GST Notices, Audits & DRC-01 Defence
Under Regulatory Scrutiny
Senior-Led GST Advisory & Litigation Representation in Bangalore
We represent businesses in high-value GST matters including DRC-01 and DRC-01A proceedings, Section 65 & 66 audits, summons under Section 70, search actions under Section 67, and appellate positioning — with direct senior involvement throughout.
- Senior-led GST representation — no junior delegation
- High-value DRC-01 / DRC-01A defence & audit positioning
- Summons and search-related authority engagement
- Strategic adjudication and appellate structuring
When GST Exposure Becomes Structural
- High-value GST audits and DRC-01 / DRC-01A proceedings
- Summons (Section 70) or search actions affecting promoter-level risk
- Interpretation-sensitive positions under departmental scrutiny
- Adjudication and appellate stages requiring defensible positioning
- Situations where routine compliance response is insufficient
Why GST Scrutiny Intensifies as Businesses Scale in Bangalore
Scale Invites Review
Higher turnover and transaction complexity increase audit frequency, notice issuance, and departmental engagement.
Liquidity Impact
ITC reversals, refund blocks, and demand notices directly affect working capital cycles and funding posture.
Promoter Exposure
Material GST matters extend beyond filings — influencing promoter accountability, lender confidence, and long-term regulatory standing.
When GST Matters Stop Being Compliance Issues
High-value GST proceedings are not routine reply exercises. They are regulatory events where early positioning determines adjudication trajectory, penalty exposure, promoter accountability, and long-term regulatory standing.
- Material tax, interest, or penalty exposure
- Promoter or director-level personal risk
- Working capital blockage or refund denial
- Proceedings moving toward adjudication or appeal
High-Value GST Matters We Represent
In material GST matters, we are engaged across disputes, departmental proceedings, and adjudication stages where exposure affects promoter liability, working capital, and regulatory positioning.
Departmental Audits & Assessments
Interpretation-led defence during Section 65 and Section 66 GST audits, scrutiny assessments, and departmental reviews — structured for exposure containment and defensible positioning before authorities.
GST Show Cause & Demand Notices
Structured handling of GST show cause notices (DRC-01 and DRC-01A), including defensible GST notice reply drafting, exposure quantification challenges, and preparation for adjudication proceedings. For a detailed overview, review our GST Notice, Audit & Litigation Advisory in Bangalore .
ITC Reversals & Mismatch Disputes
Defence against GST ITC reversal notices, 2A/2B mismatch disputes, and supplier non-compliance — protecting liquidity and sustaining defensible credit positions.
GST Summons, Search & Investigation
Senior-led representation during GST summons under Section 70 and GST search proceedings under Section 67 — ensuring controlled authority engagement and promoter-level risk containment.
Anti-Profiteering Proceedings
Strategic defence in complex anti-profiteering proceedings involving pricing analysis, margin scrutiny, and representation before authorities.
Blocked GST Refunds & Denials
Structured recovery strategy for GST refund rejection cases, including RFD-01 denials and procedural objections — safeguarding working capital and documentation defensibility.
When GST Exposure Requires Escalation
Not every GST matter requires structured escalation. However, certain developments indicate that internal handling may no longer be sufficient and that representation before authorities becomes necessary.
Receipt of a GST Show Cause Notice (DRC-01 / DRC-01A)
When a formal GST show cause notice is issued proposing tax, interest, or penalty demands, response positioning materially affects adjudication outcomes.
GST Summons Under Section 70
A GST summons requiring appearance or document production signals investigative scrutiny and requires controlled engagement strategy.
Search Proceedings Under Section 67
GST search or inspection actions elevate exposure beyond compliance — requiring immediate stabilisation and documentation discipline.
Significant ITC Reversal or Refund Rejection
Material input tax credit reversals or GST refund denials affecting working capital may require structured challenge and representation.
Allegations of Suppression, Misclassification, or Fraud
When notices reference suppression, wrongful ITC claims, or intent-based allegations, escalation becomes critical due to potential penalty and reputational implications.
Matters Proceeding to Adjudication or Appeal
Once proceedings advance toward adjudication orders or appellate stages, structured representation and precedent-aware positioning become essential.
Why Promoters Engage Aarthavya for High-Value GST Notices, Audits & Disputes
Aarthavya is engaged during GST show cause notices (DRC-01 / DRC-01A), Section 65 and 66 audits, Section 70 summons, search proceedings under Section 67, and matters progressing toward adjudication or appeal. We are not a routine compliance firm. We are engaged when promoter liability, working capital exposure, and regulatory positioning require structured, senior-led judgement.
Engagements typically begin once routine compliance responses are no longer defensible.
