Talk to an Expert
Talk to an Expert ✆ +91 945 945 6700
Trusted by 10,000+ Businesses

DRC-01 and DRC-01A Response and Reply Service in 2026

Reviewed by CA and CS Team, Patron Accounting LLP ICAI & ICSI Registered| 15+ Years Experience| Last Updated: Verify Credentials →

Documents: DRC-01A pre-notice intimation or DRC-01 SCN, departmental annexure, GSTR-1/3B/9 for the period, GSTR-2B, books of account, reconciliation working files, and prior compliance history.

Fees: Starting from INR 9,999 (Exl GST and Govt. Charges) - per DRC form engagement covering Part A through closure.

Eligibility: Every registered taxpayer who has received a DRC-01A Part A pre-notice intimation or a DRC-01 formal Show Cause Notice under Section 73, 74, or 74A of the CGST Act.

Timeline: Day-1 analysis within 24 hours; DRC-01A Part B reply within 15-21 days; DRC-06 reply within 30 days of SCN (extendable); DRC-03 payment within statutory windows for penalty optimization.

10,000+ Businesses Served | 4.9 Google Rating | 1,500+ DRC Form Responses Filed | Rs 200 Crore+ in Demand Optimized via Pre-SCN DRC-03 Route

15+ YearsIndustry Experience
CA & CSCertified Experts
4.9
Based on 500+ reviews

Get Free Consultation

Talk to a CA/CS expert today

🇮🇳 +91

Our team will get back to you shortly. No spam.

Real Stories from Real People

Hear how teams across industries use Patron to save time, cut costs, & stay in control.

Fetching latest Google reviews…

I've had an outstanding experience working with my CA - Patron Accounting. Their professionalism, attention to detail, and timely communication made the entire process seamless and stress-free.

I'm glad that I was able to connect with Patron. They took the minimum time to do the calculations based on the details provided by me and were really helpful throughout the process.

Really a fantastic experience with Patron Accounting especially Shubham, he was extremely great. Knowledgeable person who deserves the 5 star for smooth handling of all documentation.

Patron Accounting gives the best service related to all account handling of our firm. I am blessed and extremely happy that Patron Accounting assigned us a dedicated point of contact.

I have called Patron to file ITR for my 5 family members. I worked with Shubham Junjunwala and Amin Jain. It was a smooth process. They understand basics very well and respond promptly.

From the very beginning, their approach has been highly professional, prompt, and solution-oriented. Every interaction reflected their deep knowledge and commitment to helping clients.

Very proficient and professional staff. Do fantastic job and instant response. Strongly recommended engaging them for all accounting needs specially for startups and growing businesses.

I contacted them to file the ITR. Shubham was the POC for me and he was really very professional and giving prompt responses. Highly recommend them for tax and compliance work.

Sunny Ashpal
Sunny Ashpal
Director - Demandify Media
Anjanay Srivastava
Anjanay Srivastava
Founder - Hunarsource Consulting
10,000+Businesses ServedGST compliance and litigation support across India.
15+Years ExperienceDeep expertise in IP registration, GST & business compliance.
50,000+Documents FiledReturns, appeals, and filings handled accurately.
4.9★Client RatingTrusted by entrepreneurs, startups, and growing businesses.
ISO CertifiedProfessional standards and documented processes.
SSL SecureYour financial and business data is fully protected.

DRC-01 and DRC-01A Response at a Glance

📌 TL;DR - DRC-01 and DRC-01A Response Services at a Glance

DRC-01A is a pre-Show Cause Notice intimation issued under Section 73(5), 74(5), or 74A(8) of the CGST Act, giving the taxpayer an opportunity to pay tax and interest voluntarily via Form DRC-03 with reduced or zero penalty - non-fraud cases attract ZERO penalty under Section 73(5), fraud cases attract 15 percent under Section 74(5). DRC-01A has three parts: Part A (officer intimation), Part B (taxpayer reply), and Part C (closure order). DRC-01 is the formal Show Cause Notice summary under Rule 142(1)(a), starting the rigid 30-day reply clock via Form DRC-06. Once DRC-01 is issued, DRC-01A Part B cannot be filed. Form DRC-03 has 11 Cause-of-Payment options and is the central voluntary-payment tool - it cannot be amended or withdrawn once filed, so the correct Cause selection is critical. Partial payment against an SCN is not allowed; saved DRC-03 applications are purged after 15 days; DRC-03A maps payments to specific demand orders retroactively. The 30-day window from DRC-01 issuance is the single most important timeline in the GST notice framework. Patron engagement at Rs 9,999 onwards covers Day-1 analysis, Cause-of-Payment strategy, DRC-03 filing, and DRC-06 reply drafting.

DRC-01 and DRC-01A are the two most consequential forms in the GST demand and recovery framework - the difference between an outcome at 0 percent penalty and one at 100 percent penalty often comes down to how these forms are responded to within their statutory windows. DRC-01A is the informal pre-Show Cause Notice intimation under Section 73(5), 74(5), or 74A(8) - the officer signals an issue but has not yet committed to formal SCN proceedings, and the taxpayer can file Part B explaining the position, accept partially with DRC-03, or accept fully and close via Part C.

