How to Reply to a DRC-01 or DRC-07 Notice under Section 73 of the GST Act

GST Notices, Orders & Remedies · Updated 22 October 2026

How to Reply to DRC-01 under Section 73 and What to Do After a DRC-07 Order

A practical guide to GST show-cause notice replies (DRC-06), supporting documents, Section 73 and Section 74A, and remedies after an adjudication order.

DRC-01 noticeDRC-06 replyDRC-07 order

If you have received FORM GST DRC-01, review the underlying show-cause notice and prepare a point-by-point response, generally submitted in FORM GST DRC-06. If you have received FORM GST DRC-07, you are generally at the order stage: consider the adjudication order, appeal rights, any permissible rectification and payment or recovery implications. These are different remedies and should not be confused.

Important distinction: DRC-01 is a summary of a show-cause notice, DRC-06 is the taxpayer’s reply to the notice, and DRC-07 is a summary of the adjudication order. A DRC-07 is not ordinarily answered by filing another DRC-06.

DRC-01 vs DRC-06 vs DRC-07: What Does Each GST Form Mean?

FormWhat it isPractical action
DRC-01Electronic summary accompanying a show-cause notice (SCN)Read the full SCN and annexures; prepare evidence and reply within the specified opportunity.
DRC-06Taxpayer’s reply to SCN under Rule 142(4)Submit submissions and supporting records using the applicable portal process.
DRC-07Electronic summary of adjudication orderRead the full order, identify the date communicated, assess appeal/rectification and demand consequences.

A tax demand can concern return mismatches, disputed input tax credit (ITC), valuation, classification, alleged short payment or an erroneous refund. The contents of the actual notice and order—not the form number alone—determine the appropriate response.

When Does Section 73 Apply in 2026?

Section 73 of the CGST Act, 2017 concerns specified non-fraud tax demands for periods up to financial year 2023–24. Section 74 addresses certain fraud, wilful misstatement or suppression matters for those earlier periods. For FY 2024–25 onward, demand proceedings generally fall under the newer Section 74A, with its own framework. A notice received in 2026 may still relate to an earlier financial year: the date received alone does not decide the governing section.

Before drafting, check the financial year, statutory provision, issuing authority, underlying allegations, tax computation, notice service and applicable limitation. A state GST notice may invoke corresponding provisions of the relevant SGST law as well.

Do not assume a generic deadline: The response date for the SCN must be verified from the documents and portal. The separate statutory timelines for passing orders, appealing an order and seeking rectification have different starting points and conditions.

How to Reply to a DRC-01 Show-Cause Notice: Step-by-Step

  1. Download the complete notice

    Log in to gst.gov.in. Look under Services → User Services → View Additional Notices/Orders or the applicable notices/orders module. Download the SCN, DRC-01 summary, annexures, correspondence and demand workings. The portal labels may change.

  2. Identify the exact allegations

    Separate each proposed tax, interest and penalty item. Note the tax period, applicable statutory section, facts relied upon and how the officer arrived at the figures. Check whether material documents or calculation sheets are missing.

  3. Reconcile your records

    Compare GSTR-1, GSTR-3B, relevant GSTR-2A/2B data, electronic ledgers, invoices and books of account. Account for timing differences, amendments, credit notes, reversals and payments supported by records. Do not treat a mismatch as conclusive proof of liability without examining the legal conditions.

  4. Prepare a paragraph-wise legal and factual reply

    State admitted and disputed facts separately. Address each allegation with a clear reconciliation, document reference and relevant statutory basis. Raise jurisdiction, service, limitation and natural-justice questions where genuinely applicable.

  5. Submit using the applicable DRC-06 workflow

    Upload the response and annexures within the portal’s permitted file types and size limits. Verify the preview before using the permitted electronic verification method. Save the submission confirmation, reference number and filed attachments.

  6. Request and prepare for a hearing where appropriate

    If a hearing is desired, request it expressly. Section 75(4) requires an opportunity of hearing in specified circumstances, including where requested in writing or where an adverse decision is contemplated. Keep hearing notices, written submissions and acknowledgements together.

  7. Monitor subsequent proceedings

    Check additional queries, hearing communications and the resulting adjudication order. Review the speaking order against the submissions made; receiving a DRC-07 summary is not a substitute for reading the full order.

Need to understand your GST notice?

For the applicable procedure and available remedies, share the notice details through the published contact channel. Avoid sending sensitive records until an appropriate secure channel is agreed.

Contact GSTLawyer.in

Documents to Keep Ready for a DRC-01 Reply

  • SCN, DRC-01, annexures and proof of communication
  • GST registration details and relevant return acknowledgements
  • GSTR-1, GSTR-3B and relevant GSTR-2A/2B extracts
  • Sales/purchase registers, ledgers and reconciliations
  • Tax invoices, debit/credit notes and payment records
  • ITC eligibility documents and reversal/re-availment workings where relevant
  • E-way bills, delivery records or contracts where they concern the allegations
  • Electronic cash/credit/liability ledger extracts and DRC-03 proof where relevant
  • Earlier notices, responses, hearings and correspondence
  • Authorisation and identification of the person filing the response

Practical tip: Number each annexure and cite it in the written reply—for example, “Annexure 3: invoice-wise reconciliation for April–June 2022.” Submit only relevant, authentic documents.

