GST Notice Reply in 2026: Every Common Notice, Reply Deadlines, Time Limits and Appeals

A GST notice is rarely a disaster, but an ignored one usually becomes one. Most notices small businesses get today are system-generated: a mismatch between GSTR-1 and GSTR-3B, credit claimed beyond GSTR-2B, a return not filed. A clear reply on time, with the numbers reconciled, closes most of them. This guide is for owners and accountants who've just found something under Notices and Orders on the GST portal. It explains each common notice, how long you have to reply, the section 73, 74 and 74A time limits, how to cut or avoid penalties, how to appeal, and a worked ₹ example. Checked against the CGST Act, CGST Rules and the GST Council's October 2026 recommendations in October 2026.

Quick answer

To reply to a GST notice, identify the form and section, reconcile the figures it questions, then either pay what's genuinely due (through DRC-03, with interest) or file a reasoned reply with documents in the form the notice names — ASMT-11 for a scrutiny notice, DRC-06 for a show cause notice, REG-18 for a cancellation notice — before the deadline. Ask for a personal hearing if anything is in dispute.

• ASMT-10 scrutiny: reply within 30 days (or longer if the officer allows); REG-17: 7 working days; DRC-01B/01C: seven days

• FY 2024-25 onwards (section 74A): notice within 42 months from the due date of the annual return, order within 12 months from the date of the notice (extendable by up to six months)

• Non-fraud: pay tax + interest under section 74A within 60 days of the notice and no penalty applies

• Appeal in APL-01 within three months from communication of the order, with a 10% pre-deposit

Where GST notices come from

Every notice is issued on the GST portal, and the important ones are emailed and sent by SMS to your registered contacts. Look under Services → User Services → View Notices and Orders, and for newer modules under Additional Notices and Orders. A notice that is uploaded on the portal is validly served even if you never opened the email, so check the portal at least once a week.

Central or state officer? Every GSTIN is assigned to either the central or the state tax administration, and a notice can come from either. Only one of them should take up the same issue for the same period, so if you receive notices from both on the same subject, point that out in your reply.

Notices come in three broad families:

1. Return-compliance notices — automatic, triggered by non-filing or by mismatches between your returns. GSTR-3A, DRC-01B and DRC-01C fall here.
2. Registration notices — REG-03 during a new application, REG-17 and REG-31 when the officer or system wants to cancel or suspend your GSTIN.
3. Assessment and demand notices — ASMT-10 after scrutiny, ADT-01 for an audit, DRC-01A as a pre-notice intimation, and DRC-01, the formal show cause notice for a tax demand.

Common GST notices and how long you have to reply

Before anything else, note the section the notice cites, the tax period, and the reply date. A notice that names the wrong section (for example, section 74 fraud wording with no allegation of fraud) or bundles several financial years together may be challengeable on those grounds alone — but you still reply on merits by the deadline.

The time limits: sections 73, 74 and 74A

Demands for unpaid tax, short-paid tax, wrong refunds and wrongly availed ITC are made under one of three sections, depending on the year:

• Section 73 (FY 2023-24 and earlier, no fraud): the order must be issued within three years from the due date of the annual return, and the notice at least three months before that.
• Section 74 (FY 2023-24 and earlier, fraud, wilful misstatement or suppression): the order within five years from the due date of the annual return, the notice at least six months before.
• Section 74A (FY 2024-25 onwards, inserted by the Finance (No. 2) Act 2024): one section for both kinds of case. The notice must be issued within 42 months from the due date of the annual return, and the order within 12 months from the date of the notice (extendable by up to six months). No notice can be issued if the tax involved for the year is below ₹1,000.

Here is how that plays out, assuming the annual return was due on 31 December after the financial year in each case:

Two practical points follow. First, for FY 2022-23 the section 73 window for notices has already closed, so a fresh non-fraud notice for that year issued now is out of time; only a fraud-based section 74 notice can still come. Second, under section 74A the clock for the order starts from the notice, so a notice issued in early 2028 must be decided by early 2029 (or mid-2029 with an extension). If an order arrives after its time limit, that's a strong ground of appeal.

If you got a notice for a year where the annual-return date was extended, or the government extended section 73 dates by notification (it did for FY 2017-18 to 2019-20), work the dates out from those notifications.

Penalties, and how paying early reduces them

Interest runs throughout at 18% a year under section 50. For ITC that was wrongly availed and used, it's 18% a year; credit that sat unused in your ledger attracts no interest. One exception to the "pay early, no penalty" rule: if the amount is self-assessed tax you collected and didn't pay within 30 days of its due date, the non-fraud penalty still applies even if you pay before the notice.