DRC-01 is the formal Show Cause Notice summary under Rule 142(1)(a) - the 30-day clock for the DRC-06 reply starts, and DRC-03 voluntary payment is still available but at an elevated penalty cost. Once 30 days from DRC-01 pass, the DRC-03 reduced-penalty route closes entirely, escalating to a DRC-07 adjudication order and the Section 107 appellate route. This is the form-procedural workflow engagement under our GST Notice umbrella, complementing the substantive defence engagements for Section 73 and Section 74. With 10,000+ businesses served, 1,500+ DRC form responses filed, and Rs 200 crore plus in demand optimized, Patron Accounting LLP runs the full DRC lifecycle with 24-hour Day-1 response and strategic Cause-of-Payment discipline.

Content is reviewed quarterly for accuracy.

What Are DRC-01 and DRC-01A?

DRC-01 (Demand and Recovery 01) is the formal summary of the Show Cause Notice issued by the proper officer under Rule 142(1)(a) of the CGST Rules 2017, along with the detailed SCN, when proceedings are initiated under Section 73, 74, or 74A of the CGST Act for tax not paid, short paid, erroneously refunded, or input tax credit wrongly availed.

DRC-01A is the pre-Show Cause Notice intimation issued under Section 73(5), 74(5), or 74A(8) before the formal DRC-01 - it gives the taxpayer an opportunity to pay tax and interest voluntarily via Form DRC-03 with significantly reduced penalty (zero percent under Section 73, 15 percent under Section 74) and close the proceedings before they escalate. DRC-01A has three parts - Part A (officer intimation with the alleged discrepancy and quantum), Part B (taxpayer reply, fully or partially aggrieved with DRC-03), and Part C (closure order issued if Part B is accepted).

DRC-01A is NOT mandatory before DRC-01 - the officer has discretion, particularly in fraud cases under Section 74 where direct DRC-01 issuance is common. Once DRC-01 is issued, the DRC-01A Part B reply window closes and the formal 30-day DRC-06 reply clock starts. Form DRC-03 is the voluntary payment form used at both stages, with 11 different Cause-of-Payment selections affecting how the payment is processed and credited.

Key Terms for DRC-01 and DRC-01A Response:

  • Form DRC-01A (Pre-SCN Intimation): Informal intimation under Section 73(5), 74(5), or 74A(8) before the formal DRC-01 SCN. Three parts - Part A, B, C. Not mandatory; officer discretion.
  • DRC-01A Part A: The officer intimation - alleged discrepancy, period, tax/interest/penalty quantum, statutory provision, and material relied upon.
  • DRC-01A Part B: The taxpayer reply, filed electronically. Three paths: fully aggrieved (explanation only), partially aggrieved (DRC-03 for accepted portion + explanation for balance), or full acceptance with DRC-03.
  • DRC-01A Part C: The closure order if Part B is accepted - formal disposal of the pre-SCN proceeding on the same grounds.
  • Form DRC-01 (SCN Summary): The formal Show Cause Notice summary under Rule 142(1)(a) - SCN reference number, section (73/74/74A), period, demand bifurcation, and the reply deadline (typically 30 days).
  • Form DRC-02 (Statement Summary): Summary of statement for subsequent periods on similar grounds under Section 73(3) or 74(3) - deemed service without a separate SCN for each period.
  • Form DRC-03 (Voluntary Payment): Form for voluntary payment of tax, interest, and penalty - 11 Cause-of-Payment options including Voluntary, SCN, Intimation DRC-01A, and mismatch causes.
  • Cause of Payment - SCN: The DRC-03 option requiring the SCN reference number and issue date; the system validates the date is within the last 30 days.
  • Cause of Payment - Intimation DRC-01A: Used when paying in response to a pre-notice intimation - triggers Section 73(5) zero-penalty closure or Section 74(5) 15-percent closure.
  • Form DRC-04 (Payment Acknowledgement): Issued by the officer on receipt of DRC-03 payment - the basis for proceedings closure.
  • Form DRC-05 (Closure on Payment): Order under Section 73(8) or 74(8) concluding proceedings on full voluntary payment.
  • Form DRC-06 (SCN Reply): The reply to the DRC-01 SCN under Section 73(2) or 74(2), filed electronically within 30 days (extendable).
  • Form DRC-07 (Order Summary): The adjudication order summary under Section 73(9) or 74(9) - triggers the Section 107 appeal route within 3 months with a 10 percent pre-deposit.
  • Form DRC-08 (Rectification): Rectifies or withdraws an earlier DRC-07 under Section 161 for apparent errors, within 6 months of the order.
  • Form DRC-03A (Payment Mapping): Retroactively maps a DRC-03 payment to a specific demand order when the original Cause was incorrectly selected.
  • 30-Day Reply Window: The window from DRC-01 service for the DRC-06 reply or reduced-penalty DRC-03 payment (10 percent Section 73 / 25 percent Section 74). Once it lapses, the reduced-penalty route closes.
  • No Partial Payment Against SCN: The portal does not allow partial DRC-03 payment against a specific SCN - it is all or none.
APL-05 DRC-01 and DRC-01A Response
Reply Window 30 Days from DRC-01

DRC-01A and DRC-01 Response Decision Framework

The DRC-01A and DRC-01 response decision is the single most consequential strategic call in the GST demand framework - it determines whether the matter closes with zero or reduced penalty, or escalates to full formal proceedings with potentially 100 percent penalty exposure. The framework differs by form stage and statutory section.

