GST Assessment & Litigation Services in India

EzyBiz India Consulting LLP provides professional GST Assessment & Litigation Services in India to Indian companies, multinational groups, foreign-owned businesses, exporters, manufacturers, service providers, start-ups and other taxpayers facing GST scrutiny, assessment, show cause notices, tax demands, adjudication, appeals and litigation.

GST disputes may arise from differences in turnover, input tax credit, GST returns, books of account, GSTR-2B, classification, tax rates, place of supply, reverse charge, exports, refunds, related-party transactions or other compliance matters.

Once a GST matter enters departmental proceedings, the taxpayer’s response should address not only the tax computation but also the facts, applicable statutory provisions, limitation, jurisdiction, documentary evidence, reconciliations and procedural requirements.

EzyBiz India assists businesses from the initial GST scrutiny or notice stage through adjudication, first appeal and GST Appellate Tribunal proceedings. Depending upon the matter, our work may involve preparation of factual submissions, GST reconciliations, reply to show cause notice, review of DRC forms, appeal documentation and representation support.

Businesses requiring wider indirect-tax support may also refer to our GST and Indirect Tax Advisory Services in India, GST Audit Services in India and GST Refund Services in India.

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GST Assessment & Litigation in India — At a Glance

GST assessment and litigation can involve several stages, beginning with scrutiny of returns or another departmental proceeding and potentially progressing to adjudication and statutory appeals.

GST Proceeding	Relevant Provision / Form	How We Assist
Scrutiny of Returns	Section 61 / ASMT-10	Review discrepancies, reconcile records and prepare ASMT-11 response
Assessment of Non-Filers	Section 62 / ASMT-13	Review best-judgment assessment, pending returns and remedial options
Assessment of Unregistered Persons	Section 63 / ASMT-14 and ASMT-15	Review registration liability, tax periods, turnover and proposed assessment
Summary Assessment	Section 64 / ASMT-16	Review order and evaluate application for withdrawal or other remedy
GST Demand Proceedings	Sections 73, 74 or 74A	Review show cause notice, computation, evidence, limitation and legal position
Reply to Show Cause Notice	DRC-06	Prepare factual and legal submissions with reconciliations and documents
Adjudication Order	DRC-07	Review findings, demand, penalty, interest and available remedies
First GST Appeal	Section 107 / APL-01	Prepare appeal, grounds, statement of facts, evidence and pre-deposit review
GST Appellate Tribunal	Section 112	Appeal preparation, documentation, written submissions and GSTAT support

Who We Assist

Our GST assessment and litigation services are available to:

Indian private and public companies;
foreign-owned Indian subsidiaries;
multinational groups;
manufacturers;
traders and distributors;
exporters;
service providers;
start-ups;
LLPs and partnership firms;
branch and project operations, where applicable; and
other registered or taxable persons facing GST proceedings.

What Is GST Assessment and Litigation?

GST assessment broadly involves determination or verification of tax liability under the CGST Act and corresponding State or Union Territory GST laws.

GST litigation arises when there is a dispute between the taxpayer and the tax authorities regarding tax liability, input tax credit, classification, valuation, refund, penalty, interest, jurisdiction, procedural compliance or another GST issue.

Assessment under GST

The GST framework contains different assessment mechanisms depending upon the circumstances.

These include self-assessment, provisional assessment, scrutiny of returns, assessment of non-filers, assessment of unregistered persons and summary assessment.

A departmental audit under Section 65 or special audit under Section 66 is different from an assessment, although findings arising from an audit may lead to demand or adjudication proceedings.

For audit-related proceedings, businesses may refer to our GST Audit Services in India.

Litigation under GST

GST litigation may commence when a discrepancy or alleged default develops into a formal demand or adjudication proceeding.

A typical dispute may involve:

show cause notice;
reply and documentary evidence;
personal hearing;
adjudication order;
tax demand;
first appeal;
GSTAT proceedings; and
higher judicial proceedings where legally maintainable.

