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DRC-01A

Reply to DRC-01A GST Notice — Voluntary Payment, Format & Sample

DRC-01A is a pre-show-cause intimation of tax ascertained under Section 73(5) or 74(5) of the CGST Act, read with Rule 142(1A). Part A is issued by the officer; the taxpayer's reply is furnished in Part B of DRC-01A, and any payment is made through Form GST DRC-03.

What is DRC-01A in GST

Rule 142(1A) empowers the proper officer to communicate details of tax, interest and penalty ascertained by him, in Part A of Form GST DRC-01A, before issuing a show cause notice under Section 73 or 74.

The taxpayer can either pay the tax with interest (and 15% penalty in Section 74 cases) in Form GST DRC-03, or make submissions in Part B of DRC-01A explaining why the ascertainment is not correct.

Options available to the taxpayer

Three broad options exist on receipt of DRC-01A.

  • Agree in full — pay the tax and interest u/s 50 via DRC-03 (no penalty u/s 73; 15% penalty u/s 74)
  • Agree in part — pay to the extent agreed via DRC-03 and file Part B of DRC-01A for the balance
  • Disagree — file Part B of DRC-01A giving reasons on merits and law

How the Part B reply should be structured

The reply in Part B should be paragraph-wise, tied to the officer's ascertainment, and supported by evidence.

  • Head of demand, period and section under which ascertainment is made
  • Point-wise response — legal grounds, factual grounds, computation errors
  • Case law and CBIC circulars relied on
  • Payment particulars in DRC-03, if any part of the demand is agreed

DRC-01A reply format — 7-step drafting checklist

A defensible reply combines procedural safeguards with grounds on merits. Use this checklist as the skeleton of every DRC-01A reply.

  1. 1. Proper officer & jurisdiction
    Verify that the officer issuing the DRC-01A has monetary and territorial jurisdiction under the CBIC circulars. A notice issued without jurisdiction is void.
  2. 2. Statutory time limits
    Check whether the DRC-01A is within limitation under Section 73/74/74A (or the applicable rule). A time-barred notice is liable to be dropped as a threshold ground.
  3. 3. Natural justice
    Confirm that the SCN is not vague, that relied-upon documents are enclosed, and that opportunity of personal hearing under Section 75(4) has been granted.
  4. 4. Statement of facts
    A clean, chronological narrative — parties, GSTIN, period, returns, audit / scrutiny trigger, prior correspondence and payments made.
  5. 5. Grounds on law and merits
    Discrepancy-wise reply — agreed, partly agreed, or disagreed, with the section, rule, circular and case law relied on. Reconciliations attached as annexures.
  6. 6. Correct form & payments
    File the reply in the prescribed form on the GST portal. Any admitted tax is paid through DRC-03 with interest, penalty and late fee shown separately.
  7. 7. Prayer & hearing request
    End the reply with a specific prayer (drop proceedings / grant hearing / accept payment) and expressly request a personal hearing.

Frequently asked questions

Related notices & orders

ASMT-10
How to Reply to ASMT-10 GST Notice — Time Limit, Format & Sample
DRC-01
Show Cause Notice in GST (DRC-01) — Meaning, Time Limits & Reply Format

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