DRC-01A Part A Receipt - Three Response Paths

  • Path 1 (Fully Aggrieved): File Part B with a detailed explanation; no DRC-03 payment. The officer may issue Part C closure or escalate to a DRC-01 SCN.
  • Path 2 (Partially Aggrieved): File Part B with explanation plus DRC-03 voluntary payment for the accepted portion (zero penalty Section 73 / 15 percent Section 74), contesting the balance.
  • Path 3 (Full Acceptance): DRC-03 voluntary payment for the full demand at zero penalty (Section 73(5)) or 15 percent (Section 74(5)). The officer issues DRC-05 closure.

DRC-01 Receipt - Four Response Paths

  • Path 1 (Full Contest): File the DRC-06 reply within 30 days addressing every allegation; no DRC-03 payment. Proceeds to hearing and DRC-07 order.
  • Path 2 (Partial Payment + Contest): DRC-03 for the accepted portion (10 percent Section 73 / 25 percent Section 74) within 30 days plus DRC-06 for the balance. The portal does not allow partial payment against the same SCN, so this must be structured carefully.
  • Path 3 (Full Acceptance Within 30 Days): DRC-03 for the full demand at 10 percent (Section 73(8)) or 25 percent (Section 74(8)). The officer issues DRC-05 closure.
  • Path 4 (Beyond 30 Days): The reduced-penalty DRC-03 route is closed. Proceed to DRC-06, hearing, and DRC-07 order - with Section 74(11) penalty at 50 percent within 30 days of the order or 100 percent thereafter.

Strategic Selection Criteria

  • Strength of the departmental allegation - documented evidence versus inference
  • Quantum of demand - manageable cash flow impact versus material
  • Section 75(2) downgrade probability (for Section 74 demands - convert to Section 73 with 10 percent penalty)
  • Time to gather reconciliation evidence versus the 30-day deadline
  • Cash flow versus the Section 107 pre-deposit (10 percent of disputed tax)

Patron Accounting Services for DRC-01 and DRC-01A

ServiceWhat We Do
Day-1 DRC Form Analysis and Strategic Path SelectionWithin 24 hours of receipt - form type identification (Part A intimation or formal SCN), section invoked (73/74/74A), period, demand quantum, and statutory deadlines mapped, with strategic path selection from the 3-path or 4-path framework.
DRC-01A Part B Reply Drafting and FilingA comprehensive Part B reply addressing each allegation, with reconciliation working papers as annexures, case-law citations, and statutory provisions, coordinated with a DRC-03 voluntary payment if partial acceptance is chosen.
DRC-03 Voluntary Payment with Strategic Cause SelectionStrategic Cause-of-Payment selection (Voluntary, SCN-specific within 30 days, or Intimation DRC-01A), section and tax period entry, Act-wise breakdown, filing within the 15-day save window, and DRC-04 acknowledgement tracking.
DRC-06 SCN Reply Drafting and 30-Day Window ManagementA comprehensive DRC-06 reply addressing every allegation with reconciliation, statutory analysis, CBIC circular references, and case law, including Section 75(2) downgrade arguments for Section 74 SCNs, with an extension request where reconciliation needs more time.
DRC-03A Retroactive Payment MappingWhere a prior DRC-03 was filed with the wrong Cause (commonly Voluntary instead of SCN-specific), a DRC-03A application maps the payment to the specific demand order, ensuring a proper offset.
Post-Order DRC-07 Analysis and DRC-08 RectificationOn receipt of the DRC-07 final order - comparison against the SCN and reply, a DRC-08 rectification application under Section 161 for apparent errors, and Section 107 appeal preparation if a substantive contest is needed.
Our Process

How DRC Form Response Works - Step by Step

From the Day-1 form analysis to the post-DRC-07 path decision, here is exactly how Patron Accounting runs an end-to-end DRC form response.

Step 1

Day-1 Form Receipt and Analysis (Within 24 Hours)

On receipt of DRC-01A or DRC-01 on the GST portal (Services then User Services then View Additional Notices/Orders), immediate download and review - form type, section (73/74/74A), period, demand bifurcation, annexures, and the statutory deadline. Engagement scope and timeline locked.

Form identified Deadline mapped
DRC-01
Form Receipt 01
Step 2

Statutory Section and Penalty Mapping

Section 73 (non-fraud): 0% pre-SCN / 10% within 30 days / 10% post-order. Section 74 (fraud): 15% pre-SCN / 25% within 30 days / 50% within 30 days of DRC-07 / 100% beyond. Section 74A (FY 2024-25+) per the applicable sub-section. The penalty cascade is visualised for the client.

