A GST notice is a clock, not a verdict. Almost every notice carries a fixed number of days to reply, and the cost of missing that window is far higher than the tax originally in dispute — an ex-parte order under Section 73 or 74 becomes a recovery proceeding, and the appeal that follows needs a 10% pre-deposit before it will even be heard.
Which notice have you received?
The first thing to establish is the section the notice is issued under, because that decides both your deadline and your options. These are the notices we see most often at our MP Nagar office.
| Form | Section | What it means | Time to respond |
|---|---|---|---|
| ASMT-10 | 61 | Scrutiny of returns — the officer has found a discrepancy, commonly GSTR-3B against GSTR-2B or GSTR-1 | Usually 30 days |
| DRC-01A | 73(5) / 74(5) | Intimation before a formal show cause notice — a chance to pay or explain first | As stated, commonly 15 days |
| DRC-01 | 73 / 74 / 74A | Formal show cause notice demanding tax, interest and penalty | 30 days |
| ADT-01 | 65 | Departmental audit — records to be produced for a full financial year | 15 days notice before audit begins |
| REG-17 | 29 | Show cause for cancellation of registration | 7 working days |
| MOV-01 to MOV-11 | 129 / 130 | Goods or vehicle detained in transit — e-way bill or documentation defect | Immediate; 7 days for penalty order |
What changed for FY 2024-25 onwards
The Finance Act 2024 introduced Section 74A, which merges the Section 73 and Section 74 procedures for tax periods from FY 2024-25 onward into a single limitation framework. Older periods continue to run under the existing Sections 73 and 74. A reply drafted under the wrong provision invites avoidable trouble, so the tax period on the notice matters as much as the allegation.
How we handle a notice
We do not send a holding reply asking for time. A weak first reply becomes part of the record and is quoted back at you in appeal.
- Read the notice against the return. We reconcile the department's figures with your GSTR-1, GSTR-3B, GSTR-2B and books to find out whether a demand exists at all. A significant share of scrutiny notices arise from timing differences and supplier filing delays rather than any real short payment.
- Confirm the limitation date. We check whether the notice itself is within time. A notice issued beyond the statutory period is challengeable on that ground alone.
- Assemble the evidence. Invoices, e-way bills, transport documents, ledgers, bank statements and supplier confirmations — attached to the reply, not merely referred to.
- Draft and file. The reply is filed on the GST portal with a documented paper trail, within the window.
- Appear at the personal hearing. Attendance matters. Orders passed ex-parte are markedly harder to reverse.
If an order has already been passed
An adverse order is not the end of the matter. A first appeal is filed in Form APL-01 before the Appellate Authority within three months of communication of the order, extendable by one further month if sufficient cause is shown. The appeal requires a pre-deposit of 10% of the disputed tax.
If you are outside that window, options still exist depending on the facts — rectification under Section 161 for an error apparent on the face of the record, restoration where the order was passed without a hearing, or a writ petition before the High Court in a narrow set of circumstances. Bring us the order and we will tell you honestly which of these applies.
Working with a Bhopal firm on a GST matter
GST proceedings are conducted through the portal, but personal hearings before the State and Central authorities in Bhopal are still attended in person. Being able to hand over the file, sit across a table for it, and have someone appear at the hearing on your behalf makes a practical difference to how a matter progresses.