Introduction: The Rise of Automated GST Notices
India’s GST ecosystem has entered a phase where technology-led scrutiny has replaced manual, officer-driven reviews. With real-time analytics, cross-return validations, and data triangulation from multiple sources such as GSTR-1, GSTR-3B, GSTR-2B, e-invoicing, and e-way bills, tax authorities are now able to identify discrepancies at scale and issue automated intimations without human intervention.
Among the most significant outcomes of this shift is the rise of automated GST notices, particularly Form DRC-01B and Form DRC-01C. These notices are not traditional show-cause notices, but system-generated intimations triggered when deviations cross prescribed risk thresholds. Importantly, they directly impact return filing, cash flows, and even business continuity if not addressed in time.
Understanding what triggers these notices, how to respond correctly, and how to prevent them has therefore become a core GST governance requirement, not merely a compliance task.
What Are DRC-01B and DRC-01C Notices?
What Is a DRC-01B Notice?
A DRC-01B notice is an automated intimation issued when there is a mismatch between tax liability declared in GSTR-1 (or IFF) and tax actually paid through GSTR-3B for a tax period.
In simple terms, when:
- Outward supplies reported in GSTR-1/IFF exceed
- Tax liability declared and paid in GSTR-3B, by an amount or percentage notified by the GST Council,
The system automatically issues Form DRC-01B requiring the taxpayer to either:
- Pay the differential tax along with applicable interest, or
- Explain the difference within the stipulated time.
This mechanism is designed to enforce discipline around self-assessed tax liabilities, treating mismatches as potential short payment unless satisfactorily explained.
What Is a DRC-01C Notice?
A DRC-01C notice relates to Input Tax Credit (ITC) mismatches.
It is issued when:
- ITC claimed in GSTR-3B exceeds
- ITC available as per GSTR-2B, by such amount or percentage as recommended by the Council.
This essentially flags situations where ITC has been availed beyond what is reflected in supplier-uploaded data, triggering concerns around excess or ineligible credit claims
Like DRC-01B, taxpayers must either:
- Reverse and repay excess ITC with interest, or
- Provide a valid explanation for the difference within 7 days
Key Causes of Automated GST Notices
Understanding the reasons for DRC-01B notice and reasons for DRC-01C notice is critical, because not all mismatches indicate tax evasion or non-compliance. Many arise from timing differences, adjustments, or genuine reporting issues.
Causes of DRC-01B (GSTR-1 vs GSTR-3B Mismatch)
Common reasons include:
- Adjustment of excess tax paid in previous months against current liability
- Timing differences, where tax was paid earlier but invoices are reported later
- Errors in GSTR-1 or IFF, intended to be corrected in subsequent periods
- Incorrect classification or reporting under wrong tables in GSTR-3B (especially Table 3.1)
- B2C to B2B conversions or amendments not aligned across returns
While these differences may be legitimate, the system treats them as short payment of self-assessed tax unless clarified.
Causes of DRC-01C (ITC Mismatch Under GST)
DRC-01C notices commonly arise due to:
- ITC pertaining to earlier periods, availed later due to delayed receipt of goods/services
- Import or SEZ credits, which are not reflected in GSTR-2B
- Reclaim of ITC reversed earlier under Rule 37 or Rule 37A
- Clerical or reporting errors in GSTR-3B, intended to be adjusted subsequently
- Excess reversal reclaim, where prior reversals exceed actual ineligibility
These situations highlight that GSTR-2B is not always a complete reflection of eligible ITC, yet automated systems rely on it as a baseline for risk detection.
How to Respond to DRC-01B and DRC-01C Notices
Both DRC-01B and DRC-01C notices require action within seven days from the date of intimation. Taxpayers must either discharge the differential amount along with interest or submit a satisfactory explanation through Part B of the respective DRC form.
Responding to a DRC-01B Notice
Where the mismatch reflects an actual short payment, the differential tax and applicable interest should be paid promptly and reported in Part B of DRC-01B. If the difference is due to timing issues, prior-period adjustments, or reporting corrections, a clear and well-documented explanation should be furnished.
Failure to respond has immediate consequences. Filing of GSTR-1 or IFF may be blocked, and the unpaid amount becomes recoverable under Section 79 without the need for a show-cause notice. This makes timely response essential to avoid disruption to regular compliance cycles.
Responding to a DRC-01C Notice
In cases of excess ITC, taxpayers must either reverse and repay the ineligible credit with interest or provide a reasoned explanation justifying the difference. If no action is taken within the stipulated timeframe, the system may block future return filings.
Unlike DRC-01B, unresolved DRC-01C notices can also expose businesses to proceedings under Sections 73 or 74, depending on the nature of the discrepancy. Accurate documentation and prompt clarification therefore play a critical role in mitigating risk.
How to Prevent Future GST Notices
With automated scrutiny becoming the norm, prevention is no longer optional. The concept note outlines several best practices that businesses should institutionalize.
Preventing DRC-01B Notices
- Perform monthly and YTD reconciliation between GSTR-1 and GSTR-3B before filing
- Adjust liability changes in the same period where amendments occur
- Ensure correct reporting under appropriate tables in GSTR-3B
- Maintain a single source of truth for outward supply and tax liability data
- Track B2C/B2B amendments and credit notes carefully
Early identification of mismatches allows corrective action before the system triggers an automated notice
Preventing DRC-01C Notices
- Closely monitor GSTR-2B vs ITC availed on a cumulative basis
- Disclose reversals and reclaims accurately in GSTR-3B
- Temporarily reverse excess ITC until reflected in GSTR-2B
- Strengthen purchase reconciliation processes
- Use ITC reconciliation not just for compliance, but also for cash-flow optimization
The note also highlights the importance of Electronic Credit and Re-claimed Statements to track reclaims of previously reversed ITC and avoid duplication or excess claims
Conclusion
DRC-01B and DRC-01C notices are not isolated from compliance alerts; they are signals of how the GST ecosystem now functions. With real-time analytics, automated thresholds, and system-driven enforcement, GST compliance has shifted from periodic filing to continuous governance.
Businesses that continue to treat GSTR-1, GSTR-3B, and GSTR-2B as independent filings risk repeated automated GST notices, blocked returns, recovery proceedings, and operational disruption. Those that invest in strong reconciliations, disciplined reporting, and timely responses can significantly reduce exposure while improving cash-flow predictability and audit readiness.
In the automated GST era, accuracy at the first point of data capture is no longer best practice; it is a necessity.