Effective GST litigation therefore requires consistency between the taxpayer’s returns, accounting records, reconciliations, factual explanation and legal submissions throughout the proceedings.

GST Scrutiny under Section 61

Section 61 of the CGST Act permits the proper officer to scrutinise returns and related particulars to verify their correctness and seek an explanation regarding discrepancies noticed.

The statutory provisions can be reviewed on the CBIC GST website.

FORM GST ASMT-10

Where a return is selected for scrutiny and the proper officer identifies a discrepancy, the taxpayer may receive FORM GST ASMT-10.

Issues commonly identified during scrutiny may include:

difference between GSTR-1 and GSTR-3B;
difference between turnover in financial statements and GST returns;
GSTR-2B and ITC mismatch;
excess input tax credit;
reverse charge differences;
incorrect tax rate;
classification issues;
e-way bill differences;
export or zero-rated supply differences; and
other return-based discrepancies.

The applicable procedure relating to scrutiny can also be referred to under the official GST Assessment and Audit Rules.

FORM GST ASMT-11 and ASMT-12

A taxpayer may respond to the discrepancy through FORM GST ASMT-11, either accepting the discrepancy and taking applicable corrective action or providing an explanation supported by relevant documents.

Where the explanation is accepted, the proper officer may communicate acceptance through FORM GST ASMT-12.

A scrutiny response should not merely reproduce GST return figures. The explanation should identify the cause of the difference and provide an appropriate reconciliation.

What Happens if the Scrutiny Explanation Is Not Accepted?

If the explanation is not considered satisfactory or corrective action is not taken, further proceedings may follow under the applicable GST provisions.

Depending upon the circumstances, this may include audit, special audit, inspection or determination of tax and other dues.

Businesses should therefore treat an ASMT-10 scrutiny notice as an important pre-dispute stage and prepare the response with the possibility of subsequent adjudication in mind.

Best Judgment Assessment under Section 62

Section 62 deals with assessment of registered persons who fail to furnish specified GST returns even after the statutory notice procedure.

The proper officer may determine the tax liability to the best of judgement on the basis of relevant information available or gathered.

When Section 62 Can Apply

Best-judgment assessment may arise where a registered person has failed to furnish a return required under Section 39 or the final return under Section 45 despite the applicable notice under Section 46.

The resulting assessment order is generally issued through FORM GST ASMT-13 together with the prescribed demand summary.

Businesses receiving an ASMT-13 order should immediately examine:

the return periods involved;
whether returns remain pending;
tax liability estimated by the officer;
information used for the assessment;
interest and late-fee consequences;
available statutory relief; and
appeal limitation if the matter is not otherwise resolved.

Filing Returns after an ASMT-13 Order

The current statutory framework provides for deemed withdrawal of a best-judgment assessment order where a valid return is furnished within the period and conditions prescribed under Section 62.

Interest and late-fee consequences may nevertheless continue even where the assessment order is deemed withdrawn.

Because the remedial period is statutory, an ASMT-13 order should be reviewed immediately rather than waiting until recovery action begins.

Assessment of Unregistered Persons under Section 63

Section 63 permits assessment of a taxable person who was liable to obtain GST registration but failed to do so, as well as specified situations involving cancellation of registration where tax liability remains.

When Section 63 Applies

A Section 63 proceeding can be significant because the dispute may concern both:

whether the person was liable for GST registration; and
the amount of GST liability for the relevant tax periods.

The review may therefore require examination of aggregate turnover, taxable supplies, exempt supplies, inter-State transactions, place of supply, threshold provisions and the effective date from which registration was required.

Businesses with registration-related issues may also refer to our GST Registration Services in India.

FORM GST ASMT-14 and ASMT-15

A notice proposing best-judgment assessment under Section 63 may be issued in FORM GST ASMT-14.

The taxpayer should respond to the proposed assessment with the relevant factual and legal position and supporting records.

