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DRC-07

DRC-07 GST Order — How to Appeal via APL-01, Time Limits & Sample

DRC-07 is the summary of the order issued by the adjudicating authority under Section 73, 74 or 74A of the CGST Act, read with Rule 142(5). It creates a demand in Part II of the electronic liability register. The three options against DRC-07 are payment via DRC-03, rectification u/s 161, or appeal in APL-01.

Options after receipt of DRC-07

Three broad options exist against a demand created by DRC-07.

  • Pay the demand in Form GST DRC-03 (Cause: liquidation of the DRC-07 demand)
  • File a rectification application u/s 161 for errors apparent on the face of the record
  • File an appeal before the Appellate Authority in Form GST APL-01 within 3 months (extendable by 1 month), after pre-deposit of 10% of the disputed tax

Limitation for filing appeal

Under Section 107, an appeal to the Appellate Authority is to be filed within 3 months from the date of communication of the order, extendable by 1 more month on sufficient cause. Section 112 governs appeals to the Tribunal.

Rectification u/s 161

Where the order suffers from an error apparent on the face of the record (arithmetical mistake, omission, patent illegality), a rectification application can be filed within 3 months from the date of the order. Section 161 is not a substitute for appeal on merits.

DRC-07 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-07 reply.

  1. 1. Proper officer & jurisdiction
    Verify that the officer issuing the DRC-07 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-07 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

DRC-01
Show Cause Notice in GST (DRC-01) — Meaning, Time Limits & Reply Format
APL-01
Appeal to Appellate Authority (APL-01) — Time Limit, Fee & Draft
APL-04
Appeal to GST Tribunal (APL-05 vs APL-04) — Time Limit & Draft

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