Core practice
GST Litigation & Notice Reply Services
Scrutiny notices, show cause notices, departmental audits, demand orders and appeals. We read the notice, reconcile your data, draft the reply and represent you, from the first letter to the GST Appellate Tribunal. For businesses in Mumbai, Navi Mumbai and Raigad.
What we handle
GST litigation services
Scrutiny & mismatch notices
Replies to ASMT-10 and similar notices on GSTR-1 vs 3B or 3B vs 2B differences, with reconciliations that close the matter early.
Show cause notice replies
DRC-01A objections and DRC-06 replies to show cause notices under Sections 73, 74 and 74A, including limitation and jurisdiction challenges.
Personal hearings
Representation before the proper officer, in person or online, with written submissions filed on record.
Departmental GST audit
Preparation for audits under Section 65 (ADT-01), attending the audit and replying to findings in ADT-02.
First appeals
Appeals in APL-01 under Section 107 against demand, refund, cancellation and detention orders, including pre-deposit and stay of recovery.
GSTAT appeals
Appeals in APL-05 under Section 112 to the GST Appellate Tribunal, and cross-objections where the department appeals.
Input tax credit disputes
ITC denied for supplier non-filing, cancelled suppliers, blocked credits, time-barred claims and Rule 86A credit blocking.
Registration disputes
Replies to REG-17 and REG-23, revocation of cancelled registration (REG-21) and related appeals.
Refunds, rectification & e-way bills
Refund rejections (RFD-08), rectification of orders under Section 161, and detention and penalty cases under Section 129.
High Court writs and appeals are handled together with our panel of tax advocates.
Local pages: GST litigation in Mumbai · GST litigation in Navi Mumbai
GST notice decoder
What does my GST notice mean?
Find the form number printed at the top of your notice (for example “FORM GST DRC-01”) and select it to see what it means, how to reply and how long you have.
Reviewed October 2026. Always follow the date written on your own notice.
Appeals
GST appeal time limits and pre-deposits
The stages a GST dispute can move through, with the statutory time limit and the deposit needed at each. Missing a time limit is the most common way strong cases are lost.
| Stage | Form / provision | Time limit | Pre-deposit |
|---|---|---|---|
| Notice or intimation | ASMT-10, ADT-01, DRC-01A | Time stated in the notice | No pre-deposit |
| Show cause notice & adjudication | DRC-01 → DRC-06 reply → hearing → DRC-07 | As stated in the SCN; adjudication time limits under Sec 73/74/74A | No pre-deposit |
| First appeal | APL-01 · Section 107 · Appellate Authority | 3 months from the order (+1 month condonable) | 10% of disputed tax |
| GST Appellate Tribunal (GSTAT) | APL-05 · Section 112 | 3 months from the appellate order (+3 months condonable) | Further 10% of disputed tax |
| High Court | Section 117 appeal or writ petition | 180 days for a Section 117 appeal | As directed by the Court |
| Supreme Court | Section 118 / SLP | As per the Court's rules | As directed by the Court |
Based on the CGST Act, 2017 as amended. Reviewed October 2026.
How we work
How we handle your notice
Read the notice and check the basics
Section, period, limitation, jurisdiction and the officer's working. Defects here can end a case on their own.
Reconcile your data
GSTR-1, GSTR-3B, GSTR-2B, e-way bills and books, matched invoice by invoice to separate real short payment from data errors.
Draft the reply
A point-wise reply with annexures, legal provisions, circulars and judgements, shared with you before filing.
Represent you at the hearing
We attend the personal hearing and file written submissions so your arguments are on record.
Review the order and advise on appeal
If the order goes against you, we tell you plainly whether an appeal is worth it and what it will cost.
Common disputes
Issues we see most often
- ITC claimed in GSTR-3B higher than available in GSTR-2B
- ITC denied because the supplier did not file returns or pay tax
- Credit taken on invoices of suppliers whose registration was later cancelled
- Differences between turnover in GSTR-1, GSTR-3B, GSTR-9 and the books
- Classification and rate disputes on goods and services
- Place of supply, and IGST vs CGST/SGST paid under the wrong head
- E-way bill lapses and detention of goods in transit
- Interest and late fee demands on delayed returns
- Refund claims for exports and inverted duty structure rejected
Be ready
Documents to keep ready
Send what you have. We will tell you what else is needed.
- The notice and every attachment, downloaded from the GST portal
- GSTR-1, GSTR-3B and GSTR-9/9C for the period
- GSTR-2A / GSTR-2B and your purchase register
- Books of accounts and ledgers for the disputed items
- Sales and purchase invoices, e-way bills and delivery records
- Payment challans and bank statements
- Any earlier letters, replies or orders on the same issue
FAQ
GST litigation questions
What is the time limit to reply to a GST show cause notice?
The reply date is written in the notice itself, and is commonly 30 days. You can ask the officer for more time in writing, but extensions are discretionary, so start immediately. Missing it can lead to an order being passed without hearing you.
What is the difference between Section 73 and Section 74?
Section 73 applies where tax was short paid or ITC wrongly availed without fraud. Section 74 applies where the department alleges fraud, wilful misstatement or suppression of facts, and the penalty is much higher. For tax periods from FY 2024-25 onwards, both are covered by a single Section 74A. Whether a notice is correctly issued under Section 74 is often the first point we contest.
How much pre-deposit is needed to file a GST appeal?
For a first appeal under Section 107 you must pay the admitted tax in full and 10% of the disputed tax. For an appeal to the GST Appellate Tribunal under Section 112, a further 10% of the disputed tax is required. Statutory caps apply to very large demands. Once the pre-deposit is paid, recovery of the balance is stayed while the appeal is pending.
What is the time limit to file a GST appeal?
A first appeal must be filed within 3 months from the date the order is communicated; the Appellate Authority can allow one more month for sufficient cause. An appeal to GSTAT must be filed within 3 months of the appellate order, with up to 3 more months condonable.
Is the GST Appellate Tribunal (GSTAT) working now?
Yes. The GSTAT was notified and began accepting appeals in September 2025, with state benches across the country. Appeals against orders that were stuck while the Tribunal was being set up had to be filed within a transitional window that has now closed, so new appeals follow the normal time limits.
Can I reply to a GST notice myself on the portal?
You can, and for a simple clerical mismatch that may be enough. For a show cause notice, a reply becomes the record the officer, the appellate authority and the Tribunal will rely on. Facts and arguments left out at this stage are hard to add later, so professional drafting usually pays for itself.
My GST registration was cancelled. Can it be restored?
Usually, yes. If it was cancelled for non-filing, you can file the pending returns with dues and apply for revocation in Form REG-21. If revocation is rejected or the time limit has passed, an appeal is possible.
What documents should I keep ready for a GST notice?
The notice and any attachments, GSTR-1, GSTR-3B, GSTR-2A/2B and GSTR-9 for the period, your books of accounts, purchase and sales invoices, e-way bills, payment proofs and any earlier correspondence with the department.