Where an assessment is ultimately made, the order may be issued in FORM GST ASMT-15 along with the prescribed demand summary.

Summary Assessment under Section 64

Section 64 provides for summary assessment in specified circumstances where immediate action is considered necessary to protect the interest of revenue.

When Summary Assessment May Be Made

A proper officer may proceed with summary assessment based on evidence showing tax liability where the statutory conditions are satisfied and the required prior permission has been obtained.

The assessment order is issued in the prescribed form, including FORM GST ASMT-16.

Because summary assessment is intended for exceptional circumstances, the factual basis, statutory preconditions and identity of the person liable should be reviewed carefully.

Withdrawal of Summary Assessment

Section 64 provides a mechanism for withdrawal of an erroneous summary assessment order in appropriate circumstances.

The prescribed forms include FORM GST ASMT-17 for application relating to withdrawal and FORM GST ASMT-18 for the relevant decision.

Where withdrawal is not available or granted, other statutory remedies may need to be evaluated based upon the nature of the order.

GST Show Cause Notices and Demand Proceedings

A GST show cause notice is a critical stage of tax proceedings because it sets out the allegations, proposed demand and legal basis on which the department proposes to take action.

The notice, its annexures and accompanying DRC forms should be read together before any response is prepared.

Common Issues Leading to GST Demands

GST demand proceedings may arise from issues including:

turnover not reported in GST returns;
GSTR-1 and GSTR-3B differences;
input tax credit mismatch;
ineligible or blocked ITC;
reverse charge liability;
classification of goods or services;
incorrect GST rate;
valuation disputes;
related-party transactions;
place-of-supply disputes;
export-of-services conditions;
refund alleged to have been erroneously granted;
credit-note disputes;
e-way bill differences;
tax collected but not paid;
non-payment or short payment of tax; and
other compliance differences identified during scrutiny, audit or investigation.

Importance of Reviewing Jurisdiction and Limitation

A show cause notice should be examined not only on the merits of the tax computation but also for jurisdictional and procedural issues.

The review may include:

financial year involved;
provision invoked;
date of notice;
statutory limitation;
proper officer;
tax period;
basis of allegation;
documents relied upon;
computation of tax, interest and penalty; and
whether the notice goes beyond the material or proceeding from which it originated.

Personal Hearing and Principles of Natural Justice

Where an adverse decision is proposed and the applicable statutory conditions require an opportunity of hearing, the taxpayer should consider requesting and properly preparing for the hearing.

A personal or virtual hearing is most effective where the written submission has already identified:

issues in dispute;
factual chronology;
reconciliations;
supporting evidence;
applicable statutory provisions; and
specific relief sought.

The oral representation should remain consistent with the written reply and documentary record.

Section 73 and Section 74 for Periods up to FY 2023-24

An important change in the GST demand framework is that Sections 73 and 74 now relate to determination of tax pertaining to periods up to Financial Year 2023-24.

Accordingly, the financial year involved should be identified before analysing the demand provision applicable to a notice.

Section 73 — Cases Other Than Fraud or Suppression

For periods to which it applies, Section 73 deals with tax not paid, short paid, erroneously refunded or input tax credit wrongly availed or utilised for reasons other than fraud, wilful misstatement or suppression of facts to evade tax.

The section contains separate provisions dealing with pre-notice payment, payment after notice, penalty and the time limit for completion of proceedings.

Each case should be analysed according to the tax period and version of the statutory provisions applicable to that period.

Section 74 — Fraud, Wilful Misstatement or Suppression Cases

For periods up to FY 2023-24, Section 74 deals with specified demand cases involving allegations of fraud, wilful misstatement or suppression of facts to evade tax.

Such allegations can have significant penalty and limitation consequences.

A taxpayer receiving a Section 74 notice should therefore examine whether the notice establishes the factual basis for the allegation rather than assuming that use of the statutory label itself proves fraud or suppression.

