No more double GST while filing appeals: GSTN fixes issue with new GST DRC- 03A form; what taxpayers should know

A long-standing issue raised by GST-registered taxpayers has been addressed by the Goods and Services Tax Network (GSTN). The issue was that any payment made through Form GST DRC-03 wasn’t automatically recognized by the GST system for any specific Demand ID. As a result, such payments were overlooked by the system while calculating the pre-deposit amount needed to file an appeal. This led to situations where taxpayers had to make double GST payments just to file an appeal against any GST order. Now, this issue has been resolved with the new GST DRC-03A form.

Jitendra Patel, Partner – Indirect Tax , N A Shah Associates LLP, explained to ET Wealth Online that under GST, whenever the assessee intends to file an appeal, they need to deposit 10% of demand as pre-deposit with the authorities.

Patel says that many times in the course of investigation or adjudication, the assessee may not accept the contention of the authorities and pay part of the amount under protest in Form DRC 03. This payment is made on the presumption that it will be adjusted against pre-deposit payable with the Appellate authorities. However, the system so far was not accepting the appeal for payment 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 long due as it was needed for adjusting GST paid in DRC 03 as pre-deposit and avoiding double payment of GST for filing appeal.

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 said to ET Wealth Online that whenever a tax payer is aggrieved by any order and opts to file an appeal, he needs to pay 10% of tax as pre deposit. Many a times a tax payer might have already paid portion of the tax via DRC 03 due to many reasons such as, payment under coercion during search / payment after order etc. but while filing the appeal online, such DRC03 was not 'netted off' against the said order, portal was asking for pre deposit amount.

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 change is already there on portal since long and this advisory is explaining the methodology so that aggrieved tax payer won't need to pay pre deposit again.

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)."

Also read: GSTAT: The missing piece in India’s GST framework finally falls in place

Details of GST DRC-03A

GSTN, in its advisory dated March 14, 2026 said: Sometimes taxpayers voluntarily pay some amount during the investigation stage using Form GST DRC-03. Later, when the taxpayer wants to file an appeal application against the demand order issued after the investigation, they are required to pay a pre-deposit to file the appeal. However, many taxpayers complain that the GST portal still asks them to pay the pre-deposit even when they have already paid more than the required amount through Form GST DRC-03.

Also read: Ease in GST appeal: Now you can make pre-deposit payment for through input tax credit, rules Supreme Court, know who will benefit from it

When a demand order (for example, 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 payment using the “Payment towards Demand” functionality on the portal, this amount is automatically adjusted against the Demand ID in the register. However, payments made through Form GST DRC-03 are not linked to the Demand ID and therefore do not appear as adjusted against the demand in the liability register.

While filing an appeal by taxpayer, the GST System auto calculates the required amount to be paid (i.e. admitted amount + pre-deposit) and checks whether any amount has already been paid by the taxpayer against the demand ID in the said liability register.

A. If this amount is equal to or greater than the required amount, then the portal will allow the taxpayer to file an appeal without prompting for further payment. The portal will show the below message, if the required amount is already paid the taxpayer.

Source: GSTN Advisory

B. If this amount is lesser than the required amount, then the portal mandates the taxpayer for the payment of balance payable.

Pre-deposit payment made through DRC 03:

As explained earlier, any payment made through Form GST DRC-03 is not automatically recognized by the GST system against any specific Demand ID. Therefore, such payments are not considered by the system while calculating the pre-deposit amount required for filing an appeal.

To ensure that the payment made through Form GST DRC-03 is counted against a particular demand order, the payment must be linked with the respective Demand ID by filing Form GST DRC-03A on the GST portal. Filing Form GST DRC-03A enables the payment made through DRC-03 to be mapped to the corresponding demand order, and the entry for the same becomes available in the Electronic Liability Register.

Consequently, at the time of filing an appeal, the system will recognize the payment (made through DRC 03 and adjusted using DRC 03A) and will not require the taxpayer to pay any additional amount again while calculating the mandatory pre-deposit.

Accordingly, taxpayers are advised to file Form GST DRC-03A to link payments made through Form GST DRC-03 with the relevant demand order before filing an appeal, wherever applicable.