From DRC-01 to DRC-07: the adjudication chain in one page
Every form in the chain has a consequence and a deadline. Knowing which form you are holding tells you what you can still do.
The demand chain runs from the pre notice intimation in DRC-01A, to the notice in DRC-01 with its summary, to the reply in DRC-06, to the order in DRC-07 which is the summary of the adjudication order and creates the liability in the electronic liability register. Payment is made in DRC-03. Rectification is in DRC-08. Recovery proceeds through DRC-09 onwards, and provisional attachment is DRC-22.
The forms, and what each means for you
DRC-01A, intimation of ascertained liability before notice. No liability, and the cheapest exit under Section 73(5) or 74(5).
DRC-01, summary of the show cause notice, served with the notice. This starts limitation for the order and fixes the outer boundary of the adjudication under Section 75(7).
DRC-06, the reply. File through the portal within the time stated, with annexures.
DRC-07, summary of the order. This is the document that creates the entry in the liability register and against which the appeal under Section 107 lies. The appeal limitation runs from communication of the order.
DRC-03, payment. Select the correct cause — voluntary, against a notice, against an order, or a pre deposit — because the selection has consequences.
DRC-08, rectification of an order, following an application under Section 161.
DRC-22, provisional attachment under Section 83, with the objection route in Rule 159(5).
The three points at which files are lost
The reply not filed on the portal. A reply sent by email or handed over, without a DRC-06 filing, is routinely recorded as no reply received, and the order then recites that the taxpayer did not respond.
The order not tracked. DRC-07 is uploaded to the portal and the appeal limitation runs from communication. A taxpayer who monitors only physical post loses the appeal window.
The payment made with the wrong cause. A pre deposit recorded as a voluntary payment is not treated as a pre deposit, and the appeal is defective until corrected.
What to check on receipt of DRC-07
That the summary matches the order. Discrepancies between the DRC-07 figure and the order figure are common and are a ground for rectification.
That the amount does not exceed the notice, and that no ground outside the notice has been confirmed.
That the order is signed and, where applicable, digitally authenticated. Unsigned orders have been set aside.
That the date of the order is within the statutory outer date for the year.
What to do on Monday
File every reply as DRC-06 on the portal, whatever else you send.
Assign portal monitoring to a named person with a weekly check, because appeal limitation runs from upload in practice.
Select the correct cause of payment in DRC-03 every time, and keep the challan with the covering letter.
On DRC-07, reconcile the summary against the order and check signature, date and scope before drafting the appeal.
This page states the general position. A reader with a specific question on their own facts may write to the GST practice at AMLEGALS.
Write to the GST practiceQuestions we are asked on this
Is DRC-07 the order, or the summary?
It is the summary. The order itself must be uploaded and served. Where only the summary is served without the order, that is a ground of challenge.
From what date does the appeal period run?
From communication of the order. Track the portal, because upload is treated as communication in practice.
Can we file a reply after the due date?
File it, and ask that it be considered. An order passed without considering a reply on record is vulnerable, even if filed late.
What if the DRC-07 amount is wrong?
Apply under Section 161 for rectification, and file the appeal in parallel if limitation is close. Do not rely on the rectification alone.
Is an unsigned order valid?
Several High Courts have held that an unsigned or unauthenticated order is not an order in law. Check the document before assuming the appeal is the only route.
In this cluster
- GST show cause notice: how to read it, and how to answer it
- Section 73 versus Section 74: where the department overreaches, and how to prove it
- Section 74A: the unified limitation regime from FY 2024-25
- DRC-01A pre notice intimation: reply, pay, or wait?
- Vague and omnibus notices: how Amrit Foods, Brindavan Beverages and Oryx Fisheries decide GST demands
- Suppression of facts under Section 74: what the department must actually prove
- Personal hearing under Section 75(4): the right, and the consequence of denying it
- Orders that travel beyond the notice: Section 75(7) in practice
- Limitation for GST demands: the year by year table you should keep in every file
- Section 168A extensions: the challenge to extended limitation, and where the litigation stands
GST Insights is published by AMLEGALS for general information. Law stated as on 3 September 2026. Not advice on any particular set of facts; not an advertisement or a solicitation under Rule 36 of the Bar Council of India Rules. Readers with a question on their own facts may write to the GST practice of their own accord.