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
DRC-03 Payments Must Be Linked via DRC-03A for Appeal Pre-deposit Recognition: GSTN Taxpayers in India face challenges with the Goods and Services Tax (GST) portal’s process for handling pre-deposit requirements when filing appeals. Despite making voluntary payments during investigations, many are still prompted to pay again when submitting appeals to the First Appellate Authority. The issue stems from how the system processes payments made through Form GST DRC-03. According to a recent advisory from GSTN, payments submitted via Form GST DRC-03 are not automatically connected to any demand order in the Electronic Liability Register. This means the system does not recognize these payments when determining the mandatory pre-deposit required for appeals. When a demand order, such as Form GST DRC-07, is issued, a Demand ID is created in the Electronic Liability Register. If taxpayers pay using the “Payment towards Demand” option, the portal adjusts the payment against that Demand ID. However, payments made through Form GST DRC-03 lack this linkage and do not appear as adjusted against the demand in the register. The advisory clarifies that the GST system does not automatically recognize payments made via Form GST DRC-03 against any specific Demand ID. As a result, these amounts are not factored into the pre-deposit calculation for appeals. To address this, GSTN has introduced Form GST DRC-03A, which allows taxpayers to manually link their voluntary DRC-03 payments to the relevant Demand ID. Once linked, the payment is recognized in the liability register, ensuring it is accounted for during the appeal process. This prevents duplicate pre-deposit requests and reduces unnecessary financial burdens on taxpayers.#goods_and_services_tax #gstn #form_gst_drc_03 #form_gst_drc_07 #electronic_liability_register
