GST Notice Reply Format — ASMT-11, DRC-06, REG-18 Templates & Sample

The universal 7-part reply structure

A GST notice reply reads like a mini brief — the officer should be able to test each ground against the record without looking anywhere else. The following seven parts appear in almost every well-drafted reply:

• 1. Cover paragraph — reference to the notice (form, DIN, date, period, section)
• 2. Preliminary submissions — jurisdiction, limitation, natural justice
• 3. Statement of facts — chronological, factual, unargumentative
• 4. Discrepancy-wise / paragraph-wise reply — one heading per issue
• 5. Grounds on law and merits — sections, rules, circulars, case law
• 6. Payment particulars — DRC-03 details (tax, interest, penalty, late fee separately)
• 7. Prayer, request for personal hearing, and verification block

Preliminary submissions — three threshold grounds

Before responding on merits, raise the threshold grounds. These operate independently of the amount involved and, if accepted, dispose of the notice:

• Proper officer / jurisdiction — CBIC monetary limit circulars govern who can issue the SCN.
• Limitation — Sec 73(2), 74(2), 74A(2) time-bar for the SCN itself.
• Natural justice — SCN not vague, RUDs enclosed, personal hearing u/s 75(4).

Discrepancy-wise reply — the drafting workhorse

Reproduce the officer's paragraph and respond immediately below it. For each paragraph, state whether the demand is agreed, partly agreed, or disagreed, and give reasons. Attach the underlying reconciliation as an annexure (GSTR-1 vs 3B, GSTR-2A/2B vs 3B, GSTR-9/9C, e-way bills).

Payment particulars

Where any part of the demand is agreed, pay through DRC-03. Show tax, interest under Section 50, penalty, and late fee in separate lines. Attach the DRC-03 challan and the taxpayer's own reconciliation of admitted vs disputed amounts.

Prayer and verification

End with a specific prayer — drop proceedings, accept the payment made, and grant a personal hearing. Verification should be signed by the authorised signatory (Section 116 authorization for a representative).

Frequently asked questions