Why the Financial Year Now Matters

The distinction between the older Sections 73 and 74 framework and the newer Section 74A framework makes the financial year particularly important.

As a broad statutory position:

Sections 73 and 74 apply to determination relating to periods up to FY 2023-24; and
Section 74A applies to determination relating to FY 2024-25 onward.

The current consolidated CGST Act can be referred to through the India Code.

Section 74A for FY 2024-25 Onward

Section 74A introduced a new determination framework for tax not paid, short paid, erroneously refunded or input tax credit wrongly availed or utilised for Financial Year 2024-25 onward.

It is therefore important that new GST demand matters are not analysed solely by applying the older Section 73 and Section 74 structure.

Unified Determination Framework

Section 74A provides a common determination provision while retaining different penalty consequences depending upon whether the case involves fraud, wilful misstatement or suppression of facts to evade tax.

The proceeding may concern:

tax not paid;
tax short paid;
erroneous refund; or
input tax credit wrongly availed or utilised.

The taxpayer should analyse both the underlying tax issue and the nature of the allegation made by the department.

Notice and Order Timelines under Section 74A

Section 74A provides a limitation framework linked to the due date for the annual return for the relevant financial year or the date of erroneous refund, as applicable.

The provision prescribes a period of 42 months for issuance of the notice in the circumstances covered by the section.

It also prescribes a separate period for passing the adjudication order after issuance of the notice, subject to the statutory provisions regarding extension and exclusions.

Limitation should nevertheless be computed case-by-case because statutory exclusions, court stays or other provisions may affect the calculation.

Penalty Depends on the Nature of the Default

Although Section 74A creates a common determination framework, penalty consequences continue to differ depending upon whether the case is an ordinary non-fraud case or involves fraud, wilful misstatement or suppression of facts to evade tax.

The taxpayer should therefore separately analyse:

tax liability;
interest;
penalty provision;
factual basis for any fraud or suppression allegation;
availability of payment-based closure provisions; and
applicable timelines.

DRC Forms in GST Demand Proceedings

GST demand and adjudication proceedings frequently involve forms prescribed under Rule 142 of the CGST Rules.

The form should not be reviewed in isolation from the detailed notice or order to which it relates.

FORM GST DRC-01A

FORM GST DRC-01A may be used for communication of a liability ascertained by the proper officer before issuance of the formal show cause notice in cases covered by the applicable provisions.

The taxpayer should determine whether:

the proposed liability is factually correct;
the underlying reconciliation has been performed;
payment is appropriate; or
a submission should be made disputing the proposed liability.

A pre-notice communication can be an important opportunity to identify factual errors before formal adjudication begins.

FORM GST DRC-01 and DRC-06

FORM GST DRC-01 is used as the prescribed electronic summary accompanying specified show cause notices under the demand framework.

The substantive notice and annexures should be examined together with DRC-01.

A reply to a show cause notice may be furnished through FORM GST DRC-06 in accordance with Rule 142.

The official form specifically provides for the taxpayer’s reply, supporting documents and option relating to personal hearing.

FORM GST DRC-07 and DRC-08

FORM GST DRC-07 is the prescribed summary of the adjudication order and records the demand determined by the proper officer.

Where an order contains an apparent error that qualifies for rectification under the applicable provisions, the rectification procedure and FORM GST DRC-08 may become relevant.

Receipt of DRC-07 should prompt immediate review of the detailed adjudication order, appeal limitation, admitted and disputed amounts, and any recovery implications.

Reply to GST Notice and Show Cause Notice

A strong GST notice response should answer the specific allegations made by the department rather than provide generic explanations or large volumes of documents without context.

First Review the Notice and Proceedings History

Before drafting the reply, the taxpayer should review:

notice date;
response deadline;
financial year and tax periods;
section invoked;
DRC or ASMT form;
previous scrutiny or audit correspondence;
allegations made;
tax computation;
documents relied upon by the department; and
whether a personal hearing has been offered or should be requested.

