A SCN is not a verdict — it is an opening position. Most matters can be narrowed or closed at the audit stage, if the file is in order and the reply is precise.
Discuss a Notice →GST disputes move quickly. The ASMT-10 discrepancy notice gives 30 days; the DRC-01 show-cause may give 30 more. By the time most assessees engage counsel, half the response window is already spent. The aim of this practice is to compress that gap — to read the file with the same care a department officer will, before the file leaves your office.
I handle both routine departmental audits (under Section 65) and the contested end of the spectrum — show-cause proceedings under Sections 73/74, anti-evasion (DGGI) matters, ITC reversals, and the appellate process before the Appellate Authority and Tribunal. Wherever a position turns on documentation, the case is won or lost in the paper trail.
Departmental audits under Section 65, special audits under Section 66, and scrutiny under Section 61. Reconciliation of GSTR-3B with GSTR-1, GSTR-2B, and the books — the three numbers must tie, and where they don't, the explanation must be ready before the audit officer asks.
DRC-01 replies for proceedings under Sections 73 (non-fraud) and 74 (fraud / suppression — 100% penalty exposure) for FY 2017-18 to FY 2023-24, and under the new consolidated Section 74A — inserted by the Finance (No. 2) Act, 2024 with effect from FY 2024-25 — which merges the two tracks into a single procedure with a 42-month SCN limitation and a 12-month adjudication clock (extendable by 6 months). Personal hearings before the adjudicating authority, follow-through to DRC-07 orders, and stay strategy if recovery is initiated.
Summons under Section 70, statement-recording sessions, search-and-seizure proceedings under Section 67, and arrest-threshold matters under Section 69. These are procedurally distinct from departmental scrutiny — statements are admissible as evidence, and the right counsel needs to be present before, not after.
First appeal under Section 107 (Appellate Authority — 3-month limitation, 10% pre-deposit). Second appeal to the GST Appellate Tribunal (constituted from FY 2025-26 onwards). Writ petitions to the High Court for jurisdictional and constitutional questions.
GSTR-1, GSTR-3B, GSTR-9, GSTR-9C, e-invoicing, e-way bill management, and new-registration applications. Routine compliance done with the same eye on dispute prevention as the litigation work.
Very. DRC-01 is the formal show-cause — issued under Section 73 or 74 for years up to FY 2023-24, or under the new consolidated Section 74A (Finance (No. 2) Act, 2024) for FY 2024-25 onwards — with a response window of 30 days. Section 74 / 74A in the fraud / suppression variant carries a 100% penalty in addition to tax and interest, and the burden of disproving the allegations sits squarely on the assessee.
Reply before the deadline; do not let it lapse into adjudication ex parte. An ex parte order is procedurally harder to unwind. Under Section 74A, the adjudicating authority has 12 months to pass an order (extendable by 6 months), which compresses the procedural calendar relative to the older regime.
Yes — Section 16(2)(aa) ties ITC to the invoice appearing in your GSTR-2B, which in turn depends on your supplier filing GSTR-1. The recent jurisprudence is evolving: several High Courts have read down the strictness where the recipient acted in good faith.
The right defence depends on the year, the state, and whether the supplier is genuine vs a registered fraudster. Documentation of due diligence at the time of purchase matters here.
Yes. Anti-evasion wing matters are procedurally different from departmental scrutiny — statements under Section 70 are admissible as evidence, and arrest provisions under Section 69 are live for matters exceeding the threshold.
I'd strongly recommend professional advice before responding to any summons in person. What is said in the first statement frames the rest of the matter.
Yes — and there's a real benefit to doing both with the same desk. Monthly GSTR-1/3B filings often surface the very issues that will be raised at audit; catching them early changes the negotiating posture from defence to disclosure.
First appeal under Section 107 lies with the Appellate Authority (Joint/Additional Commissioner — Appeals) within 3 months, with a 10% pre-deposit of disputed tax.
The GST Appellate Tribunal is functional as of FY 2025-26 — second appeals are routed there with a further 20% pre-deposit. Writ jurisdiction lies with the High Court for jurisdictional and fundamental-rights issues.
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