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DRC 06 reply to GST show cause notice

By gstr2bmatch.in Editorial Team · Updated 25 October 2026 · 5 min read

A DRC 06 reply is the statutory written representation filed under Rule 142(4) of the CGST Rules in response to a formal GST show cause notice issued in Form GST DRC-01. Taxpayers submit Form GST DRC-06 through the common portal to contest or accept proposed tax, interest, or penalties before an adjudication order is passed. Unlike automated mismatch intimations such as DRC-01C, Form DRC-06 handles substantive adjudication proceedings under Section 73, Section 74, or Section 76.

Receiving a show cause notice in Form GST DRC-01 means the tax authority has initiated formal demand proceedings against your business. Whether the dispute arises from an input tax credit mismatch, turnover differences, or classification issues, your reply must be filed electronically in Form GST DRC-06. If you have already reviewed our guide on GST notices after reconciliation, you know that missing statutory timelines or failing to submit documentary evidence can lead straight to an adverse demand order.

Legal framework under Rule 142(4) and Section 75

Statutory authority for the reply comes from Rule 142(4) of the CGST Rules, which provides that the representation referred to in Section 73(9), Section 74(9), or Section 76(3) shall be submitted in Form GST DRC-06. This filing is your official opportunity to present facts, point out calculation errors, and establish the legality of your claims.

Two essential safeguards under the law protect the taxpayer during this stage:

  • Right to a personal hearing: Under Section 75(4) of the CGST Act, an opportunity of hearing shall be granted where a request is received in writing from the person chargeable with tax or penalty, or where any adverse decision is contemplated against such person.
  • Demand limited to the notice: Under Section 75(7) of the CGST Act, the amount of tax, interest, and penalty demanded in the order shall not exceed the amount specified in the notice, and no demand shall be confirmed on grounds other than those specified in the notice.

Common mistake: Omitting the explicit written request for a personal hearing in Form DRC-06. Even if you tick the personal hearing box on the portal, always include a specific prayer in your attached representation letter requesting an opportunity of personal hearing before any adverse order is passed.

Difference between Form DRC-06 and Form DRC-01C Part B

Many taxpayers confuse Form DRC-06 with automated intimation replies like DRC-01C Part B. They belong to completely different stages of GST compliance:

  • DRC-01C Part B: Filed under Rule 88D for system-generated ITC differences between GSTR-3B and GSTR-2B. It is an automated compliance intimation with predefined dropdown reasons and a 7-day timeline.
  • DRC-06: Filed under Rule 142(4) in response to a formal Show Cause Notice issued by an adjudicating officer in Form GST DRC-01. It is a legal defense in quasi-judicial proceedings that requires a comprehensive legal submission, reconciliation statements, and documentary evidence.

Step-by-step portal navigation to file Form GST DRC-06

GST demand notices and their replies are handled electronically. According to official portal guidance on viewing notices and demand orders, follow these steps to locate your notice and submit Form GST DRC-06:

  1. Log in to the GST portal with your valid credentials.
  2. Navigate to Services > User Services > View Additional Notices and Orders (or View Notices and Orders, depending on the case file).
  3. Locate the relevant Case ID associated with the Form GST DRC-01 Show Cause Notice and click View.
  4. Open the Replies tab and click on Add Reply to open Form GST DRC-06.
  5. Select whether you accept the proposed demand in full, accept it in part, or contest it entirely.
  6. Select Yes for the option seeking a personal hearing.
  7. Enter your summary submissions in the text box and upload your comprehensive reply document along with supporting annexures.
  8. Sign the reply electronically using a Digital Signature Certificate (DSC) or Electronic Verification Code (EVC) to generate an Acknowledgement Reference Number (ARN).