A complete chronology helps avoid inconsistent submissions between scrutiny, audit, adjudication and appeal.

Prepare Reconciliations and Documentary Evidence

Where the dispute involves return or accounting differences, the response should be supported by reconciliations.

Depending upon the issue, these may include:

GSTR-1 versus GSTR-3B;
GSTR-3B versus books of account;
GSTR-2B versus purchase register;
financial statements versus GST turnover;
RCM liability reconciliation;
e-way bills versus invoices;
export invoices versus GST returns;
shipping bills and Customs data;
credit notes and debit notes;
electronic credit ledger; and
electronic cash ledger.

For preventive reconciliation and compliance review, businesses may also refer to our GST Audit Checklist.

Prepare Issue-Wise Legal Submission and Hearing Notes

The written reply should ideally deal with every issue separately.

A structured submission may contain:

brief background;
chronology;
issue raised by the department;
taxpayer’s factual position;
reconciliation or computation;
supporting documents;
relevant GST provisions;
notifications or circulars;
judicial authorities, where relevant;
request for personal hearing; and
specific relief requested.

Documents should be indexed and cross-referenced to the written submission wherever possible.

GST Adjudication Orders, Demand and Recovery

After considering the show cause notice, taxpayer’s reply, documents and hearing, the proper officer may pass an adjudication order determining the liability.

Review of the Adjudication Order

An adverse GST order should be reviewed immediately to identify:

issues confirmed;
issues dropped;
tax determined;
interest;
penalty;
credit or payment already considered;
reasoning adopted by the officer;
whether submissions and evidence were considered;
DRC-07 demand summary;
rectification issues;
appealability; and
appeal limitation.

Merely reviewing the final demand figure is insufficient because the reasoning in the order determines the grounds required in appeal.

Demand, Recovery and Rectification

Where the taxpayer accepts the order, the applicable demand and payment requirements should be complied with.

Where the order is disputed, the taxpayer should promptly evaluate:

rectification for an apparent mistake;
statutory appeal;
required pre-deposit;
effect of appeal on recovery;
payment of admitted liability; and
other remedies available under GST law.

Delay in reviewing an order can reduce the time available for preparing an effective appeal.

First Appeal under Section 107

Section 107 of the CGST Act provides the statutory framework for appeal to the first Appellate Authority against eligible decisions or orders.

The appeal against a demand order is filed electronically in the prescribed form, including FORM GST APL-01, through the GST Portal.

Time Limit for Filing GST First Appeal

A taxpayer aggrieved by an appealable decision or order may generally file an appeal within three months from the date of communication of the order.

The Appellate Authority has limited power to condone delay for the additional period permitted by the statute where sufficient cause is established.

The official filing procedure can be reviewed in the GST Portal guidance on filing an appeal against a demand order.

Pre-Deposit and Effect on Recovery

A first GST appeal requires payment of the admitted amount and the applicable statutory pre-deposit in relation to the disputed tax.

The current GST Portal guidance describes the prescribed first-appeal pre-deposit as 10% of the disputed tax, subject to the statutory provisions and applicable limits.

Once the applicable conditions for appeal are satisfied, the balance disputed demand receives the treatment prescribed under the GST framework.

Grounds of Appeal, Statement of Facts and Evidence

An effective GST appeal should not merely state that the adjudication order is incorrect.

The appeal package should ordinarily include:

copy of the impugned order;
demand details;
chronology of proceedings;
statement of facts;
issue-wise grounds of appeal;
supporting evidence;
reconciliations;
copies of material submissions filed before the adjudicating authority;
applicable legal authorities;
proof of admitted tax and pre-deposit; and
condonation application, where applicable.

Grounds should be drafted after examining both the show cause notice and the adjudication order so that procedural and substantive issues are appropriately preserved.

GSTAT Appeals and Further Litigation

The Goods and Services Tax Appellate Tribunal (GSTAT) is the second appellate forum under the GST framework for appeals against eligible orders passed by the Appellate or Revisional authorities.