When you pay voluntarily, use DRC-03 and choose the right reason (voluntary, against intimation, or against show cause notice). If you've already paid through DRC-03 and the officer then raises a demand order for the same amount, link the payment to the demand with DRC-03A so the order isn't enforced again.

How to reply to a GST notice, step by step

Replying to a GST notice

1. 1

   Download and read the notice

   Download the notice and any annexure from Notices and Orders. Note the form, the section, the tax period, the amount and the reply date.

   Tip: Check the notice carries the officer's name, designation and jurisdiction.

2. 2

   Rebuild the officer's numbers

   Pull GSTR-1, GSTR-3B, GSTR-2B/2A and GSTR-9 for the period, plus your books. Work out exactly where the difference in the notice comes from.

3. 3

   Split agreed and disputed amounts

   Typical explanations: timing (ITC claimed in a later month), cancelled invoices still in GSTR-1, credit notes, reverse charge paid but shown in the wrong table, typing errors in one return.

4. 4

   Pay what's genuinely due

   Pay the agreed tax and interest through DRC-03 before replying, and quote the ARN. In non-fraud cases this removes penalty on that part.

5. 5

   File a reasoned reply

   Use the form the notice names (ASMT-11, DRC-01A Part B, DRC-06, REG-18). Give a reconciliation table and attach invoices, ledger extracts and GSTR-2B pages. Keep to the facts and cite the relevant section or circular.

6. 6

   Ask for a personal hearing

   Tick the option or request it in writing. Under section 75(4) a hearing must be granted on request or before any adverse decision.

7. 7

   Track the outcome

   ASMT-12 closes a scrutiny; DRC-05 closes proceedings after payment; DRC-07 is the order. Diary the appeal deadline from the date the order is communicated.

What a good reply looks like. One page of summary up front, then a table that starts from the officer's figure and walks to yours line by line, then annexures numbered to match. Officers handle hundreds of these; the reply that lets them tick a box gets closed.

Hearings and adjournments. You can ask for time if you have a genuine reason, but section 75(5) allows a maximum of three adjournments. The order can't demand more than the notice proposed, or on grounds the notice didn't raise (section 75(7)).

Worked example: an ASMT-10 for a Pune trader

Kulkarni Hardware in Pune gets an ASMT-10 for FY 2024-25 on 16 October 2026. It lists two discrepancies:

1. ITC in GSTR-3B exceeds ITC in GSTR-2B for the year by ₹1,20,000.
2. Tax in GSTR-1 exceeds tax paid in GSTR-3B by ₹40,000.

The accountant reconciles each:

• ₹90,000 of the ITC gap is invoices dated March 2025 that suppliers uploaded in April. They appear in Kulkarni's April 2025 GSTR-2B, and the March GSTR-3B claimed none of them — the claim was made in April. The officer's annual comparison is mixing two years. Explanation, with the April 2025 GSTR-2B pages attached.
• ₹30,000 of the ITC gap is GST on a car bought for the owner's use, claimed in October 2024 by mistake. It's blocked under section 17(5) and was used to pay tax. Pay it.
• The ₹40,000 output-tax gap is an invoice cancelled in December 2024 after its e-invoice was generated; it stayed in GSTR-1, but the customer never took delivery and its IRN was cancelled. Explanation, with the cancelled IRN and the credit note issued in GSTR-1 for January 2025.

Payment. Interest at 18% a year on ₹30,000 from 21 October 2024 (the day after the October return was due) to 15 November 2026 — 755 days — is ₹30,000 × 18% × 755 ÷ 365 ≈ ₹11,170. Kulkarni pays ₹30,000 + ₹11,170 through DRC-03 and files ASMT-11 on 10 November with the explanations and the DRC-03 ARN, inside the 30 days (or longer if the officer allows) window.

Outcome. If the officer accepts, he issues ASMT-12 and the matter closes. If he doesn't accept the explanations, the case moves to a show cause notice under section 74A (FY 2024-25), which must be issued by 30 June 2029. Because the ₹30,000 was already paid with interest before any notice, no notice or penalty can follow on that amount. On anything still disputed, paying tax and interest within 60 days of the notice avoids penalty; if it goes to an order instead, the non-fraud penalty is 10% of the tax or ₹10,000, whichever is higher — on a ₹40,000 demand, ₹10,000, since 10% would be only ₹4,000.

Registration notices: REG-17 and REG-31

A REG-31 means your registration has been suspended under Rule 21A(2A), usually because the system found a big gap between GSTR-1, GSTR-3B and your suppliers' data, or because returns are missing. While suspended you can't issue tax invoices or get refunds. Reply within 30 days with an explanation; if suspension was for non-filing, filing all pending returns revokes it automatically.

