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GST Adjudication Support Services
GST Adjudication Support is the specialised legal and factual representation of a registered taxpayer during the formal adjudication stage under Section 75 of the CGST Act, 2017 read with Rule 142 of the CGST Rules. Adjudication is the stage where the Proper Officer, after considering the show cause notice, the taxpayer's written reply, evidence on record, and submissions made during personal hearing, passes a reasoned order in Form DRC-07 confirming, modifying, or dropping the proposed demand. It is the moment at which every legal argument, factual reconciliation, and documentary piece prepared during earlier proceedings either holds the line or falls away — making high-quality adjudication support arguably the single most important phase of any GST dispute.
Section 75 lays down the golden framework for every adjudication proceeding — an opportunity of being heard must be granted before any adverse order under Section 73 or 74, adjournments are permitted for sufficient cause (though not more than three), orders cannot go beyond the grounds specified in the SCN, findings must be supported by reasons, and interest under Section 50 is a statutory consequence even without a specific demand. Violations of these structural safeguards — denial of hearing, orders traveling beyond SCN, absence of reasons — are grounds to challenge the order itself. Equally, aggressive but well-grounded legal submissions, case-law compilation, and disciplined factual narratives can often turn a seemingly certain demand into a dropped SCN or a significantly reduced order.
We offer end-to-end GST Adjudication Support — from reviewing the SCN and earlier replies, building a tight factual and legal case, drafting and filing written submissions and supplementary replies, attending personal hearings with structured oral arguments, coordinating adjournments and additional evidence, reviewing draft orders where made available, analysing the final DRC-07 order for appealable infirmities, and setting up the first appeal under Section 107 — so every adjudication proceeding is handled with the care and discipline that the stage demands, and no argument that could have been made is ever left unmade.
Sec 75
General provisions for adjudication
3 Adj.
Max adjournments allowed
Rule 142
Procedural adjudication rule
Form DRC-07
Final adjudication order
Laws & Frameworks We Work Under
CGST Act – Sec 73 / 74
CGST Act – Sec 75
CGST Act – Sec 76 / 77 / 78
CGST Rules – Rule 142
CGST Act – Sec 161 (Rectification)
Forms DRC-01 / 06 / 07 / 08
Natural Justice Principles
Section 107 (Appeal)
Section 75 — The Statutory Framework of Adjudication
Sec 75(1)
Exclusion of Stay Period
Where service of SCN or passing of order is stayed by court / tribunal, the stay period is excluded from limitation.
- Stay-period exclusion
- Protects limitation clock
- Relevant in writ challenges
- Key in legacy disputes
- Important for officers
- Common point of argument
Sec 75(4)
Opportunity of Hearing
Personal hearing must be granted where requested in writing or where any adverse order is contemplated.
- Mandatory opportunity
- Either on request or adverse case
- Denial = natural justice breach
- Strong ground in appeal
- Can lead to set-aside
- Documentation critical
Sec 75(5)
Adjournments & Timelines
Adjournments can be granted for sufficient cause, subject to a statutory cap of three adjournments per proceeding.
- Maximum three adjournments
- Sufficient cause required
- Reasons to be recorded
- Date-wise paper trail
- Affect quality of defence
- Strategic timing matters
Sec 75(6) / (7)
Orders Must Be Reasoned & Within SCN
The adjudication order must set out reasons and cannot travel beyond the grounds specified in the SCN.
- Reasoned order mandatory
- No "non-speaking" orders
- Must stick to SCN grounds
- No new allegations at order stage
- Cross-checked in appeal
- Vital procedural safeguard
Core Activities During GST Adjudication
Analysis
SCN & Reply Analysis
Deep re-reading of the SCN, earlier DRC-06, and annexures to crystallise the real issues in dispute.
SCN
DRC-06
Pleadings
Written Submissions
Supplementary written submissions focusing on the strongest legal grounds and documentary evidence.
Written
Structured
Case Law
Case-Law Compilation
Curated bunch of Supreme Court, High Court, and Tribunal decisions supporting the taxpayer's position.
SC / HC
AAR / AAAR
Hearing
Personal Hearing
Structured oral arguments, responding to officer's questions, and filing additional submissions on the spot.
Oral
Live
Adjournment
Adjournment Strategy
Using the three adjournments under Section 75(5) strategically for data gathering and counsel coordination.
Limited
Strategic
Evidence
Additional Evidence
Filing fresh documents, reconciliations, and declarations to address officer's queries during adjudication.
Docs
Recon
Order
DRC-07 Review
Technical review of the final order — findings, reasoning, quantum — for appealable infirmities.