GSTAT is operational and provides online facilities including e-filing, case status, cause lists and orders through its official portal.

Appeal before GSTAT under Section 112

Section 112 governs appeals to the GST Appellate Tribunal against eligible orders.

The taxpayer should review:

first appellate order;
issues decided against the taxpayer;
issues decided in the taxpayer’s favour;
statutory limitation;
maintainability;
pre-deposit requirements;
supporting evidence;
questions of fact and law; and
electronic filing requirements.

The current GSTAT framework can be accessed through the official GST Appellate Tribunal portal.

Preparing a GSTAT Appeal

Tribunal proceedings require a complete and organised record because the dispute has generally already passed through adjudication and first appeal.

Preparation may involve:

review of complete assessment or adjudication record;
review of first appellate order;
drafting grounds of appeal;
preparation of factual chronology;
compilation of paper book;
written submissions;
case-law research;
reconciliation statements;
additional applications, where maintainable; and
hearing preparation.

Consistency with the factual record created before the lower authorities is particularly important.

High Court and Supreme Court Matters

Depending upon the nature of the GSTAT order, statutory provisions and issues involved, further proceedings may lie before the appropriate higher judicial forum.

Such matters generally require close coordination between tax professionals and experienced legal counsel.

EzyBiz India can assist with the tax computations, factual chronology, reconciliation, documentary record and coordination required for higher GST litigation while legal representation is undertaken by the appropriate advocate or counsel.

How EzyBiz India Assists with GST Assessment & Litigation

EzyBiz India provides integrated assistance covering the factual, accounting, tax and procedural aspects of GST disputes.

GST Assessment and Show Cause Notice Support

Depending upon the matter, our services may include:

review of GST notice;
review of ASMT and DRC forms;
identification of applicable statutory provision;
limitation review;
GST return reconciliation;
turnover reconciliation;
input tax credit reconciliation;
GSTR-2B review;
RCM reconciliation;
classification and GST-rate analysis;
place-of-supply analysis;
export transaction review;
preparation of tax computation;
preparation of documentary evidence;
drafting reply to scrutiny or show cause notice;
preparation of hearing notes; and
representation support before GST authorities.

GST Appeal and GSTAT Support

For appellate matters, our assistance may include:

review of adjudication order;
review of DRC-07;
appeal limitation analysis;
pre-deposit computation;
preparation of statement of facts;
drafting grounds of appeal;
compilation of documentary evidence;
preparation of issue-wise reconciliations;
written submissions;
case-law research;
paper-book support;
first appellate representation;
GSTAT appeal preparation;
GSTAT documentation and e-filing support; and
coordination with advocates and counsel where required.

Support for Foreign-Owned and Multinational Businesses

Foreign-owned businesses may face additional GST disputes involving:

cross-border services;
import of services;
export of services;
related-party transactions;
intercompany charges;
management and support services;
reimbursements;
place of supply;
reverse charge;
input tax credit;
transfer pricing-related invoicing from a GST perspective; and
refund claims.

Where the dispute overlaps with international tax or transfer pricing, businesses may also refer to our International Tax and Transfer Pricing Services in India.

For broader regulatory support, visit our Tax and Regulatory Advisory Services in India.

Frequently Asked Questions on GST Assessment & Litigation

What should I do after receiving a GST notice?

First identify the section, tax period, response deadline, allegations, amount proposed and documents relied upon by the department. The underlying GST returns, books, invoices, GSTR-2B, electronic ledgers and previous departmental correspondence should then be reviewed before a response is filed.

A notice should be answered issue-wise with appropriate reconciliations and supporting evidence rather than with a generic response.

What is the difference between GST scrutiny and GST assessment?

Scrutiny under Section 61 involves examination of GST returns and related information for discrepancies. The taxpayer is given an opportunity to explain the differences.

