Final Demand Order — Appeal Within 3 Months

How to Reply to DRC-07 Summary of Order — AI Response Guide

DRC-07 is issued under Section 73(9)/74(9), Rule 142(5). This guide explains the legal basis, common grounds, procedural steps, and how GST Notice AI drafts your reply in under 60 seconds with relevant citations and defences.

What is DRC-07?

Form DRC-07 is the Summary of Order issued under Rule 142(5) of the CGST Rules after adjudication of a Show Cause Notice (DRC-01) under Section 73 or 74. It formalises the tax, interest, and penalty confirmed by the adjudicating officer and creates an enforceable demand.

Legal Section

Section 73(9)/74(9), Rule 142(5)

Appeal Window

3 Months (Extendable 1 Month)

Reply Deadline

3 Months from Service

Risk Level

Very High — Becomes Recoverable

Appeal Form

Form APL-01

Issuing Authority

Proper Officer (Adjudicating Authority)

Common Reasons for Receiving DRC-07

Confirmed Demand After DRC-01 Hearing

The adjudicating officer finds the taxpayer's reply to the DRC-01 Show Cause Notice unsatisfactory and confirms the tax proposed along with interest under Section 50 and penalty under Section 73(9) or 74(9).

Ex-Parte Order for Non-Appearance

If the taxpayer failed to respond to the SCN or did not appear for personal hearing despite reminders, the officer may pass an ex-parte order confirming the entire demand.

Partial Confirmation with Modified Demand

Officer accepts part of the reply and reduces the demand — DRC-07 reflects the revised amount which still needs to be paid or appealed against.

Penalty-Only DRC-07 under Section 122

Certain contraventions (e.g. issuing incorrect invoice, non-issuance of e-way bill) can attract a standalone DRC-07 for penalty under Section 122 without any tax demand.

How to Respond to DRC-07

1

Verify the DRC-07 matches the underlying DRC-01 / Section 74 proceedings. Check notice number, DIN, date of order, and officer details.

2

Reconcile the confirmed amount — tax + interest + penalty — against the figures in the Show Cause Notice. Identify any new additions made at the order stage without a fresh SCN (grounds for appeal).

3

Decide: pay under protest, file appeal under Section 107 via Form APL-01, or pursue rectification under Section 161 if there is an apparent error.

4

If appealing: deposit 10% of disputed tax (pre-deposit) within 3 months from date of service. Draft grounds of appeal citing violation of natural justice, incorrect application of law, or factual errors.

5

File APL-01 electronically on the GST portal along with the appeal fee, supporting documents, and a certified copy of DRC-07. Maintain acknowledgment of filing.

6

Track the appeal — if Appellate Authority confirms the demand, the next forum is GSTAT (Section 112) or High Court (writ/appeal under Section 117).

How GST Notice AI Helps with DRC-07

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Pre-Deposit Calculator

Compute the exact 10% pre-deposit under Section 107(6) including correct treatment of admitted vs disputed tax — and auto-generate the DRC-03 payment linkage.

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Grounds of Appeal Drafting

AI drafts grounds of appeal citing procedural lapses (natural justice, SCN-order mismatch), substantive defences (Section 16 conditions, time-bar), and applicable precedents.

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Deadline Watchdog

Tracks the 3-month appeal window with escalating WhatsApp and email alerts at 45, 30, 15, 7, and 1 day before expiry.

Reply to DRC-07 with AI

Upload your DRC-07 notice. AI drafts the reply, computes deadlines, and cites every applicable section and rule.

No credit card required. Analyse your first 3 notices free.

Frequently Asked Questions — DRC-07

What is DRC-07 in GST?
DRC-07 is the Summary of Order issued under Rule 142(5) after an adjudication order under Section 73 or 74 of the CGST Act. It formalises the demand of tax, interest, and penalty and becomes recoverable if not appealed within 3 months.
What is the appeal period against DRC-07?
You can file an appeal under Section 107 within 3 months of the date of communication of the order. The Appellate Authority may condone delay up to a further 1 month on sufficient cause shown.
What is the pre-deposit for filing an appeal?
Under Section 107(6), you must deposit 10% of the disputed tax amount (capped at ₹25 crore under CGST + ₹25 crore under SGST) as pre-deposit. Admitted portion must be paid in full. No pre-deposit is required for penalty-only orders.
Can DRC-07 be rectified without an appeal?
Yes — under Section 161 read with Rule 142(7), you can file for rectification of any apparent error on the face of the record within 3 months of the order. This is faster than an appeal but limited to obvious arithmetic or typographical errors.