GST Adjudication Support | Savlana Init

GST Compliance · Adjudication

GST Adjudication — Prepared. Argued. Best Outcome.

GST adjudication is where the demand is fought or conceded — we prepare the DRC-06 written reply, compile case law and CBIC circulars, attend every personal hearing, make oral and documentary submissions, and review the DRC-07 order immediately for appeal.

GST adjudication is the quasi-judicial proceeding in which the adjudicating officer hears both the department's case (as set out in the show cause notice) and the taxpayer's response (the DRC-06 reply and personal hearing submissions) and then passes a demand order in Form DRC-07. The adjudicating officer is a Superintendent, Deputy/Assistant Commissioner, or higher official depending on the demand quantum. The quality of the representation at this stage determines whether the demand is confirmed, reduced, or dropped entirely.

Adjudication is not a passive formality — it is an active contested proceeding requiring careful preparation. The written reply (DRC-06) must address every paragraph of the show cause notice with specific factual and legal submissions — a general denial is not sufficient. The personal hearing is the opportunity to supplement the written reply with oral arguments, respond to specific officer concerns, and present additional documents. Officers are entitled to weigh both the written reply and the oral submissions in passing their order — and frequently do modify the demand at the hearing stage based on convincing submissions.

We prepare for GST adjudication the way a case is prepared for a tribunal hearing — paragraph-by-paragraph review of the SCN, legal research on the specific issues, case law compilation, computation challenge, and a clear written reply and oral submission brief. We also advise on the interplay between contesting the demand and voluntarily paying the undisputed portions through DRC-03 — so the taxpayer minimises both tax and penalty exposure while preserving a strong contested position on the genuinely disputed amounts.

Our GST Adjudication Services

Personal Hearing Attendance & Representation

CA attendance at the personal hearing before the adjudicating officer — oral submissions, documentary evidence presentation, and response to officer queries on record.

DRC-06 Written Reply

Comprehensive DRC-06 reply prepared paragraph-by-paragraph — legal grounds, factual reconciliation, computation disputes, and documentary annexures for every contested point.

Case Law & Circular Research

Research and compilation of relevant GST judgements, CBIC circulars, advance rulings, and AAR orders supporting the taxpayer's position on each disputed issue.

Computation Challenge

Independent computation of the correct tax liability — challenging the officer's demand quantum through identification of computational errors, wrong rate application, and ITC over-reversal.

Voluntary DRC-03 Timing Advisory

Strategic advisory on timing and amount of voluntary DRC-03 payment during adjudication — triggering the minimum penalty provision without conceding the contested portion.

Adjournment & Extension Management

Management of hearing adjournments, reply deadline extensions, and rescheduling — ensuring procedural defaults do not prejudice the taxpayer's substantive position.

DRC-07 Order Review

Immediate review of the DRC-07 adjudication order — identifying appeal grounds, contested amounts, and the 3-month appeal window from date of communication.

Multi-Period Representation

Consolidated representation for taxpayers with multiple show cause notices across different tax periods — unified legal narrative and consistent legal position across all proceedings.

Our Process

SCN Paragraph-by-Paragraph Review

Every paragraph of the show cause notice is reviewed — the legal ground, the computation, and the factual allegation are mapped to available evidence and applicable law.

DRC-06 & Case Law Brief Preparation

A comprehensive written reply is drafted — legally structured, factually grounded, and supported by computation statements, case law briefs, and documentary annexures.

Pre-Hearing Preparation

A hearing brief is prepared — oral submission outline, key case law citations, and documentary evidence organised for presentation at the personal hearing.

Personal Hearing Attendance

Our CA attends the hearing, makes oral submissions, presents documents, responds to the officer's questions, and ensures the proceedings are properly recorded.

DRC-07 Review & Next Steps

The adjudication order is reviewed immediately on receipt — appeal merit, pre-deposit requirement, and limitation period are confirmed without delay.

Why It Matters

✓Every SCN paragraph addressed — no uncontested ground for confirmation

✓Personal hearing attended — not just a written reply

✓Case law and CBIC circulars cited for every contested legal issue

✓Officer's computation challenged with independent correct calculation

✓Voluntary DRC-03 timed to minimise penalty before order is passed

✓Adjournment requested and granted to prevent procedural defaults

✓DRC-07 reviewed immediately — 3-month appeal window tracked from receipt

✓Multi-period SCNs handled with consistent unified legal position

Frequently Asked Questions

At the personal hearing, the adjudicating officer calls the taxpayer or their representative to present their case against the show cause notice — making oral submissions, presenting documents, and responding to officer questions. The officer considers both the written DRC-06 reply and the oral submissions before passing the DRC-07 order.

Yes. A Chartered Accountant authorised by the taxpayer through a letter of authorisation can appear and make submissions at a GST adjudication hearing. Professional representation significantly improves the outcome — both through the quality of the written reply and the oral submissions at the hearing.

The adjudicating authority depends on the quantum of the demand: up to ₹10 lakh — Superintendent; ₹10 lakh to ₹2 crore — Deputy/Assistant Commissioner; ₹2 crore to ₹5 crore — Additional/Joint Commissioner; above ₹5 crore — Commissioner. The first appellate authority is one level above the adjudicating officer.

Under Section 73, the order must be passed within 3 years from the due date of the relevant annual return. Under Section 74 (fraud), the limit is 5 years. Orders passed beyond the limitation period are legally void and can be challenged in appeal or by writ petition.

If the taxpayer or representative fails to attend, the officer may proceed ex parte — passing the order without the taxpayer's submissions. It is critical to attend or request an adjournment in advance. Even after an ex parte order, an application for recall can be made if sufficient cause for non-attendance is shown.

The optimal strategy depends on the merits of each component of the demand. Where a portion of the demand is clearly payable (e.g., late fee, undisputed ITC excess), paying that portion through DRC-03 before the order reduces the overall penalty exposure. The genuinely contested portion should be formally contested — forcing the officer to pass a reasoned order that can be appealed if adverse.

Facing a GST adjudication hearing?

We prepare your DRC-06 reply, compile case law, attend every personal hearing with oral submissions, and review the DRC-07 order immediately for appeal — your best defence before the demand is confirmed.