Review
Appeal
Rectification
Section 161 Rectification
Rectification of mistakes apparent on record before going into full-blown appeal, where appropriate.
Sec 161
DRC-08
What Our Adjudication Support Engagement Covers
Prep
Pre-Hearing Preparation
End-to-end preparation of the adjudication brief — factual map, legal grounds, exhibits, case law, and narrative.
- Issue-wise brief
- Legal position paper
- Exhibit list & paper book
- Case-law digest
- FAQ for officer's questions
- Risk & quantum matrix
Hearing
Hearing & Representation
Attending personal hearing, oral advocacy, supplementary submissions, and clarification of complex points.
- Oral advocacy
- Written notes of argument
- Adjournment requests
- Cross-issue coordination
- Post-hearing submissions
- Draft order review (where possible)
Order
Order Review & Appeal Readiness
Clause-by-clause review of the DRC-07 order and preparation for rectification or first appeal.
- DRC-07 clause review
- Appealable grounds mapping
- Section 161 rectification
- Pre-deposit & quantum
- APL-01 appeal preparation
- Stay of recovery
Our GST Adjudication Support Services
Case Strategy Memo
Comprehensive legal strategy memo covering issues, defences, risks, precedents, and probable outcomes.
Written Submissions
Supplementary written submissions to the DRC-06 reply, refined with the benefit of hindsight and fresh inputs.
Case-Law Pack
Curated case-law compilation — relevant SC, HC, Tribunal, and AAR decisions — filed along with submissions.
Paper Book & Exhibits
Structured paper book with indexed exhibits for ease of reference during hearing and order drafting.
Personal Hearing
Appearance at personal hearings with oral arguments, question handling, and real-time evidence submission.
Section 75 Defence
Protecting procedural rights — hearing denial, orders beyond SCN, absence of reasons, and limitation.
DRC-07 Review
Detailed review of the adjudication order for reasoning, findings, and appealable infirmities.
Rectification & Appeal
Section 161 rectification petitions for clear errors, and seamless first appeal under Section 107 where needed.
When Strong Adjudication Support Makes the Difference
High-Value SCN
SCN demand is large enough that a full-blown adjudication defence is economically worthwhile.
Section 74 Allegation
SCN invokes Section 74 on fraud / suppression grounds that need to be actively contested.
Contested Classification
Dispute on HSN / SAC classification or rate applicability with significant tax impact.
Export / Refund Denial
SCN disputing zero-rated treatment, LUT exports, or refund claims under Rule 89 / 96.
Fake Invoice Allegation
Alleged availment of ITC on fake / non-existent vendor invoices — serious exposure and reputation risk.
Procedural Breach
Earlier stage saw hearing denial, incomplete record, or orders traveling beyond SCN grounds.
Multi-Issue SCN
Complex SCN covering multiple legal issues across multiple years needing disciplined handling.
Precedent-Setting Case
Dispute has implications for future years or other group entities — order needs to be managed carefully.
Information & Documents We Typically Need
Notice & Prior Pleadings
- DRC-01 SCN & annexures
- DRC-06 reply filed
- Earlier ASMT / ADT record
- Scrutiny / audit reports
- Prior correspondence
- Hearing notices
- DRC-03 challans, if any
Returns & Books Data
- GSTR-1 / 3B / 2A / 2B
- GSTR-9 / 9C filings
- Electronic ledgers
- Audited financials
- Trial balance & registers
- ITC / RCM workings
- Reconciliation papers
Legal & Evidence
- Sample invoices / POs
- Key contracts
- HSN / SAC memos
- Pricing / costing notes
- Prior judicial record
- Case-law references
- Authorisation / POA
Our End-to-End Adjudication Approach
1
Case Review
Deep review of SCN, DRC-06, and prior record to identify the best lines of defence.
2
Strategy Memo
Issue-wise strategy memo covering law, facts, risk, and target outcome for each issue.
3
Submissions & Brief
Drafting written submissions, case-law compilation, and structured paper book / exhibits.
4
Personal Hearing
Attending hearings with oral arguments, additional submissions, and live query handling.
5
Order & Next Steps
DRC-07 review, Section 161 rectification where applicable, and first appeal if needed.
Why Choose Us for GST Adjudication Support
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Structured, strategy-led defence
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Strong oral advocacy
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Section 75 procedural expertise
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Deep case-law library
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Disciplined paper-book preparation
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Effective adjournment use
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Rectification & appeal continuity
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Order-grounded appeal drafting
FAQs on GST Adjudication Support
What is adjudication under GST?
