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GST / Litigation & Compliance

GST DRC-01A Reply Before Show-Cause Notice: Part A, Part B and the Pre-SCN Window

A technical guide to replying to a DRC-01A pre-show-cause intimation, covering Part A/Part B, the voluntary payment route and the consequences of a bare denial before the SCN stage.

29 Oct 20263 min read

Form GST DRC-01A is a pre-show-cause intimation under Rule 142(1A) of the CGST Rules, issued before proceedings under Section 73 or 74. It communicates the officer’s tentative view of the tax, interest and penalty and gives the taxpayer an opportunity to pay voluntarily through DRC-03 or to explain why the proposed demand is not sustainable. The DRC-01A stage is not a mandatory pre-condition in every case after the 2020 amendment, but once the officer exercises the option and issues the intimation, the taxpayer’s reply shapes whether a show-cause notice follows and what it contains.

Part A and Part B

The DRC-01A has two parts. Part A records the officer’s intimation of the proposed tax, interest and penalty. Part B is the taxpayer’s response: either acceptance of the liability with the DRC-03 payment details, or a disagreement with reasons and supporting evidence. The taxpayer should complete Part B carefully; a bare denial without reconciliation leaves the officer with no basis to close the proposed demand.

The Agreement Route

Where the taxpayer agrees with the proposed liability, the payment should be made through DRC-03, and the details should be furnished in Part B. The voluntary payment route can reduce the penalty exposure and close the matter before a show-cause notice. The taxpayer should ensure that the DRC-03 payment is correctly allocated to the tax, interest and penalty heads and that the reference to the DRC-01A is recorded.

The Disagreement Route

Where the taxpayer disagrees, the Part B response should set out the legal basis and the factual reconciliation. The response should address each proposed demand head: the tax amount, the interest computation and the penalty invocation. The taxpayer should annex the reconciliations, ledgers, invoices, returns and any judicial or circular authority. The response should be framed as a pre-SCN submission that the officer can rely on if the matter proceeds to DRC-01.

The Madras High Court has held that a taxpayer must first respond to a GST show-cause notice before challenging the invocation of Section 74 in writ proceedings. The same discipline applies at the DRC-01A stage: the taxpayer should engage with the intimation rather than reserve all arguments for a later challenge.

The Consequence of a Bare Denial

A bare denial at the DRC-01A stage does not prevent the officer from issuing a DRC-01. It may, however, weaken the taxpayer’s position because the officer can record that the explanation was considered and not accepted. A response that is specific, documented and legally framed gives the officer a basis to drop the proposed demand or to narrow it.

The Transition to DRC-01

Where the officer is not satisfied with the Part B response, the next step is a show-cause notice in DRC-01 under Section 73 or 74. The taxpayer’s DRC-01A response becomes part of the record and should be cross-referenced in the DRC-01 reply. The taxpayer should not treat the DRC-01A as a preliminary formality; it is the first substantive opportunity to shape the demand.

What the Taxpayer Should Control

The DRC-01A outcome depends on three variables: whether the taxpayer uses Part B to agree and pay or to disagree with a documented explanation; whether the response addresses tax, interest and penalty separately; and whether the response is framed to be carried forward into the DRC-01 stage. The taxpayer that controls these variables either closes the matter early or builds a record for the demand stage.


Call to Action: We advise taxpayers on DRC-01A Part B responses, voluntary DRC-03 payments and pre-SCN strategy. For a pre-SCN engagement, contact office@anujdesaiassociates.com, Ph No. 9619456656, Website https://anujdesaiassociates.com, LinkedIn linkedin.com/in/ca-anuj-desai-122547230.

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