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.
Where service of SCN or passing of order is stayed by court / tribunal, the stay period is excluded from limitation.
Personal hearing must be granted where requested in writing or where any adverse order is contemplated.
Adjournments can be granted for sufficient cause, subject to a statutory cap of three adjournments per proceeding.
The adjudication order must set out reasons and cannot travel beyond the grounds specified in the SCN.
Deep re-reading of the SCN, earlier DRC-06, and annexures to crystallise the real issues in dispute.
Supplementary written submissions focusing on the strongest legal grounds and documentary evidence.
Curated bunch of Supreme Court, High Court, and Tribunal decisions supporting the taxpayer's position.
Structured oral arguments, responding to officer's questions, and filing additional submissions on the spot.
Using the three adjournments under Section 75(5) strategically for data gathering and counsel coordination.
Filing fresh documents, reconciliations, and declarations to address officer's queries during adjudication.
Technical review of the final order — findings, reasoning, quantum — for appealable infirmities.
Rectification of mistakes apparent on record before going into full-blown appeal, where appropriate.
End-to-end preparation of the adjudication brief — factual map, legal grounds, exhibits, case law, and narrative.
Attending personal hearing, oral advocacy, supplementary submissions, and clarification of complex points.
Clause-by-clause review of the DRC-07 order and preparation for rectification or first appeal.
Comprehensive legal strategy memo covering issues, defences, risks, precedents, and probable outcomes.
Supplementary written submissions to the DRC-06 reply, refined with the benefit of hindsight and fresh inputs.
Curated case-law compilation — relevant SC, HC, Tribunal, and AAR decisions — filed along with submissions.
Structured paper book with indexed exhibits for ease of reference during hearing and order drafting.
Appearance at personal hearings with oral arguments, question handling, and real-time evidence submission.
Protecting procedural rights — hearing denial, orders beyond SCN, absence of reasons, and limitation.
Detailed review of the adjudication order for reasoning, findings, and appealable infirmities.
Section 161 rectification petitions for clear errors, and seamless first appeal under Section 107 where needed.
SCN demand is large enough that a full-blown adjudication defence is economically worthwhile.
SCN invokes Section 74 on fraud / suppression grounds that need to be actively contested.
Dispute on HSN / SAC classification or rate applicability with significant tax impact.
SCN disputing zero-rated treatment, LUT exports, or refund claims under Rule 89 / 96.
Alleged availment of ITC on fake / non-existent vendor invoices — serious exposure and reputation risk.
Earlier stage saw hearing denial, incomplete record, or orders traveling beyond SCN grounds.
Complex SCN covering multiple legal issues across multiple years needing disciplined handling.
Dispute has implications for future years or other group entities — order needs to be managed carefully.
Deep review of SCN, DRC-06, and prior record to identify the best lines of defence.
Issue-wise strategy memo covering law, facts, risk, and target outcome for each issue.
Drafting written submissions, case-law compilation, and structured paper book / exhibits.
Attending hearings with oral arguments, additional submissions, and live query handling.
DRC-07 review, Section 161 rectification where applicable, and first appeal if needed.
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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