Cascade mapped 73/74/74A
0-100%
Penalty Map 02
Step 3

Reconciliation and Evidence Audit

GSTR-1, GSTR-3B, GSTR-2B and GSTR-9 reconciliation for the period, a books-of-account walkthrough, and supplier compliance verification. Each allegation is traced to evidence - genuine, timing-related, factually wrong, or interpretive.

4-way recon Allegations traced
Evidence 03
Step 4

Strategic Path Selection (3-Path or 4-Path)

A client meeting on response strategy - fully contest, partial acceptance plus contest, or full acceptance plus DRC-03 - with an economic analysis of penalty cost across stages, the Section 107 pre-deposit, and cash flow impact.

Path chosen Economics run
Strategy 04
Step 5

DRC-03 Voluntary Payment Filing (If Applicable)

For acceptance scenarios - DRC-03 filing with strategic Cause-of-Payment selection (Voluntary, SCN-specific within 30 days, or Intimation DRC-01A). Section, FY, tax period, and Act-wise breakdown filled accurately; ARN retained; DRC-04 acknowledgement tracked.

Cause correct ARN retained
DRC-03
DRC-03 05
Step 6

DRC-01A Part B or DRC-06 Reply Drafting

For Part B - explanation with annexures. For DRC-06 - a comprehensive reply addressing every allegation with reconciliation, statutory provisions, CBIC circulars, and case law, plus Section 75(2) downgrade arguments for Section 74 SCNs.

Every allegation 75(2) for 74
Reply Draft 06
Step 7

Electronic Filing on the GST Portal

Filing under Services then User Services then View Additional Notices/Orders then View then Case Details then Reply. Supporting documents uploaded (up to 4 files of 5 MB each), submitted via DSC or EVC, with the ARN retained.

Docs uploaded DSC / EVC
Filing 07
Step 8

Personal Hearing Preparation and Attendance (DRC-01 Stage)

If a personal hearing is scheduled - brief preparation with reconciliation evidence, statutory arguments, and case law. Attendance by an authorised CA/CS under Section 116; multiple hearings often required for Section 74 matters.

Section 116 Brief ready
Hearing 08
Step 9

DRC-05 (Closure) or DRC-07 (Adjudication Order)

If the full voluntary-payment route - a DRC-05 closure order concluding proceedings. If the contest route - a DRC-07 adjudication order post-hearing, with analysis of confirmed versus dropped items.

DRC-05 / 07 Items analysed
DRC-05/07
Order 09
Step 10

Post-DRC-07 Path Decision

Three options - pay the confirmed demand (with Section 74(11) 50% penalty if within 30 days), a Section 107 appeal within 3 months with a 10% pre-deposit, or DRC-08 rectification for apparent errors under Section 161.

Section 107 Or rectify
Onward Path 10

Documents and Data Checklist

Have these inputs ready for an efficient DRC form response:

  • DRC-01A (all parts) or DRC-01 SCN with all departmental annexures
  • Any prior ASMT-10 scrutiny notice for the same period (procedural defence)
  • GSTR-1, GSTR-3B, GSTR-9, and GSTR-9C for the disputed period
  • GSTR-2A and GSTR-2B monthly downloads
  • Books of account - trial balance, ledger extracts, journal vouchers
  • Sales register and purchase register for the period
  • Tax invoices, debit notes, credit notes, and e-way bills for disputed transactions
  • Supplier compliance status - GSTR-1 filing record of all challenged vendors
  • Bank statements showing tax payment via cash and ITC utilisation
  • Prior DRC-03 filings with DRC-04 acknowledgements (any earlier voluntary payments)
  • Earlier DRC forms received for the same GSTIN (pattern analysis)
  • Cash flow forecast for the Section 107 pre-deposit (if the appeal route is considered)
  • DSC or EVC credentials for GST portal filing

Common Challenges and Patron Solutions

ChallengeImpactHow Patron Accounting Solves It
Wrong DRC-03 Cause-of-Payment SelectionSelecting "Voluntary" instead of "SCN" or "Intimation DRC-01A" means the payment does not auto-link to the demand order, creating reconciliation issues and potential recovery despite payment. DRC-03 cannot be amended once filed.A pre-filing decision on Cause selection - SCN with manual reference within 30 days, Intimation DRC-01A for pre-SCN, Voluntary only for self-ascertained payments. If a wrong Cause was filed earlier, a DRC-03A retroactive mapping application fixes the linkage. Zero Cause errors in the last 18 months.
30-Day Window Missed - Reduced-Penalty Route ClosedThe DRC-01 SCN starts a rigid 30-day clock for reduced-penalty DRC-03 payment (10 percent Section 73 / 25 percent Section 74). Once it lapses, exposure can jump to 100 percent under Section 74(11) post-order.Day-1 intake with a 30-day countdown auto-tracked. The options decision is finalised by Day-7 to allow Day-21 filing if accepting, with a Day-28 buffer. Zero missed 30-day windows across 1,500 plus engagements.
Partial Payment Against SCN Not Allowed by PortalThe portal forces an all-or-nothing DRC-03 payment against a specific SCN, even when a taxpayer wants to accept some allegations and contest others.Strategic structuring - file DRC-03 as "Voluntary" for the accepted portion before the deadline, then DRC-06 contesting the balance, with DRC-03A mapping if needed. Alternatively, contest the full SCN showing accepted versus contested portions and accept officer reduction at hearing.
DRC-01A Issued for Multiple Years - Strategy MisalignedTaxpayers often receive 4-6 DRC-01A intimations simultaneously (FY 2018-19 through FY 2023-24) and treat them as one matter, confusing per-year deadlines and replies.Year-wise engagement structuring - each DRC-01A is a separate file with its own countdown, strategy, and DRC-03, with pattern analysis across years to present a consistent narrative while meeting per-year procedural requirements.

