Reply to GST Notice — ASMT-10, DRC-01, REG-17 & Appeals
A GST notice reply has to reach the officer on the GST portal within the time the notice allows, which can be as short as seven working days. We read the notice, reconcile it with your books, draft the reply for your review and see it through to the order or an appeal.
What it is
A GST notice is a written communication from a GST officer asking you to explain a point or pay tax. A GST notice reply is your answer, filed in the prescribed form on the GST portal, with the documents that support it. A good reply can close the matter at the notice stage.
Most notices come under the Central Goods and Services Tax Act, 2017 and the CGST Rules, 2017: Section 61 for scrutiny of returns, Sections 73, 74 and 74A for tax demands, and the registration rules for REG-03 and REG-17. Each notice names the section and the reply date.
Who it applies to
Your returns don’t match (ASMT-10)
Under Section 61, the officer scrutinises your GST returns and sends Form GST ASMT-10 listing the discrepancies, such as GSTR-1 sales not matching GSTR-3B. You explain in Form ASMT-11.
The officer wants tax paid (DRC-01A, DRC-01)
DRC-01A is an intimation of the tax the officer has worked out, sent before a show cause notice. DRC-01 is the summary of the show cause notice itself under Section 73, 74 or 74A. You reply to it in DRC-06.
Your registration is in question (REG-03, REG-17)
REG-03 asks for clarification on a new registration application, answered in REG-04. REG-17 is a show cause notice for cancellation, answered in REG-18.
Why it matters
An unanswered notice becomes an order
If you do not reply, the officer decides on the material he has. Expect the full demand, with interest and penalty.
Early payment cuts the penalty
Paying the part you accept early can reduce or remove the penalty.
The reply shapes your appeal
Facts and documents placed on record at the notice stage carry weight before the Appellate Authority.
Documents required
The notice itself
- The notice with every annexure and working sheet
- The date of service, as shown on the GST portal
From your returns and books
- GSTR-1, GSTR-3B and GSTR-2B for the period
- Annual return GSTR-9 and GSTR-9C, if filed
- Sales and purchase registers, invoices and e-way bills
- Bank statements and ledger accounts
For filing the reply
- GST portal login of the authorised signatory
- Challans in DRC-03 for any amount already paid
Section 73, 74 or 74A: which one applies
| Section 73 | Section 74 | Section 74A | |
|---|---|---|---|
| Period covered | Up to FY 2023-24, no fraud alleged | Up to FY 2023-24, fraud or suppression alleged | FY 2024-25 onwards, both kinds of case |
| Notice deadline | At least 3 months before the order deadline | At least 6 months before the order deadline | Within 42 months from the due date of the annual return |
| Order deadline | 3 years from the due date of the annual return | 5 years from the due date of the annual return | 12 months from the notice, extendable by 6 months |
| Penalty | 10% of tax or ₹10,000, whichever is higher | Equal to the tax | 10% of tax or ₹10,000 without fraud; equal to the tax with fraud |
Section 74A came in through the Finance (No. 2) Act, 2024. Here is the catch: it gives one time limit for every demand from FY 2024-25 onwards, and the fraud question decides only the penalty. For older years, Sections 73 and 74 still apply.
How it works
Read the notice and mark the deadline
We note the section, the period, the amount and the reply date.
Reconcile the numbers
We match the officer’s figures against your returns, books of account and GSTR-2B, and sort each point into accepted, explained or disputed. Take a common ASMT-10: a Faridabad auto-parts supplier claimed more credit in GSTR-3B than its GSTR-2B shows. If the gap is a vendor who filed late, the reply shows when that vendor filed.
Pay what you accept
Any amount you accept is paid through DRC-03 with interest, so the penalty on it is reduced or removed.
Draft the reply for your review
We draft a point-by-point reply with annexures. You review and approve it, and it is filed from your login in the form the notice requires.
Attend the hearing and track the order
We ask for a personal hearing where the officer proposes an adverse order, and we review the order when it comes.
Timelines
Answer REG-03 and REG-17 in seven working days
Replies go in REG-04 and REG-18. In practice, if a REG-03 on a new Faridabad shop’s application asks for the owner’s consent letter, get it signed the same day.
Explain an ASMT-10 within 30 days
Reply in ASMT-11 within 30 days of service, or within a longer period the officer allows.
Reply to DRC-01 by the date given
Reply in Form DRC-06.
Pay a confirmed demand within three months
Under Section 78, tax demanded in an order is payable within three months of service.
Appeal within three months
File Form GST APL-01 within three months of communication, plus one month for sufficient cause.
Reach the Tribunal within three months
Appeal the Appellate Authority’s order to the GST Appellate Tribunal within three months of communication.
Appeals and the GST Appellate Tribunal
If the order goes against you, the first appeal lies to the Appellate Authority under Section 107 in Form GST APL-01, within three months. Before filing, you pay the tax you admit in full, plus 10% of the disputed tax, capped at ₹20 crore under the CGST Act. Where the order demands only a penalty, the pre-deposit is 10% of the penalty.
