Reply to GST Show Cause Notice — Drafting Tips and Template

[Letterhead of the Taxpayer]
[Legal Name] | GSTIN: [22ABCDE1234F1Z5]
[Principal Place of Business, State, PIN]

Ref: Reply to SCN No. [___]                         Date: [DD-MM-YYYY]

To,
The [Superintendent / Assistant Commissioner], CGST & SGST,
[Range / Division / Ward], [Commissionerate],
[Address].

Subject: Reply to Show Cause Notice No. [___] dated [DD-MM-YYYY]
         issued under Section [73/74] of the CGST Act, 2017 for the
         tax period [Month/Year to Month/Year] — reg.

Reference: SCN in Form GST DRC-01 / ASMT / ADT bearing ARN [___].

Respected Sir/Madam,

1. This is with reference to the captioned Show Cause Notice ("the
   Notice") received on [DD-MM-YYYY], whereby a demand of tax
   ₹[amount], interest under Section 50 and penalty under Section
   [___] has been proposed. The contents of the Notice are denied
   save to the extent expressly admitted herein.

PRELIMINARY OBJECTIONS
2. The Notice is vague and does not disclose the specific ground/
   discrepancy with supporting material, and is therefore bad in law
   for want of a proper "statement of grounds" as required under
   Section 73(1)/74(1) read with Rule 142.

3. Invocation of Section 74 (extended period) is unsustainable as
   there is no fraud, wilful mis-statement or suppression of facts —
   all returns (GSTR-1/3B) were duly filed and figures disclosed.

SUBMISSIONS ON MERITS
4. As regards the alleged [mismatch/excess ITC/short payment] of
   ₹[amount]: it is submitted that [state facts — e.g., the ITC is
   supported by valid tax invoices under Section 16, goods/services
   were received, tax was paid by the supplier, and reflected in
   GSTR-2B for the period]. Reconciliation is enclosed as Annexure-A.

5. The reliance placed on [___] is misplaced because [reason]. The
   settled legal position in [case citation, if any] supports the
   assessee.

6. Without prejudice, even if any amount is held payable, penalty
   under Section 73(8)/74 is not attracted as the tax (if any) stands
   paid along with interest — see Annexure-B (DRC-03 challan).

PRAYER
7. It is therefore prayed that this Hon'ble Authority be pleased to:
   (a) drop the proceedings initiated vide the said Notice; and
   (b) grant an opportunity of PERSONAL HEARING under Section 75(4)
       before passing any adverse order.

The above is submitted true and correct to the best of my knowledge.

Thanking you,
Yours faithfully,

For [Legal Name of Taxpayer]

____________________
[Name of Authorised Signatory]
[Designation] | Ph: [___] | Email: [___]

Enclosures:
1. Copy of the impugned SCN.
2. Annexure-A: Reconciliation statement.
3. Annexure-B: DRC-03 challan (if paid under protest).
4. Copy of Authorisation Letter / Board Resolution.