DRC Form Response Service Fees

Fee ComponentAmount
Patron Accounting Professional FeesStarting from INR 9,999 (Exl GST and Govt. Charges) - per DRC form engagement
DRC-01A Part B Reply with DRC-03 PaymentINR 9,999 - pre-SCN intimation response, voluntary payment optimization
DRC-01 SCN Standard Response (Section 73)INR 14,999 - DRC-06 reply within 30 days, hearing representation
DRC-01 SCN Standard Response (Section 74)INR 19,999 - DRC-06 with Section 75(2) downgrade arguments, hearing
DRC-03 Strategic Filing (No SCN Context)INR 4,999 - Cause-of-Payment selection, computation, filing
DRC-03A Retroactive Payment MappingINR 9,999 - mapping wrongly-filed DRC-03 to a specific demand order
Multi-Year DRC-01A Response (5+ years)INR 49,999+ - year-wise replies plus coordinated strategy across years
DRC-08 Rectification ApplicationINR 14,999 - Section 161 rectification for apparent DRC-07 errors
Tax, Interest, and Pre-DepositBilled separately at actuals - tax via DRC-03, Section 50 interest, and Section 107 pre-deposit (if appeal route)

All fees and charges listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on the volume of work and the complexity involved.

Professional service charges for drafting, filing, and representation are separate from the statutory fees. The exact fee depends on the complexity of the case, disputed amount, and number of hearings required. Contact us for a detailed quote.

Get a free DRC-01 and DRC-01A Response consultation - Call +91 945 945 6700 or WhatsApp us. No-obligation assessment.

Time Taken for DRC Form Activities

StageEstimated Timeline
Day-1 DRC form analysis and path selection1 day (Day 1 of the 30-day window)
Four-way GSTR reconciliation (GSTR-1/3B/2B/9)3-7 days
DRC-01A Part B reply drafting5-10 days (within the DRC-01A window)
DRC-03 voluntary payment filing1 day (after computation)
DRC-06 SCN reply drafting and filing10-15 days (within 30 days of DRC-01, extendable)
DRC-03A retroactive mapping application3-5 days
Personal hearing attendance4-6 hours per hearing
DRC-04 acknowledgement trackingAuto-issued within 1-2 weeks of payment
DRC-05 closure order pursuit1-3 months (officer discretion under Section 73(8)/74(8))
DRC-07 adjudication order3-12 months
DRC-08 rectification application15-30 days (within 6 months of DRC-07)

Standard DRC timeline: DRC-01A Part A receipt to Part C closure is typically 2-4 months; DRC-01 SCN to a DRC-07 order is typically 3-12 months. The DRC-08 rectification window is 6 months from the order - but the single rigid timeline that governs penalty cost is the 30-day window from DRC-01 service.

Key Benefits

Benefits of Professional DRC Form Response

Day-1 Response Capability

Captures the 30-day reduced-penalty window every time, with a countdown auto-tracked from service.

Strategic Cause-of-Payment Selection

Prevents DRC-03 errors that cannot be amended once filed.

Pre-SCN DRC-03 Route Preserved

Zero penalty (Section 73) or 15 percent (Section 74) where the pre-SCN window is still open.

Penalty Cascade Visualization

Helps clients make informed pay-versus-contest decisions across stages.

DRC-03A Retroactive Mapping

Fixes prior DRC-03 errors by mapping the payment to the correct demand order.

Multi-Year DRC-01A Structuring

Year-wise files with a consistent narrative across simultaneous intimations.

Section 75(2) Downgrade Arguments

Built into DRC-06 replies for Section 74 SCNs to cut penalty exposure.

Proven Track Record

Rs 200 crore plus optimized via the pre-SCN route across 1,500+ engagements, with zero missed windows.

Trust Signals and Outcome Proof

10,000+ Businesses Served | 4.9 Google Rating | 50,000+ Documents Filed | 15+ Years of Practice

Trusted by Hyundai, Asian Paints, Bridgestone, and 10,000+ Indian enterprises - listed companies, mid-market corporates, SMEs, manufacturers, traders, service providers, e-commerce sellers, exporters, and small businesses facing DRC form responses across all GST sectors and turnover bands.

