A GST demand or show cause notice can be devastating — but you do not face it alone. PJRJ combines CA-tax technical depth with experienced legal advocacy at every level of the GST dispute resolution machinery.
We analyse facts and law thoroughly, engage the department early where escalation can be avoided, and advocate fearlessly when appeals or writs are necessary.
Litigation forums we cover
Level 1 — Departmental proceedings
Adjudicating authority — GSTO and Assistant/Deputy Commissioner.
- Show cause notice (SCN) replies
- DRC-01 / DRC-01A responses
- Personal hearing representation
- Audit, scrutiny, and inspection support
Level 2 — Commissioner (Appeals)
First appeal against adverse orders-in-original.
- Memorandum of appeal (APL-01)
- Stay of recovery applications
- Paper book compilation
Level 3 — GSTAT
Goods and Services Tax Appellate Tribunal — handled in-house by our tax team.
- Appeals and cross-appeals
- Statement of facts and grounds
- National and State Bench representation
Level 4 — High Court
Delhi, Bombay, Madras, Gujarat, and other High Courts via empanelled advocates.
- Article 226 writ petitions
- Appeals on substantial questions of law
- Challenges to provisional attachment
- Refund withholding matters
Level 5 — Supreme Court
Apex Court practice through Advocates on Record and senior counsel.
- SLPs under Article 136
- Constitutional challenges
- Caveat petitions
- Senior counsel briefing
Additional litigation support
- Legal opinion and second opinion on pending matters
- Section 73 vs. 74 demand strategy
- Penalty waiver and interest challenge
- Recovery proceeding defence — bank attachment challenges
- DGGI summons, search, and seizure support
GST Litigation FAQs
Can the GST department attach my bank account?
Yes, under Section 83 during pendency of specified proceedings. Unlawful attachments can be challenged in a High Court writ. We have obtained interim stays for clients in such matters.
What is the time limit for filing a GST appeal?
Three months to the Commissioner (Appeals), extendable by one month for sufficient cause. Three months to GSTAT from the Commissioner (Appeals) order. Contact us immediately on receiving an adverse order.
Discuss your gst litigation requirements
Speak directly with a PJRJ GST specialist — we respond within one business day.