GST show cause notices
Review of the allegations, demand computation, limitation and jurisdiction; reconciliation of returns and books; drafting of a written reply with supporting evidence.
Practice Area · GST Litigation
GST Litigation, Notices and Appeals
Representation for businesses facing GST show cause notices, demand orders, credit blocking and refund rejections — from the first reply to appeals before the Appellate Authority, the GST Appellate Tribunal and the High Court.
- What the firm does
- Replies, representation and appeals in GST proceedings under the CGST Act, 2017 and the corresponding State GST Acts.
- Who it is for
- Manufacturers, traders, exporters, service providers and professionals who have received a GST notice, order or intimation.
- Where
- Based in Jalandhar, Punjab; matters handled across India, with presence in Chandigarh for Punjab & Haryana High Court work.
Show cause notices and demand proceedings
Most GST disputes start with an intimation or a show cause notice. A careful first reply shapes everything that follows, including the scope of any later appeal.
DRC-01A, DRC-01 and DRC-07 proceedings
Responses to pre-notice intimations (DRC-01A) and summaries of notices (DRC-01), filing of replies in DRC-06, and review of the summary of the order (DRC-07) to assess rectification or appeal.
Section 73, Section 74 and Section 74A
Advice on whether a notice has been correctly issued as a non-fraud (Section 73) or fraud/suppression case (Section 74), and on the unified provision in Section 74A that applies to demands for financial year 2024-25 onwards. Read the guide to Sections 73, 74 and 74A.
Personal hearing representation
Preparation of written submissions and representation at personal hearings, which Section 75(4) of the CGST Act requires where requested or where an adverse decision is contemplated.
GST appeals and higher remedies
Appeals must be filed within statutory time limits and generally require a pre-deposit of a portion of the disputed tax.
First appeals under Section 107
Drafting of grounds of appeal and statement of facts, computation of pre-deposit, filing in Form GST APL-01 and representation before the Appellate Authority. Read the GST appeal guide.
GST Appellate Tribunal (GSTAT)
Second appeals under Section 112 of the CGST Act against orders of the Appellate Authority.
Writ petitions
High Court writ petitions under Article 226 of the Constitution where there is a breach of natural justice, a jurisdictional defect or an arbitrary action such as registration cancellation or bank attachment.
Rectification applications
Applications under Section 161 of the CGST Act to correct errors apparent on the face of the record, which can resolve some disputes without a full appeal.
Input tax credit, ledger blocking and refund disputes
ITC disputes
Defence of credit claims challenged for GSTR-2A/2B mismatches, supplier non-compliance, alleged fake invoices or ineligibility under Section 17(5).
Blocking of the electronic credit ledger
Representations and challenges against restrictions imposed under Rule 86A of the CGST Rules. Read about Rule 86A.
Refund litigation
Replies to deficiency memos and refund show cause notices, and appeals against rejection of refunds of accumulated ITC, export refunds and excess tax paid.
Registration and enforcement actions
Revocation of cancelled registrations, responses to summons and inspections, and objections to provisional attachment under Section 83.
Who typically approaches the firm for gst litigation
- Businesses that have received a GST notice, intimation or adverse order
- Exporters whose refunds are delayed or rejected
- Taxpayers whose electronic credit ledger has been blocked
- Companies facing inspections, summons or bank attachment
- Chartered accountants seeking litigation support for their clients
How an engagement works
- Share the documents. The notice, order or draft you are dealing with, and relevant dates.
- Initial review. The firm identifies the issues, the deadlines and the documents needed.
- Scope and engagement. Scope and fees are agreed in writing before work begins.
- Preparation and representation. Drafting, filing and appearances, with updates at each stage.
Further reading from the Legal Knowledge Centre
Common questions about gst litigation
What GST litigation services does the firm provide?
The firm assists with replies to show cause notices and DRC-01 proceedings, matters under Sections 73, 74 and 74A of the CGST Act, appeals before the Appellate Authority and the GST Appellate Tribunal, writ petitions, ITC and refund disputes, blocking of the electronic credit ledger under Rule 86A, rectification applications and personal hearings. See GST litigation.
Does the firm assist with GST show cause notices?
Yes. The firm reviews the notice and the demand computation, identifies jurisdictional, limitation and factual issues, reconciles the underlying records and drafts a written reply with supporting documents. It can also represent the taxpayer at the personal hearing. Response timelines in a notice are strict, so the notice should be shared as early as possible.
Can the firm assist in GST appeals?
Yes. The firm prepares and files appeals against adverse orders, including the grounds of appeal, statement of facts and supporting documents, and represents the appellant at the hearing. Appeals are subject to statutory time limits and a mandatory pre-deposit. Read the GST appeal guide.
Does the firm handle ITC disputes?
Yes. This includes disputes over denial or reversal of input tax credit, mismatches between GSTR-2A/2B and books, credit denied because of supplier non-compliance, and blocking of credit under Rule 86A.
When can tax authorities provisionally attach bank accounts under GST?
Section 83 of the CGST Act allows provisional attachment of property, including bank accounts, during specified proceedings where the Commissioner is of the opinion that it is necessary to protect the interest of revenue. The power must be exercised in accordance with the statute and the conditions laid down by courts, and attachment orders can be challenged through objections and, where appropriate, writ petitions.
Related practice areas
Discuss a gst litigation matter
Share the notice, order or question you are dealing with. The firm will review the scope and explain the available options and next steps.