A REG-17 is a show cause notice to cancel registration. Reply in REG-18 within 7 working days. If the ground is non-filing, Rule 22 lets the officer drop proceedings if you file all pending returns and pay the tax, interest and late fee instead of a detailed reply — the order dropping them is REG-20. If your registration is cancelled anyway, you have 90 days to apply for revocation; our GST registration cancellation guide covers that.

Appealing a GST order

If an order (DRC-07, or a refund rejection, or a cancellation order) goes against you:

The appeal path

Step 1

Order (DRC-07, RFD-06, REG-19)

date of communication

Step 2

APL-01 to Appellate Authority

3 months + 1; 10% pre-deposit

Step 3

Appellate order (APL-04)

Step 4

APL-05 to GSTAT

3 months; further 10%

Step 5

High Court on a substantial question of law

• First appeal: Form APL-01 on the portal to the Appellate Authority within three months from communication of the order. The authority can allow one more month for sufficient cause, but not beyond.
• Pre-deposit: all amounts you admit, plus 10% of the disputed tax, capped at ₹20 crore under each of CGST and SGST. For orders that demand only a penalty, a pre-deposit of 10% of the penalty applies from 1 October 2025. Once you pay it, recovery of the rest is stayed.
• Second appeal: to the GST Appellate Tribunal (GSTAT) in Form APL-05, within three months of the first appellate order, with a further 10% of the remaining disputed tax, again capped at ₹20 crore per Act. GSTAT opened online filing of appeals in late 2025; for orders communicated before 1 April 2026, the notified last date to file was 30 June 2026.

Filing APL-01 in practice. The appeal is filed online under Services → User Services → My Applications → Appeal to Appellate Authority. You enter the order number, the disputed and admitted amounts and the pre-deposit, and upload a statement of facts and grounds of appeal. The portal issues a provisional acknowledgement at once, and the final acknowledgement with the appeal number follows in APL-02. Draft the grounds carefully: you can add new grounds later only if the authority accepts that leaving them out wasn't wilful or unreasonable.

The Appellate Authority aims to decide within a year and can't send the case back to the original officer, but it can raise the demand only after giving you notice. Pre-deposits are refunded with interest if you win.

What the 57th GST Council proposed

Recent and proposed changes to notices and appeals

1 Nov 2024

Section 74A applies to demands for FY 2024-25 onwards

31 Mar 2025

Section 128A interest and penalty waiver for FY 2017-18 to 2019-20 closed

1 Oct 2025

10% pre-deposit for penalty-only appeals

30 Jun 2026

Deadline for GSTAT appeals on orders communicated before 1 April 2026

8 Oct 2026

57th GST Council recommends ₹10,000 notice threshold and penalty reforms (not yet law)

The 57th GST Council (8 October 2026) recommended a package on disputes. None of it is law yet; most changes need amendments to the CGST Act through a Finance Act:

• No show cause notice where tax is below ₹10,000 (CGST + SGST + IGST + cess), and pending notices and appeals below that amount to be decided as if the threshold had applied.
• 5% penalty in non-fraud cases if tax and interest are paid within 30 days (section 73) or 60 days (section 74A) of the order, and removal of the ₹10,000 minimum penalty in non-fraud cases.
• Penalty to be deemed a "charge" where tax, interest and penalty are voluntarily paid in time.
• Pre-deposit for penalty-only appeals capped at ₹40 crore (₹20 crore each under CGST and SGST).
• General penalty under section 125 cut from ₹25,000 to ₹10,000.
• A circular with guidelines for officers on notice quality, timely orders, invoking fraud only on merits and holding personal hearings.
• A validation clause for notices that courts struck down for covering several financial years in one notice.
• A right to object and be heard before credit is blocked under Rule 86A.

Until these are notified, reply to every notice as the law stands. Mention a recommendation in your reply only as context, not as a ground.

Mistakes that turn small notices into big demands

Not replying. The officer is then free to decide on the material he has. Even a short reply asking for time and a hearing keeps you in the process.

Replying by email or letter only. Replies must go on the portal in the named form; an email isn't a reply on record.

Paying without reconciling. Businesses sometimes pay the whole amount in a DRC-01A to make it go away, then find most of it was a timing difference. Pay only what you've confirmed.

Not linking payments. A DRC-03 paid without referring to the notice can leave the demand open; use DRC-03A to link it.

Missing the appeal window. Three months plus one is absolute for the first appeal. Diary it the day the order arrives. If you're also chasing a refund that was rejected, the same appeal route applies; see our GST refund guide.

