GST notices to a client: the reply windows for ASMT-10, the 7-day DRC-01B and DRC-01C, DRC-01A and DRC-01, and a register to track them

A firm with a few hundred GST clients gets notices every week, each on its own clock, and most of them arrive on the GST portal rather than in anyone's inbox. The work that goes wrong is rarely the reply itself; it is the notice nobody noticed until the seven days had passed.

Each notice and its clock

ASMT-10: scrutiny of a return

When a return is selected for scrutiny under section 61 and the officer finds a discrepancy, rule 99 has the officer issue ASMT-10 and ask for an explanation within such time, not exceeding thirty days from the date of service of the notice, or such further period as the officer permits. The client can accept and pay, or explain, in ASMT-11; if the officer accepts it, ASMT-12 closes the matter.¹

DRC-01B and DRC-01C: the 7-day intimations

Rule 88C covers the case where tax in GSTR-1 exceeds tax paid in GSTR-3B beyond the set limit; rule 88D covers credit taken in GSTR-3B beyond what is available, beyond the set limit. In both, the client is told in Part A and must, within a period of seven days, pay the difference through DRC-03 or explain in Part B.²³ Rule 59(6) then does not allow the client to file GSTR-1 for a later period until they have paid or replied.⁴ These are the notices most worth a daily check, because a missed one shows up as a blocked return in the next filing week.

DRC-01A: before a show cause notice

Under rule 142(1A), the officer may, before serving a show cause notice, send the tax, interest and penalty as the officer has worked them out, in Part A of DRC-01A. It is optional for the officer; when it comes, the client can pay or make submissions in Part B.⁵ Our recommendation is to treat it as the first notice and answer it in full, since what is settled here does not reach the show cause notice.

DRC-01: the show cause notice

Which section applies depends on the year. For years up to 2023-24, section 73: the notice is issued at least three months before the order's time limit, which is three years from the due date of that year's annual return, and if the client pays the tax with interest within thirty days of the notice, no penalty is payable and the proceedings are concluded.⁶ For 2024-25 onwards, section 74A: the notice is issued within forty-two months of the annual return's due date, the order within twelve months of the notice, and in cases without fraud, paying the tax with interest within sixty days of the notice means no penalty.⁷

The annual return for 2022-23 was due on 31 December 2023, so under section 73 its orders must be issued by 31 December 2026.⁶ For a client with a 2022-23 notice, the reply and the hearing are this month's work, as in our compliance calendar.

The hearing

Section 75 requires a hearing where the client asks for one in writing, or where an adverse decision is contemplated, and allows adjournments for sufficient cause, but no more than three times to a person during the proceedings.⁸ Our recommendation is to ask for the hearing in the written reply, and to count each adjournment in the register.

The notice register

One row per notice, kept by the person who checks the portal, read by the partner every week:

• Client and GSTIN, and the form: ASMT-10, DRC-01B, DRC-01C, DRC-01A, DRC-01 or another.
• The period it is about, and the section it was issued under.
• Date of the notice, and the date it was served or seen on the portal.
• The reply due date, worked out from the notice: 7 days, up to 30, the date stated, or the 30 or 60 days that avoid penalty.
• The amount, who in the firm handles it, and the papers asked of the client.
• The reply: date filed and its acknowledgement number.
• The hearing: date, and adjournments used out of three.
• The outcome: closed, paid, or order received, with its date.

It works like our UDIN register: the column that matters is the next date, sorted so the nearest is on top. Whether replies and hearings are part of the fee belongs in the engagement letter.

Messages you can copy

Replace the words in brackets. These are written for WhatsApp, like our GST return reminders.

What can run by itself

• The portal check, for every client every day, with each new notice added to the register as a row.
• The due date, worked out from the form and the notice date, and a warning two days before it.
• The first message to the client, asking for the papers, and a follow-up naming only what is still missing, as in our client reminders.
• The papers, filed under the client and the notice as they arrive, as in our document processing.

What stays with your team

• The reply itself, and whether to pay, explain or contest.
• The hearing, and the decision to ask for an adjournment.
• Anything that may be fraud or suppression, which changes the section and the penalty, and needs a partner from the first day.

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