Jitendra Patel, Partner – Indirect Tax , N A Shah Associates LLP, defined to ET Wealth Online that below GST, every time the assessee intends to file an enchantment, they should deposit 10% of demand as pre-deposit with the authorities.
Patel says that many occasions in the middle of investigation or adjudication, the assessee could not settle for the competition of the authorities and pay a part of the quantity below protest in Form DRC 03. This cost is made on the presumption that it will likely be adjusted in opposition to pre-deposit payable with the Appellate authorities. However, the system up to now was not accepting the enchantment for cost of GST made in DRC 03.
Patel says: “Therefore in spite of pre-deposit being paid, there were issues with adjusting the pre-deposits. To solve the problem faced by the appellants, the authorities have introduced the concept of another form DRC 03A which will correlate the amount paid under protest etc in DRC 03 against the demand raised and subsequently adjust it as pre-deposit.”
Patel says that this advisory was lengthy due because it was wanted for adjusting GST paid in DRC 03 as pre-deposit and avoiding double cost of GST for submitting enchantment.
Patel says: “This will ease the technical issues faced by appellant and ensure smooth filing of the appeals. It was a very tax friendly move to address the procedural gap and stream lines pre-deposit for appeals.”
Chartered Accountant Deep Koradia stated to ET Wealth Online that every time a tax payer is aggrieved by any order and opts to file an enchantment, he must pay 10% of tax as pre deposit. Many a occasions a tax payer may need already paid portion of the tax by way of DRC 03 as a result of many causes corresponding to, cost below coercion throughout search / cost after order and so forth. however whereas submitting the enchantment on-line, such DRC03 was not ‘netted off’ in opposition to the stated order, portal was asking for pre deposit quantity.
Koradia says: “DRC03A is the form, which is released couple of years ago. By filling DRC03A, one can allocate amount paid via DRC03 against any order. Once done, portal won’t ask for pre deposit amount (and only ask for differential amount if such amount paid via DRC 03 falls short of 10%).”
According to Koradia, this alteration is already there on portal since lengthy and this advisory is explaining the methodology in order that aggrieved tax payer will not must pay pre deposit once more.
Koradia says: “It is worthwhile to take a note that whatsoever ‘admitted amount’ needs to be paid fully, and if any DRC 03 paid towards admitted amount than pre deposit needs to be paid for disputed tax portion as per section 107(6).”
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Details of GST DRC-03A
GSTN, in its advisory dated March 14, 2026 stated: Sometimes taxpayers voluntarily pay some quantity in the course of the investigation stage utilizing Form GST DRC-03. Later, when the taxpayer needs to file an enchantment software in opposition to the demand order issued after the investigation, they’re required to pay a pre-deposit to file the enchantment. However, many taxpayers complain that the GST portal nonetheless asks them to pay the pre-deposit even after they have already paid greater than the required quantity by means of Form GST DRC-03.
When a requirement order (for instance, Form GST DRC-07) is issued to a taxpayer, a Demand ID is created in Part II of the Electronic Liability Register on the GST portal. If the taxpayer makes a cost utilizing the “Payment towards Demand” performance on the portal, this quantity is robotically adjusted in opposition to the Demand ID within the register. However, funds made by means of Form GST DRC-03 are usually not linked to the Demand ID and subsequently don’t seem as adjusted in opposition to the demand within the legal responsibility register.
While submitting an enchantment by taxpayer, the GST System auto calculates the required quantity to be paid (i.e. admitted quantity + pre-deposit) and checks whether or not any quantity has already been paid by the taxpayer in opposition to the demand ID within the stated legal responsibility register.
A. If this quantity is the same as or higher than the required quantity, then the portal will permit the taxpayer to file an enchantment with out prompting for additional cost. The portal will present the beneath message, if the required quantity is already paid the taxpayer.
GSTN
B. If this quantity is lesser than the required quantity, then the portal mandates the taxpayer for the cost of steadiness payable.
Pre-deposit cost made by means of DRC 03:
As defined earlier, any cost made by means of Form GST DRC-03 shouldn’t be robotically acknowledged by the GST system in opposition to any particular Demand ID. Therefore, such funds are usually not thought of by the system whereas calculating the pre-deposit quantity required for submitting an enchantment.
To be sure that the cost made by means of Form GST DRC-03 is counted in opposition to a specific demand order, the cost should be linked with the respective Demand ID by submitting Form GST DRC-03A on the GST portal. Filing Form GST DRC-03A permits the cost made by means of DRC-03 to be mapped to the corresponding demand order, and the entry for a similar turns into obtainable within the Electronic Liability Register.
Consequently, on the time of submitting an enchantment, the system will acknowledge the cost (made by means of DRC 03 and adjusted utilizing DRC 03A) and won’t require the taxpayer to pay any extra quantity once more whereas calculating the obligatory pre-deposit.
Accordingly, taxpayers are suggested to file Form GST DRC-03A to hyperlink funds made by means of Form GST DRC-03 with the related demand order earlier than submitting an enchantment, wherever relevant.