Official links

• GST portal — Notices and OrdersServices > User Services > View Notices and Orders / Additional Notices
• Section 74A, CGST ActDemands for FY 2024-25 onwards
• Rule 142, CGST RulesDRC-01A, DRC-01, DRC-03, DRC-06, DRC-07
• Rule 99, CGST RulesASMT-10 scrutiny
• Section 107, CGST ActAppeals and pre-deposit
• 57th GST Council recommendations (PIB)Proposed notice and penalty reforms

What to do next

Most notices start with a mismatch you could have caught earlier. Reconcile your purchase data with GSTR-2B every month, check that your GSTR-3B liability matches GSTR-1 before filing, and keep a folder for each financial year with returns, reconciliations and replies. If a notice involves a large amount or alleges fraud, get a GST practitioner or chartered accountant involved before you reply.

This is general information, not legal or tax advice — confirm on the official source or with a professional.

Frequently asked questions

How many days do I have to reply to a GST notice?

It depends on the notice. ASMT-10 scrutiny notices give up to 30 days (or longer if the officer allows); REG-17 cancellation notices give 7 working days; REG-31 suspension intimations 30 days; GSTR-3A non-filing notices 15 days; DRC-01B and DRC-01C intimations seven days. A DRC-01 show cause notice states its own reply date, usually 30 days. Always check the date printed on the notice.

What is the time limit for a GST demand notice?

For FY 2023-24 and earlier, section 73 orders must be issued within three years from the due date of the annual return (notice at least three months earlier) and section 74 fraud orders within five years from the due date of the annual return. From FY 2024-25, section 74A applies: the notice must be issued within 42 months from the due date of the annual return and the order within 12 months from the date of the notice (extendable by up to six months).

Can I avoid penalty by paying before the notice?

In non-fraud cases, yes. If you pay the tax and interest before a show cause notice is served and inform the officer through DRC-03, no notice is issued for that amount and no penalty applies. Under section 74A you can also pay tax and interest within 60 days of the notice and the proceedings close without penalty.

What is the difference between DRC-01A and DRC-01?

DRC-01A is an optional pre-notice intimation: the officer tells you the tax, interest and penalty he has worked out, and you can pay or object in Part B before a formal notice is issued. DRC-01 is the summary of the actual show cause notice under section 73, 74 or 74A. You reply to DRC-01 in Form DRC-06.

How do I appeal against a GST order?

File Form APL-01 on the GST portal within three months from communication of the order, extendable by one month for sufficient cause. You must first pay all admitted amounts plus 10% of the disputed tax, capped at ₹20 crore under each of CGST and SGST. Paying the pre-deposit stays recovery of the balance.

Will small GST notices below ₹10,000 stop?

Not yet. The 57th GST Council (8 October 2026) recommended that no show cause notice be issued where the tax involved is under ₹10,000, and that pending cases below that amount be decided as if the threshold applied. It needs an amendment to the CGST Act. Until then, section 74A only bars notices where the tax for a year is below ₹1,000.

Sources & verification

Figures on this page were checked against the sources below when it was last reviewed on 11 October 2026. Each rate and limit is stored once with its own official source and review date, and official update channels are monitored daily so changes are picked up. How we verify

1. 1.Section 61 – CGST Act, 2017 (scrutiny of returns) — CBIC · accessed 11 October 2026
2. 2.Rule 99 – CGST Rules, 2017 (ASMT-10, ASMT-11, ASMT-12) — CBIC · accessed 11 October 2026
3. 3.Section 73 – CGST Act, 2017 — CBIC · accessed 11 October 2026
4. 4.Section 74 – CGST Act, 2017 — CBIC · accessed 11 October 2026
5. 5.Section 74A – CGST Act, 2017 — CBIC · accessed 11 October 2026
6. 6.Rule 142 – CGST Rules, 2017 (notice and order for demand) — CBIC · accessed 11 October 2026
7. 7.Section 75 – CGST Act, 2017 (general provisions on demands) — CBIC · accessed 11 October 2026
8. 8.Section 107 – CGST Act, 2017 (appeals to Appellate Authority) — CBIC · accessed 11 October 2026
9. 9.Section 112 – CGST Act, 2017 (appeals to Appellate Tribunal) — CBIC · accessed 11 October 2026
10. 10.Rule 22 – CGST Rules, 2017 (cancellation of registration) — CBIC · accessed 11 October 2026
11. 11.Recommendations of the 57th Meeting of the GST Council — Press Information Bureau, Ministry of Finance · accessed 11 October 2026
12. 12.The GSTAT manual: a guide to appeals under GST — Grant Thornton Bharat · accessed 11 October 2026