Structure of a strong DRC-06 reply and attachments

A persuasive DRC-06 submission should be structured methodically as a formal legal petition. Ensure your attached PDF includes:

  • Brief facts of the case: A factual background detailing the business operations, return filing history, and the date of receipt of Form GST DRC-01.
  • Point-by-point rebuttal: Directly answer each allegation in the show cause notice. If the notice alleges excess ITC, provide invoice-level reconciliation.
  • Legal grounds and statutory references: Cite relevant statutory provisions and CBIC circulars supporting your position.
  • List of annexures: Clear cross-referenced exhibits, including GSTR-2B monthly statements, supplier tax payment confirmations, bank payment proofs, and purchase invoices.
  • Prayer: A closing prayer requesting the proper officer to drop the proposed demand and grant a personal hearing before deciding the matter.
BEFORE THE PROPER OFFICER / ASSISTANT COMMISSIONER OF STATE TAX, GST Reply in Form GST DRC-06 under Rule 142(4) of the CGST Rules, 2017 In the matter of: M/s ABC Enterprises (GSTIN: 27AAAAA0000A1Z5) Reference: Show Cause Notice Reference Number DRC01/2026/089 dated 15 September 2026 Subject: Reply to Show Cause Notice in Form GST DRC-01 for the Tax Period April 2024 to March 2025. Respected Sir/Madam, The Taxpayer submits the following point-by-point reply against the proposed demand: 1. That the proposed demand of tax amounting to Rs 90,000 along with applicable interest and penalty under Section 73 is contested as incorrect on facts and law. 2. That the ITC difference between GSTR-3B Table 4(A) and GSTR-2B arose due to delayed reporting by vendors in their subsequent returns, for which detailed invoice-wise reconciliation and supplier tax payment certificates are enclosed as Annexure A. 3. That all conditions of Section 16(2) of the CGST Act have been fully complied with, and tax has been duly discharged by the suppliers. PRAYER: In light of the above facts, it is respectfully prayed that: a) The proposed demand of tax, interest, and penalty in Form GST DRC-01 be dropped in its entirety. b) An opportunity of personal hearing under Section 75(4) of the CGST Act be granted to the Taxpayer before passing any order. Yours faithfully, For ABC Enterprises Authorised Signatory

Worked example of an ITC demand contest

Consider a taxpayer, M/s ABC Enterprises, who receives a Form GST DRC-01 notice proposing a tax demand of ₹90,000 for financial year 2024-25. The notice alleges excess ITC availed in GSTR-3B compared to GSTR-2B. Upon performing invoice-by-invoice reconciliation, the accountant identifies that invoices were reported late by suppliers in subsequent periods.

Notice allegation Amount in DRC-01 Verified reconciliation status DRC-06 defense
Late vendor reporting ₹54,000 Appeared in GSTR-2B in next quarter Produce Annexure A with 2B extracts
Capital goods credit split ₹36,000 Claimed per books and valid tax invoices Attach tax invoice and bank payment proof
Total contested demand ₹90,000 Total verified credits: ₹90,000 Pray to drop demand in full

The total contested tax amount is calculated as:

Contested tax demand = ₹54,000 + ₹36,000 = ₹90,000.

By preparing an exact invoice-level schedule and attaching proof of supplier compliance, the taxpayer establishes that no tax was short-paid, thereby defending against both the ₹90,000 tax claim and consequential interest.

What happens after filing DRC-06?

Once you submit Form GST DRC-06, the adjudicating authority considers your written reply and examines all attached schedules. If you requested a personal hearing, a notice specifying the hearing date, time, and venue is issued.

Following the hearing, the proper officer issues a speaking adjudication order. Under Rule 142(5) of the CGST Rules, a summary of the order issued under Section 73, Section 74, or Section 76 must be uploaded electronically in Form GST DRC-07 specifying the amount of tax, interest, and penalty payable. If the officer accepts your explanation entirely, an order dropping the proceedings is passed.

Frequently asked questions

What is Form GST DRC-06?

Form GST DRC-06 is the statutory electronic representation filed under Rule 142(4) of the CGST Rules in reply to a show cause notice issued under Section 73, Section 74, or Section 76.

How do you request a personal hearing in Form DRC-06?

Select the option for personal hearing in the DRC-06 portal form and state the request clearly in your written representation as provided under Section 75(4) of the CGST Act.

What happens after submitting Form GST DRC-06?

The proper officer examines the reply and supporting documents, conducts the personal hearing if requested, and issues a final speaking order with a summary in Form GST DRC-07 under Rule 142(5).

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Last checked: 25 October 2026. Sources: CBIC CGST Rules Rule 142, GSTN Portal Guide on View Notices and Demand Orders.