Patron has filed 1,500 plus DRC form responses (DRC-01A Part B, DRC-03, DRC-06, DRC-08) across the active client base with Rs 200 crore plus in demand exposure optimized via the pre-SCN voluntary payment route at zero or 15 percent penalty - with zero missed 30-day windows, zero DRC-03 Cause-of-Payment errors in the last 18 months, and an average Day-1 to DRC-03 turnaround under 15 days when the acceptance route is chosen.

With offices in Pune, Mumbai, Delhi, and Gurugram, Patron Accounting serves businesses across India - both in-person and remotely. See our GST notice support in Delhi for local assistance.

DRC-01A vs DRC-01 - Decision Framework

ParameterDRC-01A (Pre-SCN Intimation)DRC-01 (Formal SCN)
Statutory ProvisionSection 73(5) / 74(5) / 74A(8)Rule 142(1)(a) under Section 73/74/74A
Mandatory or DiscretionaryOfficer discretion (not mandatory)Mandatory before adjudication
Parts / Structure3 parts (A, B, C)Single summary form (with detailed SCN)
Reply FormDRC-01A Part B (within window)DRC-06 within 30 days
Reply WindowOfficer-specified (typically 15-30 days)Rigid 30 days (extendable on request)
Voluntary Payment FormDRC-03 (Cause: Intimation DRC-01A)DRC-03 (Cause: SCN, within 30 days)
Pre-SCN Penalty (Section 73)0% (zero) under Section 73(5)N/A - SCN already issued
Pre-SCN Penalty (Section 74)15% under Section 74(5)N/A - SCN already issued
Post-SCN Penalty (Section 73)N/A - pre-SCN stage10% within 30 days; 10% thereafter
Post-SCN Penalty (Section 74)N/A - pre-SCN stage25% within 30 days; 50% within 30 days of DRC-07; 100% beyond
Closure FormDRC-01A Part C (officer order)DRC-05 (on full payment) or DRC-07 (adjudication)
Escalation PathDRC-01 SCN if Part B unsatisfactoryDRC-07 order if DRC-06 unsatisfactory
Strategic WindowBest stage for low-penalty closure30-day clock for reduced penalty

Related Services

  • GST Services - the complete GST services hub covering registration, returns, ITC, refunds, notices and audits.
  • GST Notice - the parent umbrella for all GST notice types.
  • GST Notice for Restaurants - the industry vertical for restaurant DRC cases.
  • GST Returns - the return-level basis for DRC demand notices.

Substantive defence engagements that complement this form-procedural workflow - Section 73 GST Notice (non-fraud SCN defence), Section 74 GST Notice (fraud SCN defence with Section 75(2) downgrade), and ASMT-10 Notice (the Section 61 scrutiny stage before DRC-01A) - are available as part of the integrated GST notice defence backbone.

Legal and Compliance Framework

ElementProvision
Governing ActCentral Goods and Services Tax Act 2017
DRC-01A Pre-SCN IntimationSection 73(5) / 74(5) / 74A(8) CGST Act
DRC-01 SCN SummaryRule 142(1)(a) CGST Rules 2017
DRC-02 Statement SummaryRule 142(2) CGST Rules
DRC-03 Voluntary PaymentRule 142(2) CGST Rules
DRC-04 Payment AcknowledgementRule 142(2) CGST Rules
DRC-05 Closure on PaymentRule 142(3) under Section 73(8) or 74(8)
DRC-06 Reply to SCNRule 142(4) CGST Rules
DRC-07 Summary of OrderRule 142(5) under Section 73(9) or 74(9)
DRC-08 RectificationRule 142(7) under Section 161
DRC-03A Retroactive MappingCBIC Notification CGST (Ninth Amendment) Rules 2021
Penalty - Section 73(5) Pre-SCNNIL
Penalty - Section 73(8) Within 30 Days10% of tax or Rs 10,000
Penalty - Section 74(5) Pre-SCN15% of tax
Penalty - Section 74(8) Within 30 Days25% of tax
Penalty - Section 74(11) Within 30 Days of DRC-0750% of tax (unique to Section 74)
Penalty - Section 74 Beyond 30 Days from Order100% of tax
InterestSection 50 CGST Act - 18% per annum
No Partial Payment Against SCNPortal restriction per Rule 142(2)
Cannot Amend or Withdraw DRC-03Once filed, locked; DRC-03 save window 15 days
Appeal RouteSection 107 - 3 months with 10% pre-deposit
Authorised RepresentationSection 116 CGST Act
AuthorityCBIC and the proper officer

The 30-day window from DRC-01 service is the most rigid statutory timeline in the GST notice framework - once it lapses, the reduced-penalty DRC-03 route closes entirely. The penalty cascade for Section 74 demands is particularly steep: 15 percent pre-SCN, 25 percent within 30 days of the SCN, 50 percent within 30 days of DRC-07, and 100 percent beyond. On a Rs 1 crore tax demand this is the difference between a Rs 1.15 crore and a Rs 2 crore outflow (plus 18 percent interest), with a successful Section 75(2) downgrade saving roughly Rs 90 lakh.

DRC-03 procedural critical points: the Cause of Payment cannot be amended after filing; the SCN Cause requires an issue date within the last 30 days (portal-validated); the Voluntary Cause does not link to a demand order; partial payment against an SCN is not allowed; a saved application is purged after 15 days; and DRC-03A is the corrective tool for retroactive mapping.

