Scrutiny notices, show cause notices, cancellation and revocation — answered on time and on the record.
A GST notice has a reply window measured in days, and the window is what decides the outcome far more often than the merits do. An unanswered ASMT-10 becomes a DRC-01; an unanswered DRC-01 becomes an ex parte order under Section 73 or 74 with tax, interest and penalty confirmed; and by then your options narrow to an appeal with a pre-deposit. We read the notice, work out what the department has actually matched, and file the reply with the evidence attached before the date runs out.
The notices you are most likely to receive
Form
What it is
Typical window
GSTR-3A
Default notice for non-filing of returns
15 days
ASMT-10
Scrutiny notice pointing to discrepancies between GSTR-1, GSTR-3B and GSTR-2B
Usually 30 days; reply in ASMT-11
DRC-01A
Intimation of tax ascertained before a formal show cause notice — the chance to pay or explain
As specified; reply in Part B
DRC-01
Show cause notice under Section 73 or 74
30 days; reply in DRC-06
REG-03
Query on a registration application
7 working days; reply in REG-04
REG-17
Show cause notice for cancellation of registration
7 working days; reply in REG-18
ADT-01
Notice of departmental audit under Section 65
15 days' advance notice of audit
Most Chennai scrutiny notices come from three mismatches. Outward supply in GSTR-1 not matching tax paid in GSTR-3B; input tax credit claimed in 3B exceeding what appears in GSTR-2B; and turnover per GST returns not reconciling with turnover per the income tax return or Form 26AS. If you can reconcile these three before you reply, most notices resolve without a demand.
How we handle a notice
Read the notice properly. Section quoted, period covered, amount proposed, the officer's jurisdiction and the exact reply date. A notice under Section 74 alleging suppression carries a much longer limitation and a heavier penalty than one under Section 73, and the reply has to address the allegation of intent, not just the arithmetic.
Reconcile. GSTR-1 against GSTR-3B, 3B against 2B, and the GST turnover against the books and the income tax return, for the period under notice.
Assemble evidence. Invoices, e-way bills, transport documents, bank statements showing payment to the supplier, and the supplier's filing status where credit is disputed.
Draft and file. Reply filed on the portal in the prescribed form within the window, with a covering submission that sets out the legal position and annexes the reconciliation.
Personal hearing. Attended where offered. Never waive it — an order passed without a hearing having been offered is defective, and an order passed after a hearing you skipped is not.
Cancellation and revocation
Registrations are cancelled for continuous non-filing, for non-commencement of business, or on the department's own motion after a REG-17 notice. The consequences bite immediately: you cannot issue a tax invoice, your customers cannot claim credit on your supplies, and e-way bills cannot be generated.
Revocation is applied for in Form REG-21 within 90 days of the cancellation order, and the period is extendable by the Commissioner or Additional Commissioner on sufficient cause.
All pending returns up to the effective date of cancellation must be filed, with tax, interest and late fee paid, before revocation is granted.
Where the cancellation was retrospective, returns for the whole retrospective period fall due.
GSTR-10, the final return, is due within three months of cancellation or of the cancellation order, whichever is later. It is missed routinely, and the late fee accrues until it is filed.
Voluntary cancellation is applied for in REG-16, and is the right route when a business has genuinely ceased — leaving a dormant registration unfiled is what produces the cancellation and the arrears in the first place.
Amendments that prevent notices
A surprising share of notices trace back to stale registration particulars — an address the business left two years ago, a director who resigned, a bank account that was closed. Core field amendments (legal name, principal place of business, addition or removal of partners or directors) are filed in REG-14 and require departmental approval; non-core fields are auto-approved. Keeping these current is cheaper than explaining them later.
If an order has already been passed, the route is an appeal in Form APL-01 within three months of communication of the order, with a pre-deposit of 10% of the disputed tax. Where the order is ex parte for non-appearance, a rectification application or a writ on natural justice grounds is sometimes available. Act quickly, because the appeal limitation is short and only condonable by a further month.
Not necessarily, but the burden is on you. Section 16(2)(aa) makes credit contingent on the invoice appearing in your GSTR-2B, so the technical position favours the department. What has helped in practice is documentary proof of a genuine transaction plus payment to the supplier through banking channels, and pursuing the supplier to file. Courts have taken differing views; the strength of your evidence decides the outcome.
The 90-day window is extendable on sufficient cause, and amnesty schemes have periodically reopened the door for older cancellations. Where revocation is no longer available, the practical route is a fresh registration plus filing GSTR-10 and clearing the old dues, since the old liability follows the PAN.
Only if the computation is right. Paying under DRC-03 in response to a pre-notice intimation closes the proceeding and avoids penalty, which is attractive when the demand is correct. Where the demand rests on a mismatch you can reconcile, paying it concedes a position you did not owe. Reconcile first, then decide.