GST Notice Review & Reply
Receiving a GST notice requires careful review of the allegations,
tax period, amount involved, supporting information and response requirements.
We review the notice against your GST returns (GSTR-1, GSTR-3B and
GSTR-2A/2B) and books of account, identify where the department’s figures
or reasoning differ from yours, and prepare a point-by-point reply supported
by documents and relevant case law.
This may include:
- Reviewing the notice and related records
- Identifying the issues raised by the tax authority
- Analysing relevant transaction and tax information
- Preparing or supporting the reply
- Organising supporting documentation
- Supporting submissions to the relevant authority
A structured response helps ensure that the issues raised by the authority
are addressed with appropriate factual and documentary support.
Show Cause Notice Response
A show cause notice under GST may require a business
to explain why a proposed tax, interest or penalty should not be imposed
or confirmed.
We examine each allegation, separate factual mismatches from disputes on
legal interpretation, and prepare the reply (Form GST DRC-06) and written
submissions for the personal hearing. The reply filed at this stage becomes
the record on which any later appeal is decided, so it needs to be complete.
The response strategy depends on the specific facts, applicable provisions
and stage of proceedings.
Applicable provisions:
Notices for periods up to FY 2023-24 are generally issued under Section 73
(cases not involving fraud) or Section 74 (cases alleging fraud, wilful
misstatement or suppression of facts), while Section 74A governs demands
from FY 2024-25 onwards. The applicable section affects time limits,
penalty exposure and the options for closing the matter early.
GST Assessment & Audit Representation
GST assessments and audits may require businesses to provide records,
explanations and supporting documentation relating to transactions and
tax positions.
Support can include:
- Reviewing assessment or audit requirements
- Analysing relevant GST records
- Identifying documentation gaps
- Preparing explanations and submissions
- Supporting communication with tax authorities
- Organising responses to questions or observations
GST Demand, Recovery, Interest & Penalty Matters
GST disputes may involve tax demands, interest, penalties and subsequent
recovery proceedings.
The matter can be reviewed to understand:
- The basis of the demand
- The tax period involved
- The underlying transaction or compliance issue
- Interest and penalty implications
- Available response or appeal options
- Documentation required to support the business's position
The applicable procedure and available options depend on the relevant
proceedings and current law.
Input Tax Credit Disputes
Input Tax Credit (ITC) disputes can affect a business's tax position and
working capital. Support may include reviewing ITC reversal matters,
analysing the underlying records and preparing relevant explanations or submissions.
The review may consider transaction documentation, tax records, reconciliation
information and the specific basis on which the ITC has been questioned.
Common issues include:
- Mismatches between GSTR-3B and GSTR-2B
- Credit denied because a supplier did not file returns or was later found to be non-existent
- Blocked credits under Section 17(5)
- Reversals under Rule 37 (supplier not paid within 180 days)
- Reversals under Rules 42 and 43 (common credits)
GST Appeals & Adjudication Proceedings
When a GST dispute progresses to adjudication or an appeal becomes appropriate,
businesses need a clear understanding of the order, grounds of dispute,
supporting documents and applicable procedural requirements.
We prepare the grounds of appeal, statement of facts and supporting paper book,
and represent you at the hearing.
First appeals lie to the Appellate Authority under Section 107 in Form GST APL-01,
generally within three months of the order, on payment of the admitted amount
and a pre-deposit of 10% of the disputed tax (subject to statutory caps).
Further appeals lie to the GST Appellate Tribunal (GSTAT) under Section 112,
and writ remedies before the High Court are considered where the issue concerns
jurisdiction or natural justice.
Representation before GST authorities is undertaken by our Chartered Accountant team.
GST Summons, Refund & E-Way Bill Disputes
GST-related issues can also arise through summons, refund disputes,
e-way bill issues and detention-related proceedings.
Support may involve reviewing the relevant documentation, understanding
the issue, preparing submissions and determining an appropriate response
within the agreed scope.
