Home / Blog / GST DRC-01 vs DRC-01A: procedure and…
GST · Notices & appealsGST DRC-01 vs DRC-01A: procedure and legal differences
DRC-01A tells you the tax the officer has worked out before a formal notice; DRC-01 is the summary of the show cause notice itself. The response, the stakes and the time limits are different. Here is how each works and how to respond.
Under GST, demand proceedings move in stages. Rule 142 of the CGST Rules prescribes the forms: DRC-01A (intimation of tax ascertained) and DRC-01 (summary of show cause notice), followed by DRC-06 (reply) and DRC-07 (order).
Side-by-side
| Point | DRC-01A | DRC-01 |
|---|---|---|
| Nature | Pre-show-cause intimation | Summary of the show cause notice under Section 73/74/74A |
| Legal effect | Opportunity to pay or object; no demand yet | Formal start of demand proceedings |
| Mandatory? | Discretionary after 2022 amendment | Required (with the detailed SCN) |
| Reply | Part B of DRC-01A | DRC-06 |
| Payment | Through DRC-03 | Through DRC-03 (and inform) |
| Effect of payment | Officer issues DRC-04 acknowledging; SCN not issued for amount paid | Non-fraud: within 60 days – no penalty; fraud: reduced penalty |
| Time | As given (often 7–15 days) | As given (typically 30 days) |
How to respond to DRC-01A
- Check the computation and period.
- If correct, pay through DRC-03 with interest (and penalty if indicated) and file Part B.
- If incorrect, file objections in Part B with reconciliation and evidence.
- Partial acceptance: pay the accepted part and object to the rest.
An unanswered DRC-01A almost always leads to DRC-01.
How to respond to DRC-01
- Download the SCN and annexures; note the reply date and hearing date.
- Prepare a detailed reply: facts, point-wise rebuttal, legal provisions, circulars, case law, and documents.
- Challenge jurisdiction or limitation if applicable (e.g. SCN beyond time under Section 73/74/74A).
- Request a personal hearing – mandatory under Section 75(4) where requested or where an adverse decision is contemplated.
- File DRC-06 on the portal and keep acknowledgement.
- Consider paying the accepted portion within 60 days to avoid penalty.
Worked example
Example: Vista Enterprises receives DRC-01A for FY 2022-23 proposing ₹6,00,000 tax for excess ITC compared with GSTR-2A.
- Vista Enterprises's reconciliation shows ₹4,20,000 relates to suppliers who filed late (visible in later 2A) and ₹1,80,000 is ITC on cars (blocked).
- Vista Enterprises pays ₹1,80,000 + interest through DRC-03 and objects to ₹4,20,000 with supplier-wise working.
- The officer accepts the objection; no SCN issued. Had Vista Enterprises ignored DRC-01A, a DRC-01 for ₹6,00,000 plus penalty would have followed.
Example 2: If a DRC-01 under Section 73 had been issued for ₹6,00,000 on 1 August 2026, paying ₹1,80,000 + interest by 30 September 2026 (within 60 days) would close that part with no penalty, while the rest is contested.
Limitation
The SCN must be issued within the time limits: - Section 73 (FY 2017-18 to 2023-24): at least 3 months before the 3-year limit for the order (from due date of annual return). - Section 74: at least 6 months before the 5-year limit. - Section 74A (FY 2024-25 onwards): within 42 months from the due date of the annual return; order within 12 months of the SCN. See Sections 73, 74 and 74A.
Common mistakes
- Ignoring DRC-01A.
- Paying through DRC-03 without linking to the notice (use DRC-03A where needed).
- Not requesting a personal hearing.
- Missing limitation arguments.
Key takeaway
DRC-01A is the chance to settle or object before a formal demand; DRC-01 is the demand itself. Respond to both with reconciliations, pay what is due early to save penalty, and contest the rest. Our GST notice team drafts DRC-01A objections and DRC-06 replies.
Official references
Provisions discussed (summaries in our Law Library):
- CGST Rules, 2017 – Section 142: Notices and orders (DRC forms)
Official sources to verify the current text, notifications and circulars:
Frequently asked questions
Is DRC-01A mandatory before a show cause notice?
After the amendment to Rule 142(1A) in 2022, issuing DRC-01A is discretionary ("may"). Many officers still issue it, and it gives a chance to pay or object before the SCN.
How do I reply to DRC-01A?
In Part B of DRC-01A – either pay the tax fully or partly through DRC-03, or file objections with reasons and documents.
How do I reply to DRC-01?
File a reply in DRC-06 within the time given (typically 30 days), with documents, and request a personal hearing. You may also pay through DRC-03 and inform the officer.
Does paying after DRC-01 reduce penalty?
In non-fraud cases (Section 73 or the non-fraud limb of 74A), paying tax with interest within 60 days of the show cause notice ends the proceedings without penalty.
Can I ask for more time to reply to DRC-01?
Yes. Request an adjournment with reasons; Section 75(5) allows up to three adjournments during proceedings.
What if the DRC-01 is issued without a detailed notice?
DRC-01 is a summary; a detailed show cause notice must accompany it. Courts have set aside demands based only on summary forms without a proper notice.
Is a hearing mandatory before an order?
Yes, where requested in writing or where an adverse decision is contemplated (Section 75(4)).
This article is general information on the law as on 10 November 2026, written for educational purposes. It is not professional advice for your case. Section numbers under the Income-tax Act, 2025 should be confirmed with the official section mapping on the Income Tax Department website before use in filings.
Have a tax, GST or business question?
Call, WhatsApp or email CA Dilbagh Singh and team, from Delhi, anywhere in India or abroad.