Assessment provisions such as Sections 62, 63 and 64 deal with determination of tax liability in specified circumstances. A scrutiny proceeding may also lead to other proceedings if the discrepancy is not satisfactorily resolved.

Which sections govern GST demand proceedings now?

For determination relating to periods up to FY 2023-24, Sections 73 and 74 remain relevant depending upon the nature of the allegation.

For FY 2024-25 onward, Section 74A provides the principal determination framework for tax not paid or short paid, erroneous refund and input tax credit wrongly availed or utilised.

What is FORM GST DRC-01?

FORM GST DRC-01 is the electronic summary accompanying specified show cause notices under the GST demand framework.

The detailed show cause notice and its annexures remain critical and should be reviewed together with DRC-01 before preparing the reply.

What is FORM GST DRC-07?

FORM GST DRC-07 is the prescribed summary of the adjudication order recording the tax, interest, penalty and other amounts determined by the proper officer.

After receiving DRC-07, the taxpayer should review the complete adjudication order and immediately determine whether payment, rectification, appeal or another remedy is appropriate.

How much time is available to file the first GST appeal?

A taxpayer may generally file an appeal under Section 107 within three months from communication of the appealable decision or order.

The Appellate Authority has limited statutory power to condone delay for the further period permitted under Section 107 where sufficient cause is established.

Is the GST Appellate Tribunal operational?

Yes. The Goods and Services Tax Appellate Tribunal is operational and provides online facilities for e-filing of appeals, case tracking, cause lists, notices and orders through the official GSTAT portal.

Related Services, Official References and Professional Information

Related Services

GST and Indirect Tax Advisory Services in India – GST advisory, assessments, notices, appeals, refunds and litigation support.
GST Audit Services in India – Assistance with departmental GST audits, audit notices, reconciliations and audit observations.
GST Refund Services in India – Assistance with RFD-01, GST refund claims, refund notices and refund appeals.
GST Registration Services in India – Assistance with GST registration and related registration matters.
GST Audit Checklist – Practical review of GST returns, ITC, books, reconciliations and supporting records.
E-Way Bill under GST – Guidance on e-way bill compliance and related GST issues.
Tax and Regulatory Advisory Services in India – Integrated tax, regulatory, assessment and litigation services.

Received a GST notice, show cause notice, DRC-01, DRC-07 or adverse GST order? Contact EzyBiz India for professional review of the notice, response deadline, disputed issues, reconciliations and available course of action.

Official References

Prepared By

EzyBiz India Consulting LLP

EzyBiz India Consulting LLP is an integrated business, tax and regulatory consulting firm providing assistance in GST, income tax, international tax, transfer pricing, FEMA, corporate compliance, audit support, accounting and India market-entry matters.

Reviewed By

Anil Agrawal, Chartered Accountant
Founder, EzyBiz India Consulting LLP

Chartered Accountant with more than 20 years of professional experience in taxation, GST, assessment, litigation, regulatory compliance, accounting, audit support and business advisory matters for Indian and international businesses.

Last Updated: September 2026

Disclaimer

The information provided on this page is for general informational and educational purposes only and should not be considered legal, tax, accounting or regulatory advice.

GST scrutiny, assessment, show cause proceedings, tax demands, penalty, interest, appeals and litigation depend upon the applicable financial year, nature of the transaction, statutory provisions, rules, notifications, circulars, judicial decisions, procedural requirements and facts of the particular case.

In particular, the applicable demand provision may differ according to the relevant financial year. Sections 73 and 74 apply to specified proceedings relating to periods up to FY 2023-24, while Section 74A applies to determination relating to FY 2024-25 onward.

Limitation periods, pre-deposit requirements, appeal procedures, portal functionality and GSTAT procedures may change. Taxpayers should review the actual notice or order and the law applicable to the relevant period before filing a reply, making payment, admitting liability or pursuing an appellate remedy.

Professional advice should be obtained after considering the specific facts, records, notices, orders and procedural stage of each matter.