What is a DRC-01?

Form DRC-01 is the formal Show Cause Notice (SCN) for demand of tax, interest, and penalty under Section 73 (non-fraud) or Section 74 (fraud/suppression) of the CGST Act, 2017.

This is the most serious demand document in GST proceedings. Once a DRC-01 is issued, you have 30 days to respond. If you do not respond, the proper officer may pass an ex-parte demand order confirming the full demand with interest and applicable penalty.

Days to Respond — Form DRC-06 Respond in Form DRC-06 on the GST portal within 30 days. Non-response leads to ex-parte demand order confirming the full demand with interest and penalty.

Section 73 vs Section 74 — The Critical Distinction

The section under which the DRC-01 is issued determines the penalty exposure and your response strategy. This distinction is critical before drafting any reply.

Factor Section 73 Section 74
Applicable when Genuine error, oversight, interpretation difference Fraud, suppression, willful misstatement
Mandatory penalty No — penalty can be waived/reduced Yes — 100% of tax as base penalty
Penalty if paid before notice NIL 15% of tax
Penalty if paid within 30 days of DRC-01 NIL 25% of tax
Penalty if paid after order, within 30 days 10% of tax (minimum) 50% of tax
Limitation period for notice 3 years from due date of annual return 5 years from due date of annual return

Important: Before drafting any reply, establish clearly which section applies to your notice. The section number will be stated in the DRC-01 itself.

Reply Template — DRC-06 (Response to DRC-01)

File your reply using Form DRC-06 on the GST portal. The template below covers all key sections — adapt it precisely to your facts and the specific allegations raised in the notice.

Form DRC-06 — Reply to Show Cause Notice
To,

[Designation of GST Officer as in notice]
[Jurisdiction]

Subject: Reply to Show Cause Notice in Form DRC-01 under Section 73/74
         of the CGST Act, 2017

GSTIN: [GSTIN]
DRC-01 Reference No.: [NUMBER]
DRC-01 Date: [DATE]
Tax Period: [PERIOD]
Alleged Demand: ₹[AMOUNT] (Tax: ₹[X], Interest: ₹[X], Penalty: ₹[X])

Respected Sir/Madam,

This is our reply to the Show Cause Notice dated [DATE] in Form DRC-01
issued under Section [73/74] of the CGST Act, 2017, proposing demand of
tax, interest, and penalty as detailed above.

I. PRELIMINARY OBJECTIONS [if any]

[This section is for jurisdictional or procedural objections — e.g.,
notice issued beyond time limit, DRC-01A not issued before DRC-01, etc.]

1. [Objection 1 with legal basis]
2. [Objection 2 with legal basis]

II. RESPONSE TO THE ALLEGATIONS

Allegation 1 from DRC-01: [Reproduce exactly]

Response:

[Detailed factual rebuttal with document references. Be specific —
amounts, invoice numbers, dates, reconciliation figures. Every statement
should be backed by an enclosed document.]

Supporting Documents: Annexure A

Allegation 2 from DRC-01: [Reproduce exactly]

Response:

[Detailed response]

[Continue for all allegations]

III. ON THE QUESTION OF PENALTY

[IF CONTESTING PENALTY UNDER SEC 73:]

It is respectfully submitted that this is not a case involving fraud,
suppression, or willful misstatement. The alleged discrepancy has arisen
on account of [REASON].

Accordingly, Section 74 is inapplicable and the matter is governed solely
by Section 73. No penalty is therefore imposable beyond the amounts
prescribed under Section 73.

[IF MAKING PAYMENT:]

In respect of the amount of ₹[AMOUNT] which we agree is payable, we have
deposited tax of ₹[TAX] and interest of ₹[INTEREST] through Electronic
Cash Ledger, details of which are enclosed as Annexure [X]. In view of
this payment within 30 days of the SCN, we respectfully submit that
penalty is NIL under Section 73 / 25% under Section 74, as applicable.

IV. PRAYER

In view of the above, we respectfully pray that:

(a) The Show Cause Notice may be dropped in respect of the disputed
    amount of ₹[AMOUNT] on the grounds stated above; and

(b) In respect of the agreed amount, credit may be given for the payment
    already made and the matter be closed accordingly.

Thanking you,
Yours faithfully,

[Authorised Signatory]
[GSTIN]  [Date]

ENCLOSURES:

A — [Primary reconciliation document]
B — Invoices relevant to disputed supplies
C — GSTR-2B extract for disputed ITC
D — Payment challans / Electronic Cash Ledger extract
E — [Any other relevant document]

Related GST Notices

GST proceedings often involve multiple notice types in sequence. Familiarise yourself with these related forms.

Received a DRC-01? Act Within 30 Days.

A Show Cause Notice demands a precise, document-backed reply. The wrong response — or no response — leads to an ex-parte demand order. Get expert guidance to protect your business.

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