Key points
- What a GST notice reply costs depends on the notice type and how much reconciliation it needs, not on a fixed market rate.
- ICAI's recommended minimum for a show cause notice reply by a CA is ₹30,000 in Class A cities like Hyderabad, ₹20,000 in Class B and ₹15,000 in Class C. It is a recommendation, not a rule.
- Tax Garden's list price is ₹3,500 per notice reply and ₹17,000 per first appeal.
- DRC-01B and DRC-01C give you only 7 days, and an unanswered one blocks your next GSTR-1.
- If the mismatch is genuine, paying tax and interest through DRC-03 before a show cause notice avoids penalty in non-fraud cases.
What drives the fee
Every GST notice reply has the same three parts of work: understanding what the officer is asking, reconciling your figures against what the department sees, and filing the reply in the right form before the deadline. The fee goes up with the second part.
| Factor | Why it matters |
|---|---|
| Number of points raised | Each discrepancy needs its own explanation and evidence |
| Volume of invoices to reconcile | Matching GSTR-1, GSTR-3B, GSTR-2B and your books takes time when there are thousands of invoices |
| Whether ITC is questioned | ITC disputes often need supplier-by-supplier checks and proof of payment |
| Stage of proceedings | A scrutiny query is simpler than a show cause notice with a demand, which is simpler than an appeal |
| Periods covered | A notice covering a whole financial year means a year of data |
| Whether you will pay or contest | Paying a genuine shortfall and reporting it is quicker than building a defence |
Notices by complexity
| Notice | What it is | Reply form and time | Usual complexity |
|---|---|---|---|
| REG-03 | Query on a new registration application | REG-04, 7 working days | Low |
| DRC-01B | GSTR-1 liability higher than tax paid in GSTR-3B (Rule 88C) | Part B, 7 days | Low to medium |
| DRC-01C | GSTR-3B ITC higher than GSTR-2B (Rule 88D) | Part B, 7 days | Low to medium |
| REG-17 | Show cause notice for cancellation of registration | REG-18, 7 working days | Low to medium |
| ASMT-10 | Scrutiny of returns under Section 61 | ASMT-11, 30 days or longer if allowed | Medium |
| DRC-01A | Intimation of tax before a show cause notice | Part B, by the date in Part A | Medium |
| DRC-01 | Show cause notice under Section 73, 74 or 74A | DRC-06, by the date in the notice | High |
| ADT-01 | Departmental audit under Section 65 | Produce records as asked | High |
| Appeal | Against an order, under Section 107 | APL-01, 3 months (plus 1 month if delay is condoned) | High |
Our guides cover each one: ASMT-10, DRC-01A, DRC-01, DRC-01B and DRC-01C, REG-03, departmental audit and GST appeals.
What ICAI recommends
ICAI's Committee for Members in Practice published a Revised Minimum Recommended Scale of Fees on 11 February 2020. Its GST rows include:
| Service | Class A cities | Class B cities | Class C cities |
|---|---|---|---|
| Adjudication / show cause notice reply | ₹30,000 and above | ₹20,000 and above | ₹15,000 and above |
| Filing of appeal / appeal drafting | ₹30,000 and above | ₹20,000 and above | ₹15,000 and above |
| Audit of accounts and reconciliation statement | ₹40,000 and above | ₹20,000 and above | ₹12,000 and above |
| Registration | ₹20,000 and above | ₹15,000 and above | ₹10,000 and above |
In Telangana, ICAI's annexure places Hyderabad in Class A and Warangal in Class B. Other cities are Class C.
Two things to keep in mind:
- It is a recommendation. ICAI's own notes say members are free to charge different rates depending on the nature and complexity of the work, and the actual fee is a matter of agreement between the CA and the client.
- It is from 2020 and covers work by chartered accountants. Use it as a reference point, not as a price list.
What Tax Garden charges
| Service | Fee |
|---|---|
| GST notice reply | ₹3,500 per reply |
| GST appeal (first level) | ₹17,000 per appeal |
| GST reconciliation (advanced) | ₹17,000 |
| GST cancellation or revocation | ₹1,500 |
When a notice covers a full year and the reply depends on a complete reconciliation of your returns and books, the reconciliation is a separate piece of work. We tell you upfront if your notice needs it.
When to handle it yourself and when to get help
Often manageable yourself:
- A REG-03 query asking for a specific document, such as a rent agreement or electricity bill
- A DRC-01B or DRC-01C where you already know the reason (an invoice reported in the wrong month, a credit note, a supplier who filed late) and can pay or explain it in Part B
Usually worth professional help:
- An ASMT-10 with several points or a large ITC difference
- Any DRC-01 show cause notice with a demand. Your reply becomes the record the officer decides on, and arguments left out at this stage are harder to raise later.
- A departmental audit under Section 65
- An appeal, which has a strict time limit and needs a pre-deposit of 10% of the disputed tax
When paying is cheaper than contesting
If the officer's figures are right, contesting only adds fees and time. In a non-fraud case, paying the tax and interest through DRC-03 before a show cause notice is issued means no penalty under Section 73(5), or Section 74A(8) for FY 2024-25 onwards. Quote the DRC-03 challan in your ASMT-11 or DRC-01A Part B reply so the officer can close the matter. See our DRC-03 guide.
Interest on short-paid tax is 18% a year under Section 50. On wrongly availed ITC, interest applies only if the credit was actually used to pay tax.
Contest when you have documents that explain the gap: credit notes, amendments in a later return, supplier filings that came late, or a wrong reading of your returns by the system.
How to structure a reply (ASMT-11 example)
A scrutiny reply in Form ASMT-11 is filed on the GST portal within 30 days of the ASMT-10, or any longer period the officer allows. Upload a reply letter with it, structured like this:
- Reference. GSTIN, notice reference number and date, and the tax period.
- Point-wise reply. Take each discrepancy in the order the notice lists it. Say whether you accept it, and if not, why.
- Reconciliation. A table matching the figures the officer questioned (for example, GSTR-1 vs GSTR-3B, or GSTR-3B ITC vs GSTR-2B) with your books, explaining every difference.
- Payment details. If you accept any part, the DRC-03 challan number, date and amount for tax and interest.
- Request. Ask the officer to accept the reply and close the proceedings, and request a personal hearing if you want one.
If the officer accepts the reply, the scrutiny ends with Form ASMT-12. If not, the officer can start audit, inspection, or proceedings under Section 73, 74 or 74A. Our GST notice reply format guide has drafts for other notice types.
How Tax Garden helps
We read the notice, tell you whether it needs professional handling, reconcile the figures it questions, and file the reply in the right form on the GST portal. If an order goes against you, we can file the first appeal. Start with our GST compliance services or see pricing.
GST rules and portal limits change. Check cbic-gst.gov.in and the GST portal before acting. This article is general information, not advice for your specific case.