Authoritative references: India Code - Sections 73, 74, 74A, 75, 107, 161 CGST Act, CBIC - Rule 142 CGST Rules DRC Forms, CBIC - CGST Ninth Amendment Rules 2021 and Notification 17/2024-CT, and the GST Portal - Notice and Order Services.

What is the difference between DRC-01 and DRC-01A?

DRC-01A is the pre-Show Cause Notice intimation issued under Section 73(5), Section 74(5), or Section 74A(8) of the CGST Act - it gives the taxpayer an opportunity to pay voluntarily via DRC-03 before formal SCN proceedings begin. DRC-01A has three parts - Part A (officer intimation), Part B (taxpayer reply), Part C (closure order). DRC-01A is NOT mandatory before DRC-01. DRC-01 is the formal Show Cause Notice summary issued under Rule 142(1)(a) starting the rigid 30-day reply clock via DRC-06. Once DRC-01 is issued, DRC-01A Part B cannot be filed for the same matter.

What is Form DRC-03 and when should I use it?

Form DRC-03 is the voluntary payment form on the GST portal used to intimate payment of tax, interest, and penalty before issuance of SCN or within 30 days of SCN. It has 11 Cause-of-Payment options including Voluntary, SCN, Annual Return, Audit, Inspection, Scrutiny, Intimation under DRC-01A, GSTR-1 vs 3B mismatch, GSTR-2B vs 3B mismatch, Reconciliation Statement, and Others. Critical: DRC-03 cannot be amended or withdrawn once filed - selecting the correct Cause is essential. Use SCN Cause within 30 days for linkage; use Intimation DRC-01A for pre-SCN payments; use Voluntary for self-ascertained payments.

What is the 30-day window in DRC-01?

The 30-day window from the date of service of DRC-01 SCN is the most critical timeline in the GST demand framework. Within this window, the taxpayer can file DRC-03 voluntary payment at the reduced post-SCN penalty rate - 10 percent under Section 73(8) or 25 percent under Section 74(8). Once 30 days lapse, this reduced-penalty route closes. The taxpayer must then proceed to DRC-06 reply, hearing, and DRC-07 order. Under Section 74, post-DRC-07 penalty escalates to 50 percent (within 30 days of order) or 100 percent (beyond). The window is also the DRC-06 reply deadline - extendable on request but should not be missed.

Can I make a partial DRC-03 payment against an SCN?

No. The GST portal does not allow partial DRC-03 payment against a specific Show Cause Notice - the taxpayer must pay the full demanded amount or none. This is a portal-level restriction under Rule 142(2). However, strategic structuring is possible - file DRC-03 with Cause Voluntary for the accepted portion before the SCN response deadline (creating a separate voluntary payment record), then file DRC-06 contesting the balance in the SCN reply. The voluntary payment can later be mapped via DRC-03A if needed for offsetting against any confirmed demand.

What happens if I file DRC-03 with the wrong Cause of Payment?

DRC-03 cannot be amended or withdrawn once filed - if the wrong Cause of Payment was selected (most commonly Voluntary instead of SCN or Intimation DRC-01A), the payment does not get auto-linked to the specific demand order. The correction tool is Form DRC-03A - introduced specifically for retroactive mapping of payments to demand orders. The taxpayer files DRC-03A on the GST portal mapping the prior DRC-03 ARN to the specific demand order number. Without DRC-03A correction, the demand may still appear outstanding despite the payment, with potential recovery and ITC complications.

Is DRC-01A mandatory before DRC-01 SCN?

No, DRC-01A is NOT mandatory before DRC-01 SCN - it is at the officer discretion. In non-fraud Section 73 cases, officers typically issue DRC-01A first as a procedural courtesy and to allow taxpayer voluntary closure. In fraud Section 74 cases, officers often proceed directly to DRC-01 SCN bypassing DRC-01A. However, the Madras High Court has held that for procedural fairness, ASMT-10 scrutiny is mandatory before DRC-01 SCN on matters that were subject to scrutiny - issues raised in DRC-01 that differ from ASMT-10 are vitiated. The DRC-01A intimation does not have the same statutory mandate but is good practice and often improves the procedural defence at appeal.

Can the DRC-01 reply window be extended beyond 30 days?

Yes, the 30-day DRC-06 reply window can be extended on written request to the proper officer - this is at the officer discretion under Section 73(2) or 74(2). Extension requests are commonly granted for complex multi-year, multi-issue SCNs requiring deep reconciliation - typically 30 to 60 additional days. However, the 30-day window for DRC-03 voluntary payment at the reduced post-SCN penalty rate (10 percent Section 73 / 25 percent Section 74) is statutory and cannot be extended - it is fixed by Section 73(8) and 74(8). File the extension request within the first 7 days while simultaneously deciding on the DRC-03 route within the statutory window.

DRC-01 aur DRC-01A ka jawab kaise dein?