Calm Control in High-Pressure GST Proceedings
Engaged during GST audits, high-value show cause notices, summons, and investigations where timelines are compressed and positions recorded today influence adjudication outcomes. We stabilise exposure and protect promoter-level interests from the outset.
Interpretation-Led GST Positioning (Not Template Replies)
Every GST notice is evaluated on classification logic, valuation structure, ITC eligibility, and statutory interpretation. Responses are structured to withstand scrutiny across adjudication and appellate forums, not drafted as routine compliance submissions.
Promoter-Centric GST Advisory & Representation
Advisory is anchored around promoter exposure, penalty risk, working capital impact, and long-term regulatory positioning. It is not limited to statutory filing compliance.
Low-Noise, High-Judgement Execution
Sensitive GST matters require calibrated engagement with authorities. Tone, sequencing of submissions, and documentation strategy materially influence regulatory perception and eventual outcomes.
Continuity from GST Notice to Closure
The same senior professionals remain involved from GST notice response through adjudication and appeal. This ensures continuity of argument, documentation discipline, and strategic positioning.
Regulatory & Precedent-Aware Positioning
Positions are structured with awareness of evolving GST jurisprudence, departmental trends, and appellate interpretation. This protects defensibility beyond the immediate proceeding.
Common Grounds for GST Show Cause Notices & Audit Disputes
Most GST show cause notices and audit disputes do not arise from return filing errors. They arise from interpretation-led positions involving classification, GST rate application, valuation methodology, and input tax credit eligibility. These issues often determine whether exposure remains manageable or escalates into adjudication or appeal.
Wrong Classification or GST Rate Application
Disputes commonly arise where authorities allege incorrect classification, incorrect GST rate application, or improper treatment of composite and mixed supplies.
Valuation & Related Party Transactions
GST demands may be triggered by valuation disagreements, bundled supply structures, or pricing mechanisms involving related-party transactions.
ITC Eligibility & Credit Reversal Disputes
Many GST notices relate to input tax credit eligibility, 2A/2B mismatches, blocked credits, or supplier non-compliance affecting working capital and liquidity planning.
When GST Disputes Impact Working Capital, Funding & Governance
High-value GST show cause notices, ITC reversals, refund blocks, and audit proceedings often extend beyond tax exposure. They influence working capital cycles, lender confidence, funding approvals, and board-level governance decisions. In such situations, GST representation must align with broader financial and capital strategy.
Virtual CFO & Financial Oversight
Where GST exposure begins affecting liquidity planning, reporting discipline, or investor scrutiny, structured board-level financial oversight becomes necessary to stabilise governance and capital posture.
Explore Virtual CFO Services →Project Finance & Bank Funding
Ongoing GST disputes can influence bank funding decisions, sanction terms, and lender negotiations. Capital structuring and regulatory positioning must remain aligned to protect funding timelines and long-term defensibility.
Explore Project Finance Advisory →Questions Promoters Ask When GST Exposure Becomes Serious
These are the questions we hear when GST show cause notices are received, summons are issued, audits begin, or ITC is blocked — and exposure becomes material.
A GST show cause notice proposing tax, interest, or penalty is a formal assertion of liability. The reply filed at this stage shapes adjudication outcomes. Language, documentation, and legal positioning must be structured carefully to prevent unnecessary escalation or crystallisation of exposure.
GST audits are not routine compliance checks. They are interpretation-led reviews. Data submissions and explanations provided during audit often form the foundation for future demand notices. Strategic handling during audit can materially limit downstream exposure.
A GST summons is an investigative step requiring appearance or document production. Statements recorded may later be relied upon during adjudication, penalty proceedings, or prosecution. Preparation and controlled engagement are critical before any appearance.
GST search proceedings significantly elevate risk. Document access, data extraction, and statements recorded during search can directly influence adjudication and penalty exposure. Immediate stabilisation and documentation discipline are essential.
Many ITC reversal notices arise from documentation gaps, supplier-side non-compliance, or reconciliation failures. Structured factual reconstruction, legal interpretation, and controlled engagement may allow credit defence or restoration.
Once the department proceeds with a confirmed demand order after reply, the matter enters adjudication and potentially appellate stages. At this point, the quality of earlier submissions, documentation record, and legal positioning becomes decisive.
Based in Bangalore and advising promoter-led businesses across India, Aarthavya handles material GST disputes, audit proceedings, and authority-level representation where exposure demands direct, senior-led judgement.
Bring Senior GST Judgement Into the Room — Before Exposure Hardens
We are engaged when GST exposure is material, timelines are compressed, and positions taken today will shape adjudication or appeal. If you are facing a GST notice, audit, summons, investigation, or significant ITC dispute, structured intervention at this stage often determines the long-term outcome.