand, an audit or an anti-profiteering case needs a chartered accountant or an advocate who can see the whole file. Use this to be ready for them, and to stop the clock running out while you look.

Limitations

• A drafting tool, not tax advice, and no substitute for a chartered accountant or advocate in a fraud, audit or large-demand case.
• It does not file anything on the GST portal and cannot read your returns or ledgers; you attach the draft and file it yourself.
• Working-day deadlines (REG-04 and REG-18) are counted without any State holiday, so treat the date shown as the earliest it can be.
• Time limits are worked out from the standard annual-return due date of 31 December; a year with an extended due date, or a notification extending a limit, changes them.
• The grounds library is a starting point with the provision behind each ground: read and rewrite every paragraph to your facts.
• Rates, forms and limits change with every amendment and notification; check the current position for your year before you file.
• Text in the Indian scripts (Devanagari, Bengali, Gujarati, Tamil, Telugu and the others) comes out right in the preview, the DOCX, the PDF and Print. A script the PDF engine cannot draw, such as Urdu, shows in the DOCX and Print but not in the PDF or the free preview’s pages.

Privacy

Everything happens in your browser. The notice you paste, your GSTIN, the amounts and the documents list are not uploaded or stored by MySmartCoPilot, and the pasted notice is never part of the reply. Keep a draft in this browser is off unless you switch it on.