GST Portal Clarifies DRC-03A Process for Appeal Pre-Deposits The Goods and Services Tax Network (GSTN) issued an advisory on March 14, 2026, addressing a recurring issue faced by taxpayers when filing first appeals under the Central Goods and Services Tax Act, 2017. The problem arises when an assessee has already made payments through Form GST DRC-03 during earlier stages of tax proceedings, such as investigations or audits, but the GST portal still requires a statutory pre-deposit for appeals. The advisory emphasizes that the key issue is whether such prior payments are properly reflected in the Electronic Liability Register, which is critical for appeal compliance. Under Section 107(6) of the CGST Act, taxpayers must fulfill two monetary conditions to file an appeal: full payment of admitted liability and a 10% statutory pre-deposit on disputed tax. However, payments made through DRC-03 during pre-adjudication stages are not automatically linked to the final demand order. This creates a situation where taxpayers may be required to pay the same amount twice, once through DRC-03 and again as a pre-deposit for the appeal. To resolve this, the GSTN advisory highlights the importance of Form GST DRC-03A, introduced via Notification No. 12/2024-Central Tax dated July 10, 2024. This form allows taxpayers to formally adjust prior DRC-03 payments against the relevant demand in the Electronic Liability Register. Once DRC-03A is filed, the earlier payment is treated as if it was made directly against the demand, enabling it to be counted toward the appeal pre-deposit requirement. The Central Board of Indirect Taxes and Customs (CBIC) further clarified this process in Circular No. 224/18/2024-GST dated July 11, 2024. The circular explains that many taxpayers inadvertently made payments through DRC-03 instead of addressing specific outstanding demands.#gstn #cbic #drc_03a #cgst_act #drc_03
