GST framework

Goods and Services Tax is a destination-based, dual-levy tax under the Central Goods and Services Tax Act, 2017 (CGST) and the State / Union Territory GST Acts, with IGST on inter-state supplies. Compliance touches registration (Section 22), invoicing (Section 31), e-way bills, returns (GSTR-1, GSTR-3B, annual GSTR-9), input tax credit (Sections 16–18), refunds (Section 54), and audits (Section 65). Disputes are adjudicated through SCN under Sections 73 (non-fraud) or 74 (fraud), then appeals under Sections 107 / 112.

Common notices and how to respond

GST DRC-01A intimation; DRC-01 SCN; DRC-07 demand order; ASMT-10 scrutiny notice; CMP-05 (composition); REG-17 (cancellation); GSTR-3A (non-filer). Each has a strict timeline — typically 30 days to reply, sometimes 7 days. A well-pleaded reply citing legal grounds, supplier filings, ledger reconciliation, and case-law on parallel proceedings often closes the matter at SCN stage without further litigation.

Input tax credit (ITC) disputes

The most frequent dispute today is ITC denial under Section 16(2)(c) where the supplier has not paid tax. The Supreme Court in Suncraft Energy (2024) and Bharti Airtel (2021) cases gave nuanced answers; the recent amendment to Rule 36 and CBIC clarifications continue to evolve. Show-cause notices issued under Section 73 / 74 must be defended quickly — failure to reply leads to ex-parte demand orders with 100% penalty under Section 74.

E-way bill detention and confiscation

Goods in transit are routinely detained under Section 129 for e-way bill defects (expired, wrong vehicle number, wrong consignment). Release is on payment of (i) tax + penalty equal to 100% of tax for owner, or (ii) 50% of value for non-owner. Confiscation under Section 130 is more severe. Bond and bank guarantee under Rule 140 secures release pending appeal — we handle this on priority for transporters in Kota.

Appeals and the new GSTAT

First appeal to the Appellate Authority (Joint Commissioner) under Section 107 within 3 months; pre-deposit of 10% of disputed tax is mandatory. Second appeal to the GST Appellate Tribunal (GSTAT) under Section 112 — finally constituted with Principal Bench at Delhi and State benches; Rajasthan Bench is being operationalised. High Court writ jurisdiction under Article 226 is reserved for jurisdictional defects, natural justice violations and the constitutional validity of provisions.