The second appeal goes to the GST Appellate Tribunal under Section 112, with a further pre-deposit of 10% of the remaining disputed tax, again capped at ₹20 crore. The Tribunal became operational under notification S.O. 4220(E) dated 17 September 2025. Under S.O. 3502(E) dated 30 June 2026, appeals against orders communicated before 1 May 2026 had to be filed by 31 July 2026. For later orders, the normal three months applies.
The Orissa High Court, for one, has been sending writ petitioners to the Tribunal, most recently in September 2026. Any writ petition must be filed and argued by a practising advocate.
What happens if you ignore a notice
The officer decides without you
The officer passes the order on the records he has, for the amount proposed, with interest under Section 50.
Recovery starts after three months
Once the three months under Section 78 run out, the department can start recovering the amount.
Your registration gets cancelled
An unanswered REG-17 ends in a cancellation order in REG-19, and you can no longer charge GST on your invoices.
Frequently asked questions
How many days do you get to reply to a GST notice?
It depends on the notice. REG-03 and REG-17 must be answered within seven working days. An ASMT-10 scrutiny notice allows 30 days from service, or a longer period the officer permits. A DRC-01 show cause notice gives its own reply date. The clock runs from service, so download the notice the day it arrives.
What is the difference between DRC-01A and DRC-01?
DRC-01A is an intimation sent before a show cause notice, telling you the tax the officer has ascertained. You can pay through DRC-03 or object in Part B of the form. DRC-01 is the summary of the show cause notice itself, issued under Section 73, 74 or 74A, and you reply in DRC-06. An objection at the DRC-01A stage can stop the matter before a formal notice is ever issued.
Should you pay the demand before replying?
Pay only what you accept, and pay it early. For FY 2024-25 onwards, Section 74A waives the penalty in non-fraud cases if tax and interest are paid before the notice or within 60 days of it. For older years, Sections 73 and 74 set their own windows, which we check against your notice. Splitting the demand this way keeps both the cost and the dispute small.
What is Section 74A of the CGST Act?
Section 74A is the single demand provision for tax periods from FY 2024-25 onwards. The notice must be issued within 42 months from the due date of the annual return, and the order within 12 months of the notice, which a senior officer can extend by six months. Penalty is 10% of tax or ₹10,000, whichever is higher, without fraud, and equal to the tax with fraud. A notice issued after 42 months can be challenged as time-barred.
What happens if you do not reply to a GST notice?
The officer passes an order on the material available, confirming the amount proposed with interest and penalty. Tax in the order is payable within three months under Section 78, after which recovery can begin. You can still appeal within three months of the order. Replying on time is far cheaper, and even a late reply before the order is better than none.
How do you appeal against a GST order?
You file Form GST APL-01 before the Appellate Authority within three months of the order being communicated, with one more month available for sufficient cause. You must first pay the admitted tax in full and 10% of the disputed tax, capped at ₹20 crore under the CGST Act. It is filed online on the GST portal. A complete record from the notice stage makes this appeal far stronger.
Is the GST Appellate Tribunal functioning now?
Yes. The GST Appellate Tribunal has been constituted and is functioning. Under S.O. 3502(E) dated 30 June 2026, appeals against orders communicated before 1 May 2026 were due by 31 July 2026; later orders follow the normal three months. The pre-deposit is a further 10% of the remaining disputed tax, capped at ₹20 crore. With the Tribunal in place, second appeals no longer have to wait.
Can a chartered accountant reply to a GST notice for you?
Yes. Section 116 of the CGST Act lets a chartered accountant, company secretary or cost accountant in practice appear as your authorised representative before GST officers and the Appellate Authority. We draft the reply for your review, and it is filed from your GST login. Writ petitions before a High Court are different and must be signed by a practising advocate. For notices and first appeals, a CA covers the work.
How do you reply to an ASMT-10 scrutiny notice?
You reply in Form GST ASMT-11 within 30 days of service, or within the longer period the officer allows. ASMT-10 comes from scrutiny of returns under Section 61 and lists the discrepancies found, often between GSTR-1, GSTR-3B and GSTR-2B. For each point, either explain it with documents or accept it and pay the tax with interest through DRC-03. A clear, reconciled reply can end the scrutiny at this stage.
What it costs
Our fee plus the government fee that applies to your case, quoted before you commit. Tell us the situation and we will price it exactly.
Pre-deposits the law requires before an appeal:
| Stage | Pre-deposit |
|---|---|
| First appeal, APL-01 (Section 107) | Admitted tax in full + 10% of disputed tax, capped at ₹20 crore (CGST) |
| Penalty-only order | 10% of the penalty |
| Tribunal (Section 112) | A further 10% of the remaining disputed tax, capped at ₹20 crore (CGST) |
Ready to begin?
Send us the notice and its date of service, and we will tell you what is at stake and have a reply drafted well before the deadline.