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GST Services

GST Notices and Litigation Support

Scrutiny queries, show cause notices, demands and first appeals — reconciled, drafted and represented, within the window you have left.

A GST notice is not a verdict. It is the department putting a discrepancy to you and asking you to explain it, and most of the notices we see are answerable — a credit mismatch caused by a supplier's filing, a place-of-supply classification the officer read differently, a return reconciled against the wrong period.

What the notice is called tells you how serious it is and how long you have. ASMT-10 is a scrutiny notice under Section 61 — a discrepancy in a return, with ASMT-11, within 30 days to reply. DRC-01A is an intimation before any formal notice, and often the cheapest moment to close a matter. DRC-01 is the formal show cause notice raising a demand. DRC-07 is the order after adjudication, and the point at which the only route left is appeal.

The limitation framework changed recently, and which one applies depends on the year under demand. For periods up to FY 2023-24, Sections 73 and 74 still govern — 3 years for ordinary cases, 5 years where fraud or wilful misstatement is alleged. From FY 2024-25, Section 74A replaced both with a single 42 months limitation. Read your notice against the right one, because an out-of-time demand is contestable on that ground alone.

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Who needs this

Is this you?

If any of these describe where you are right now, this is the service you are looking for.

  • You have received an ASMT-10 scrutiny notice and the ASMT-11, within 30 days window is running.

  • You have a DRC-01A intimation or a DRC-01 show cause notice raising a demand for tax, interest and penalty.

  • A DRC-07 order has been passed against you and you are considering a first appeal.

  • Your input credit has been questioned because suppliers did not file, and you are being asked to reverse credit you legitimately paid for.

  • Your electronic credit ledger has been blocked, or a provisional attachment has been made on your bank account.

  • Registration cancellation proceedings have started, or your registration has been cancelled and you need revocation.

What’s included

Everything handled, end to end

The full scope of the engagement, so there is nothing to discover halfway through.

  • Notice assessment and position advice

    What the notice actually alleges, how strong it is, what the exposure is, and whether it is worth contesting or closing.

  • Limitation check

    Whether the demand is within time under the framework applicable to that financial year — the first thing worth testing, and often decisive.

  • Reconciliation and evidence assembly

    The underlying returns, ledgers and invoices reconciled so the reply rests on documents rather than assertion.

  • Drafting and filing replies (ASMT-11, within 30 days, DRC-01 responses)

    Replies drafted to the specific allegation, filed within the window, with supporting annexures indexed.

  • Departmental representation

    Personal hearings attended and the matter argued before the adjudicating authority, so you are not explaining your own books under pressure.

  • Voluntary closure where it is cheaper (DRC-03)

    Where the department is right, paying early through DRC-03 to limit interest and penalty is advice too — not every notice should be fought.

  • First appeals (APL-01)

    Grounds of appeal drafted, 10% of the disputed tax pre-deposit computed, and the appeal filed within the 3 months from the order window.

  • Attachment and cancellation matters

    Credit ledger unblocking, provisional attachment representations, and registration revocation applications.

Documents required

What you'll need to hand over

Collected once, at the start. We tell you which of these apply to your case before you gather anything.

Send these first — before anything else

  1. 01The notice or order itself, complete with all annexures
  2. 02The date it was served, and the reply deadline stated on it
  3. 03The financial year and tax periods it covers
  4. 04Any earlier correspondence on the same matter

For the reply

  1. 01All GST returns filed for the periods under dispute
  2. 02Electronic credit and cash ledger extracts for those periods
  3. 03GSTR-2B for the periods where input credit is questioned
  4. 04Purchase invoices and proof of payment for disputed credit
  5. 05Sales invoices, e-way bills and delivery evidence for disputed supplies
  6. 06Audited financial statements and reconciliation for the years concerned

For an appeal

  1. 01The DRC-07 order being appealed
  2. 02The complete reply and annexures filed at adjudication stage
  3. 03Record of the personal hearing, if one was held
  4. 04Proof of pre-deposit payment
  5. 05Board resolution or authorisation for the signatory, for companies and LLPs

Send the notice the day you receive it, even if you cannot gather anything else yet. Reply windows run from service, not from when you got around to reading it, and the single most common reason a good case becomes a bad one is a window that closed while documents were being collected.

