GST Show Cause Notice (DRC-01) in 2026: Section 73, 74 and 74A Explained, With Time Limits and How to Reply

GST | RegisCorp Team

Short answer: A GST show cause notice in Form DRC-01 is not a demand order. It is a notice asking you to explain why the department should not demand tax, interest and penalty. For financial years up to 2023-24 it comes under Section 73 (non-fraud) or Section 74 (fraud). From 2024-25 it comes under Section 74A, which covers both. You reply in Form DRC-06 on the GST portal, within the time written on the notice, and you can pay any part you agree with through DRC-03. If you do nothing, the officer can pass a demand order in DRC-07, and an order is much harder to fight than a notice.

Source note. The time limits below follow published commentary on Sections 73, 74 and 74A of the CGST Act and the Rule 142 forms, and the 57th GST Council press release of 8 October 2026 for the proposed relief. We link the official portals at the end. Read your own notice carefully, because the dates, section and grounds in the notice decide your deadlines. This is general information, not legal advice.

Why this matters now

Notices are rising because the GST system now matches your GSTR-1, GSTR-3B, GSTR-2B and e-invoice data automatically. When the numbers do not match, a notice follows. In October 2026 the 57th GST Council also recommended several reliefs, such as a Rs 10,000 minimum for show cause notices and lower penalties, but those need law changes. Until then, the existing rules and deadlines apply to you. For a practical, step-by-step service view, see our guide to replying to a GST notice.

Section 73, Section 74 or Section 74A: which one applies to you?

Financial yearSection usedMeaning
Up to 2023-24Section 73Tax short paid or not paid, credit wrongly taken, without fraud
Up to 2023-24Section 74The same, but with fraud, wilful misstatement or suppression
2024-25 onwardsSection 74AOne section for both fraud and non-fraud cases

The first thing to check on any notice is the section and the financial year. They decide your time limits and the penalty exposure. If a notice quotes the wrong section for the year, say so in your reply.

Time limits that decide whether a notice is valid

SectionNotice must be issuedOrder must be passed
73At least 3 months before the order deadlineWithin 3 years of the annual return due date
74At least 6 months before the order deadlineWithin 5 years of the annual return due date
74AWithin 42 months of the annual return due dateWithin 12 months of the notice date

Worked examples

The annual return due date, not the date you actually filed, is the starting point. Check the notice date against these limits. A notice outside the time limit can be challenged on that ground alone.

DRC-01 and DRC-01A: do not confuse them

A notice covers one financial year and the same grounds cannot be raised twice for the same year, but different grounds can be raised in a later notice. A separate notice is issued for each other year.

What to do in the first seven days

  1. Log in and download the notice. Notices are served on the GST portal, and also by email or SMS. The date of service matters.
  2. Note four things: the section, the financial year, each ground, and the reply date.
  3. Collect the records: invoices, e-way bills, GSTR-1, GSTR-3B, GSTR-2B, bank statements, contracts and any earlier reconciliations.
  4. Decide what is right and what is not. If part of the demand is correct, you can pay it through DRC-03 and mention the payment in your reply.
  5. Ask for more time if you need it. The extension request is made through the reply form on the portal, so make it before the date passes.

How to write the reply (DRC-06)

A good reply is short, structured and complete:

You can still upload a reply on the portal after the date has passed, but do not depend on this. An order can be passed once the time is over.

What can happen next

These items come from the Council's press release of 8 October 2026 and need notifications or amendments before they apply:

Until those are notified, plan on the existing penalty rules. Our summary of all the Council decisions is in the 57th GST Council guide.

The five most common reasons for GST notices

  1. Credit mismatch between GSTR-2B and GSTR-3B.
  2. Sales mismatch between GSTR-1 and GSTR-3B, or against e-invoice and e-way bill data.
  3. Credit from non-filing or cancelled suppliers, or from invoices not shown in GSTR-2B.
  4. Late or missing returns, including the annual return.
  5. Reverse charge not paid, or paid late, on eligible purchases.

Fixing these before a notice arrives is far cheaper than answering one. Monthly reconciliation of your books against GSTR-2B and GSTR-1 is the best habit you can build.

Mistakes that turn a notice into an order

Frequently asked questions

Is a DRC-01 a demand? No. It is a show cause notice. The demand comes only with an order in DRC-07.

How many days do I have to reply? The notice states the date. Reply within it. If you need more time, ask on the portal before it passes.

Can I pay part of the amount? Yes. Pay the part you accept through DRC-03 and refer to it in your reply.

Which section applies to FY 2024-25? Section 74A, which covers both fraud and non-fraud cases.

Will the Rs 10,000 threshold cancel my small notice? Not yet. It is a recommendation that needs a law change. Answer the notice in the meantime.

Do I need a professional? For small, simple mismatches you may handle it yourself. For fraud allegations, large amounts or credit disputes, speak to a GST professional early.

How RegisCorp can help

Our team reviews the notice, checks the section and time limits, prepares the reply and supporting records, and represents you through the hearing. Share your notice with us through the website or WhatsApp.

Official sources

Last updated 3 November 2026. Dates and sections vary by case, so verify your own notice.