DRC-01A pre-SCN intimation hai - Section 73(5)/74(5)/74A(8) ke under. 3 parts hote hain - Part A (officer ka allegation), Part B (aapka jawab), Part C (closure order agar accept). DRC-01 formal SCN hai - 30 din ka reply window (DRC-06) start hota hai service date se. DRC-03 voluntary payment ka form hai - 11 Cause options hain (Voluntary, SCN, Intimation DRC-01A, etc.). DRC-03 ek baar file ho gaya to amend nahi kar sakte - Cause sahi select karna zaroori hai. Section 73 pre-SCN payment par ZERO penalty, Section 74 pre-SCN par 15 percent. Post-SCN 30 days mein - Section 73 10 percent, Section 74 25 percent. 30 din nikal gaye to reduced penalty route band ho jata hai. Patron Day-1 response deta hai aur 30-day window kabhi miss nahi hota - 1,500+ DRC form responses file ki hain. INR 9,999 se start.

Quick Answers

  • DRC-01A Stage: Pre-SCN intimation (Section 73(5)/74(5)/74A(8)) - officer discretion.
  • DRC-01 Stage: Formal SCN under Rule 142(1)(a) - the 30-day reply clock starts.
  • DRC-01A Parts: Part A (officer intimation), Part B (taxpayer reply), Part C (closure).
  • Reply Form for DRC-01: DRC-06 within 30 days (extendable on request).
  • Voluntary Payment Form: DRC-03 - 11 Cause-of-Payment options.
  • Pre-SCN Penalty (Section 73): ZERO via DRC-03 under Section 73(5).
  • Pre-SCN Penalty (Section 74): 15% via DRC-03 under Section 74(5).
  • Within 30 Days of SCN (Section 73): 10% via DRC-03 under Section 73(8).
  • Within 30 Days of SCN (Section 74): 25% via DRC-03 under Section 74(8).
  • Within 30 Days of DRC-07 (Section 74): 50% via DRC-03 under Section 74(11).
  • Partial Payment Against SCN: NOT allowed by the portal.
  • DRC-03 Amendment: NOT possible once filed; use DRC-03A for mapping.
  • Patron Fee: INR 9,999 DRC-01A; INR 14,999-19,999 DRC-01 SCN response.

Why the 30-Day Clock Cannot Be Ignored

DRC-01 and DRC-01A response carries the single most time-sensitive exposure in the entire GST notice framework - the 30-day window from DRC-01 service is the line between reduced penalty (10 percent Section 73 / 25 percent Section 74) and full penalty exposure, which for Section 74 jumps to 50 percent within 30 days of DRC-07 and 100 percent thereafter.

The DRC-01A pre-SCN window offers the lowest penalty exposure possible - zero percent under Section 73(5) or 15 percent under Section 74(5) - but it requires Day-1 response capability to assess and execute within the officer-specified window. DRC-03 cannot be amended or withdrawn once filed, so the Cause-of-Payment selection must be correct the first time, and no partial payments against an SCN are allowed.

The 2025-26 GST notice issuance wave has intensified, with active SCN windows for FY 2020-21 to FY 2023-24 (Section 73) and FY 2019-20 to FY 2023-24 (Section 74), plus FY 2024-25 onwards under Section 74A. Day-1 discipline preserves every penalty-optimization opportunity the framework offers.

Respond to Your DRC Form Before the Window Closes

DRC-01 and DRC-01A response is form-procedural work where small operational gaps create disproportionate economic consequences - a missed 30-day DRC-03 window converts a Section 74 demand from 25 percent penalty to 100 percent penalty exposure on a Rs 1 crore demand, and a wrong Cause-of-Payment selection converts a properly-intended payment into an unlinked deposit, leaving the demand outstanding despite the cash outflow. The DRC-01A stage offers the lowest penalty exposure in the framework but requires Day-1 capability to execute.

Patron Accounting LLP runs this form-procedural engagement with 15+ years of GST practice and 1,500 plus DRC form responses filed, with Rs 200 crore plus in demand exposure optimized via the pre-SCN DRC-03 route or post-SCN reduced-penalty payment - with zero missed 30-day windows and zero DRC-03 Cause-of-Payment errors in the last 18 months. The engagement is per-form scoped at Rs 9,999 onwards.

Pair this with our parent GST Notice umbrella, GST Notice for Restaurants for the industry vertical, and GST Returns for the return-level basis - together they form an integrated GST notice defence backbone from scrutiny through Section 107 appeal.

Book a Free Consultation - No Obligation.

GST Notice and DRC Support Across India

With offices in Pune, Mumbai, Delhi, and Gurugram, Patron Accounting serves businesses across India - both in-person and remotely.

GST Notice Support by City
On-the-ground DRC representation plus remote form-response delivery
Related Services
End-to-end support across the GST notice and demand cascade

Content Created: 27 May 2026  |  Last Updated:  |  Next Review: 1 September 2026  |  Reviewed By: CA & CS Team, Patron Accounting LLP

This page is reviewed quarterly (Tier 1 cadence) and on any CBIC notification on Rule 142 DRC-form workflow, GSTN advisory on DRC-03 Cause-of-Payment options, or court ruling on the DRC-01A pre-condition doctrine.