Suggested Structure of a GST DRC-01 Reply

To: The Proper Officer [jurisdiction]

Subject: Response to SCN dated [date], reference [number], concerning FY [year]

GSTIN / taxpayer: [GSTIN and legal name]

1. Background: Identify the show-cause notice, legal provision, periods and disputed allegations.

2. Preliminary issues (if any): Briefly explain genuine concerns over jurisdiction, service, limitation or omitted relied-upon material.

3. Issue-wise response: Reproduce each allegation in short form, state the relevant facts, provide reconciliation and cite exhibits and applicable provisions.

4. Tax / interest / penalty computation: Explain discrepancies and distinguish any admitted liability from disputed items.

5. Request: Seek consideration of submissions, access to relied-upon records where necessary, opportunity of hearing and a reasoned decision.

Annexures: Indexed supporting documents.

Authorised signatory: [Name, capacity and date]

This is an explanatory outline, not a universal filing template. A response should be tailored to the actual allegations and prevailing procedural requirements.

Received DRC-07? Review the Order, Not Another Notice Reply

DRC-07 records the summary of the adjudication order. It may reflect a demand for tax, interest, penalty or other amounts. Download the full order; check whether the authority considered the evidence and submissions, the amount confirmed, the order’s communication date and available remedies.

First appeal — Section 107

An aggrieved taxpayer ordinarily has three months from communication of the appealable order to file a first appeal, subject to statutory exceptions and a limited condonation provision. Relevant admitted dues and prescribed pre-deposit conditions require case-specific assessment. Do not assume filing a reply to DRC-07 preserves the appeal limitation period.

Read about GST appeals in Patna →

Rectification — Section 161

An error apparent on the face of the record may qualify for rectification under Section 161, subject to its statutory time limits and conditions. Rectification is not a general substitute for an appeal or an opportunity to reargue every factual issue.

Read Section 161 →

If payment or recovery action is threatened, independently review the statutory recovery provisions, applicable appeal-stay effect and any actual recovery communications. Do not ignore a confirmed demand.

Common Mistakes to Avoid

  • Calling DRC-07 a new show-cause notice and attempting to file a routine DRC-06 in response.
  • Responding to the DRC-01 summary without reading the underlying SCN and annexures.
  • Using Section 73 automatically for FY 2024–25 onward instead of checking Section 74A.
  • Relying on blanket statements about 15- or 30-day notice-reply periods.
  • Uploading an unindexed bundle of invoices without issue-wise explanations.
  • Assuming every ITC mismatch proves wrongful credit, or that every mismatch is harmless.
  • Confusing payment of disputed tax with the right to contest the proposed demand.
  • Missing a personal hearing, appeal limitation date or prescribed portal acknowledgement.

Frequently Asked Questions

What is the difference between DRC-01 and DRC-07?

DRC-01 is a summary accompanying a show-cause notice; DRC-07 is a summary of the order after adjudication. Different statutory remedies apply at each stage.

Which form is used to reply to a GST show-cause notice?

FORM GST DRC-06 is the prescribed taxpayer response to a show-cause notice under Rule 142(4), subject to the applicable portal workflow.

Can I respond to a DRC-07 by filing DRC-06?

Ordinarily no. DRC-07 is an order summary. Consider a statutory appeal, qualifying rectification, compliance or other available remedies based on the actual order.

How many days are allowed for a DRC-01 response?

Check the response date in the actual notice and any valid extension or further directions. There is no safe universal 15- or 30-day answer for every SCN.

Does Section 73 apply to GST notices for FY 2024–25?

Generally, Section 74A is the governing demand framework for FY 2024–25 onward. Section 73 applies to earlier periods within its statutory scope; verify the notice’s period and legal basis.

What if the GST demand is based on a GSTR-2B mismatch?

Analyse the actual period, invoices, supplier compliance, statutory ITC conditions, reconciliations and applicable circulars or case law. A complete answer requires more than a screenshot of the mismatch.

Can I ask for a personal hearing?

Yes. Make an express request when appropriate. Section 75(4) contains a hearing requirement in specified circumstances.

Can I appeal a DRC-07 demand order?

An appealable adjudication order can generally be challenged under Section 107, subject to limitation, maintainability and required payments. Review the full order and the date it was communicated.

Is rectification the same as an appeal?

No. Section 161 addresses qualifying apparent errors and has specific timing and scope restrictions; it does not replace an appeal on disputed merits.

Should I pay before submitting a reply?

Payment consequences depend on the statutory section, timing, admitted and disputed amounts, and facts. Check the legal effect before making payment or attempting to close proceedings.

Primary Legal Sources and Further Reading

Information on GST Notices, Orders and Appeals in Bihar

GSTLawyer.in publishes procedural guidance on GST notices and remedies. For case-specific review, consult a qualified professional with the actual notice, order and relevant records.

Advocate Tabish Ahmad · Patna, Bihar
+91 9308985626

View Contact Details →

Editorial note: This article provides general legal information, not an opinion on any particular case. Applicable law, notifications, limitation, portal functionality and evidence should be verified for the relevant financial year and proceedings. Substantive changes should be approved by the reviewing advocate before publication.

How to Reply to a DRC-01 or DRC-07 Notice under Section 73 of the GST Act

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