How it works

5 steps, start to finish

Where the work actually goes, and what we need from you at each stage.

  1. Read the notice and fix the deadline

    We identify what has been issued, under which section, for which periods, and exactly how many days remain. You get that in writing before anything else happens.

    Confirm with us

  2. Test limitation and merits

    Whether the demand is in time for that financial year, and whether the underlying allegation survives reconciliation. Sometimes the answer is that the department is right.

    With the assessment

  3. Agree the strategy

    Contest, part-concede, or close it voluntarily through DRC-03. We put the options and the likely cost of each to you, and you choose.

    Before drafting

  4. Draft, file and appear

    Reply drafted and filed within the window, with the personal hearing attended and the matter argued.

    Within the reply window

  5. Appeal if the order goes against you

    Grounds drafted and APL-01 filed with the 10% of the disputed tax pre-deposit, inside the 3 months from the order window.

    3 months from the order

Timeline & fees

What to expect, and what it costs

Timelines are indicative and depend on departmental processing and how quickly documents come back to us. Message us on WhatsApp for a written quote.

Enquire on WhatsApp
Reply to ASMT-10 scrutiny notice
ASMT-11, within 30 days
Reply to a show cause notice
As stated on the notice
First appeal against a DRC-07 order
3 months from the order
Demand limitation — periods up to FY 2023-24, ordinary cases
3 years
Demand limitation — periods up to FY 2023-24, fraud alleged
5 years
Demand limitation — FY 2024-25 onwards, unified
42 months

Professional fees

On request

FAQs

Common questions

The questions we are actually asked about GST Notices & Litigation. If yours is not here, ask us directly.

Ask us something else
  • ASMT-10 is a scrutiny notice under Section 61. The officer has compared your returns and found a discrepancy, and wants an explanation. You reply in ASMT-11, within 30 days. It is the least severe stage and the cheapest to resolve — answered properly, it usually ends there.

  • The matter proceeds without your side of it. A scrutiny notice escalates to a show cause notice, a show cause notice becomes an adjudication order assessing tax on the department's figures, and your only remaining route is an appeal that costs a pre-deposit. Ignoring it removes options; it does not remove the demand.

  • It depends on the year. For periods up to FY 2023-24, 3 years for ordinary cases and 5 years where fraud is alleged, under Sections 73 and 74. From FY 2024-25, Section 74A applies a single 42 months limitation. A demand issued outside the applicable period is contestable on that ground alone.

  • Section 74A, inserted by the Finance (No. 2) Act 2024, replaced the separate fraud and non-fraud demand routes with one framework from FY 2024-25. The limitation became a uniform 42 months — longer than the old non-fraud period, shorter than the old fraud one. Penalty still turns on whether fraud is established.

  • In practice, yes, which is unfair but is how it operates — your GSTR-2B only shows what suppliers reported. The answer is evidential: invoices, proof of payment, and evidence the supply happened. Cases like these are winnable, but on documents, not on the argument that it was not your fault.

  • Sometimes, and we will say so. Where the department is right, paying early through DRC-03 limits interest and penalty and closes the matter. Contesting a demand you will lose costs fees, a 10% of the disputed tax pre-deposit and years. The judgement is which situation you are actually in.

  • A pre-deposit of 10% of the disputed tax, paid before the appeal is admitted, plus the appeal must be filed within 3 months from the order. The pre-deposit is not a penalty — it is refundable if you succeed — but it is real cash that must be found at the point of filing.

  • Often, yes. Cancellation for non-filing can usually be revoked once the outstanding returns and dues are cleared, provided you apply within the prescribed window. The urgent part is the window, so treat a cancellation order as time-critical rather than something to resolve eventually.

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