Adjudication under GST is the formal process by which the Proper Officer determines the tax, interest, and penalty payable by a taxpayer in respect of a show cause notice issued under Sections 73, 74, 76, or other enabling provisions of the CGST Act. It is governed by Section 75 which lays down the general procedural framework — opportunity of hearing, adjournments, reasoned orders, and the requirement to stay within the grounds of the SCN. Adjudication culminates in a formal order in Form DRC-07 (or a closure order in Form DRC-05 where the matter is dropped), both of which are binding unless rectified under Section 161 or reversed in appeal under Section 107.
How does Section 75 safeguard the taxpayer during adjudication?
Section 75 embeds several structural safeguards — Section 75(4) mandates a personal hearing where requested in writing or where any adverse decision is contemplated; Section 75(5) allows adjournments for sufficient cause up to a maximum of three; Section 75(6) requires orders to set out the facts and law relied upon and to record reasons; Section 75(7) restricts the adjudicating officer from traveling beyond the grounds of the SCN or demanding amounts higher than those proposed. Violations of these safeguards are independent grounds to challenge the order and are routinely relied upon at the appellate stage.
How important is the personal hearing in adjudication?
Personal hearing is often the single most important moment in the entire proceeding. It is the only opportunity to address the officer's oral concerns, clarify complex factual points, introduce supplementary evidence, and humanise the dispute — none of which a purely written reply can achieve. Section 75(4) makes it mandatory where requested or where the proposed order is adverse, and denial of personal hearing is a well-recognised ground to set aside the order in appeal. We prepare for every hearing with structured notes, exhibits, and an anticipated question list — so that no point the officer may raise catches the taxpayer unprepared.
How many adjournments can be taken during adjudication?
Section 75(5) of the CGST Act caps the number of adjournments at three per proceeding, each to be granted only for sufficient cause, with the officer required to record reasons in writing. Beyond three adjournments, the officer can proceed ex parte based on the material on record. This cap makes timing strategic — adjournments need to be used where genuinely needed (awaited documents, specialist counsel, parallel proceedings), and not wasted on minor logistics issues. We plan adjournment use as part of the overall case strategy so that each date of hearing adds real value to the defence.
Can new issues be raised by the officer during adjudication?
No — this is explicitly prohibited by Section 75(7). The adjudication order cannot travel beyond the grounds set out in the SCN, both in terms of the issues and the quantum of tax demanded. If the officer wishes to raise a new issue, a fresh SCN is required. Orders that introduce new grounds or increase the demand beyond what was proposed are vulnerable to being set aside on this ground alone, either through rectification under Section 161 where appropriate, or in first appeal under Section 107. Identifying such transgressions in DRC-07 is one of the first things we do during order review.
What is the role of case law in adjudication?
Properly curated case law — especially Supreme Court and binding High Court decisions — can change the entire tenor of an adjudication. Relevant rulings on limitation, ITC eligibility, classification, natural justice, and Section 74 ingredients are often decisive. AAR / AAAR rulings, while binding only on the applicant and the jurisdictional officer, also have persuasive value. We compile a structured case-law booklet for every hearing — with short head-notes, paragraph references, and the exact proposition each judgment supports — so that the officer has no difficulty in appreciating how binding precedent governs the matter at hand.
What is a Section 161 rectification and when is it useful?
Section 161 of the CGST Act allows rectification of any error or mistake apparent on the face of the record in any order, decision, notice, or other document passed under the Act — by the same authority that passed it. It is useful where the DRC-07 order has arithmetic errors, factually incorrect entries, orders on issues not raised in the SCN, or internal contradictions. A rectification application in Form DRC-08 is often a faster, cheaper route than a first appeal, especially for narrow errors. Where the real dispute is on facts or law itself, Section 161 is inappropriate and Section 107 appeal is the correct route.
What happens if we still lose at the adjudication stage?
An adverse DRC-07 order is appealable under Section 107 of the CGST Act before the first Appellate Authority. The appeal must be filed in Form GST APL-01 within three months (extendable by one month for sufficient cause) from the date of service of the order, along with a 10% pre-deposit of the disputed tax amount. Once a valid appeal with pre-deposit is filed, recovery of the balance is automatically stayed under Section 107(7). Because of this dynamic, every adjudication engagement is run with one eye on the appellate stage — building a record that makes the appeal, if needed, as strong as possible from day one.
Give Every GST Adjudication the Preparation It Deserves
Partner with our specialists for end-to-end GST Adjudication Support — written submissions, case-law briefs, paper books, personal hearings, DRC-07 review, and first appeal — all under one roof.
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