A GST notice is not a verdict. It is a question, and it carries a deadline. How that question is answered in the first reply usually decides whether the matter closes at the department’s desk or turns into a demand order, an appeal and a locked-up pre-deposit.
We read the notice, test it against the law and your records, and prepare a reply that deals with every allegation, supported by reconciliations and documents. Where an order has already been passed, we represent you in appeal.
Notices we regularly handle
Scrutiny of returns: ASMT-10
Discrepancies noticed in returns under Sec. 61, such as turnover or credit differences between returns and other data.
Show cause notice: DRC-01
Demand of tax, interest and penalty under Sec. 73 or Sec. 74, and under Sec. 74A for FY 2024-25 onwards.
Liability mismatch: DRC-01B
Tax as per GSTR-1 higher than tax paid in GSTR-3B, under Rule 88C.
Excess credit: DRC-01C
Input tax credit in GSTR-3B higher than the credit available in GSTR-2B, under Rule 88D.
Registration matters
Queries on a new application, show cause notice for cancellation in REG-17, and revocation of a cancelled registration.
Non-filing of returns: GSTR-3A
Notice to return defaulters, which can lead to best judgment assessment if it is left unanswered.
Departmental audit: ADT-01
Audit of books under Sec. 65, audit observations and the final audit report.
Recovery and attachment
Recovery proceedings and provisional attachment of bank accounts under Sec. 83.
Common reasons behind GST demands
- Credit denied because the supplier did not file returns, did not pay tax or had its registration cancelled with retrospective effect
- Differences between GSTR-3B and GSTR-2A or GSTR-2B for earlier years
- Turnover in GST returns not agreeing with the income tax return, Form 26AS or e-way bill data
- Reverse charge not paid on notified services
- Classification and rate disputes
- Credit availed after the permitted time limit, or on blocked items
- Orders passed without a hearing because notices on the portal were never seen
How we handle a notice
- Review.
We check what is alleged, the period involved, the reply date, and whether the notice is within limitation and properly issued. - Reconcile.
The department’s figures are rebuilt from your returns, books and portal data to find the real difference, which is often much smaller than the amount demanded. - Reply.
A paragraph-wise reply is drafted with legal grounds, working sheets and supporting documents, and filed on the portal within time. - Represent.
We appear as your authorised representative at the personal hearing and file additional submissions where needed. - Appeal.
If the order is adverse, we advise on the merits and cost of an appeal and prepare and argue it before the appellate authority.
Appeals: time limits you must not miss
A first appeal against an adjudication order lies under Sec. 107 and has to be filed within three months from the date the order is communicated, with a pre-deposit of 10% of the disputed tax. A further appeal lies before the GST Appellate Tribunal under Sec. 112, with an additional pre-deposit of 10% of the disputed tax. Once these periods are over, the demand becomes recoverable, so an order should be acted upon as soon as it is received.
We appear before the adjudicating and appellate authorities under GST as authorised representatives. Where a matter needs to be taken before a High Court, we prepare the factual record and work alongside your legal counsel.
What to share with us
- The notice or order, with all annexures and the reference number
- Returns filed for the period: GSTR-1, GSTR-3B and GSTR-9
- GSTR-2A or GSTR-2B and the purchase register
- Earlier replies and correspondence, if any
- Portal access to view notices, orders and ledgers
Frequently asked questions
What happens if I do not reply to a GST notice?
The officer can decide the matter on the material available, which normally means the full demand is confirmed with interest and penalty. Recovery from the bank account or from debtors can follow. A reply filed in time keeps every defence open.
The reply date is very close. Can more time be taken?
In most proceedings a written request for adjournment can be made before the due date. It should be filed on the portal with reasons, and not assumed to be granted.
The order was passed without my knowledge. Is there a remedy?
Yes, in many cases. Depending on the date of the order, the options are an appeal with an application to condone the delay, or a rectification application where the error is apparent from the record. The dates decide which remedy is still open.
My bank account has been attached. What can be done?
Objections can be filed against a provisional attachment asking for release of the account, along with a reply on the underlying dispute. We prepare both, since release usually depends on how the main allegation is answered.