ALERT Received a GST DRC-01 Notice? Respond within 30 days. Let our experts review your case documentation. Get Notice Support
ALERT Received a GST DRC-01 Notice? Respond within 30 days. Let our experts review your case documentation. Get Notice Support
ALERT Received a GST DRC-01 Notice? Respond within 30 days. Let our experts review your case documentation. Get Notice Support

Litigation

Structured drafting, document trail building, and coordination support for GST and Income Tax disputes across Gujarat.

DRC-01 Notice DRC-07 Order ASMT-10 Scrutiny APL-01 Appeal Section 148 Reassessment
GST Appeals
Technical Replies
Reassessments

Important Legal Notice (ICAI Compliance)

Please be advised that all formal representations before tax authorities, appellate forums, and legal bodies are conducted solely by qualified, independent Chartered Accountants and Advocates. Numero One Tax and Legal Private Limited is not a licensed auditing body or legal firm; our role is strictly limited to litigation support, data analysis, documentation assistance, and coordination services.

Scope of Support

Litigation Support Services

Technical drafting and documentation coordination across core tax dispute areas.

GST Notice Replies (Section 61 / 73 / 74)

Assistance in analyzing audit findings, drafting responses to scrutiny notices (Form GST ASMT-10), and preparing comprehensive legal replies to formal show-cause notices (Form GST DRC-01).

GST First Appeals (Section 107)

End-to-end documentation preparation, statement of facts drafting, and procedural coordination for filing first appeals (Form GST APL-01) before the Joint Commissioner (Appeals).

Scrutiny Assessments (Section 143(3))

Detailed analysis of questionnaire requirements in regular scrutiny, preparing data trails, and drafting submissions for portal uploading under the Faceless Assessment Scheme (Section 144B).

Income Tax Reassessments (Section 147 / 148)

Challenging reopening procedures by drafting replies to preliminary show-cause notices (Section 148A), identifying procedural gaps, and coordinating return filings in response to Section 148.

CIT (Appeals) & ITAT Support (Section 246A / 253)

Technical compiling of Paper Books, drafting Grounds of Appeal (Form 35), and professional coordination for representation before the CIT (Appeals), Joint Commissioner (Appeals), and ITAT.

Rectifications & PCIT Revisions (Section 154 / 263 / 264)

Assistance in drafting petitions for rectification of apparent errors in tax orders (Section 154) and preparing revision applications before the Principal Commissioner of Income Tax.

Appellate Hierarchies

Statutory Appellate Forums

Understanding the standard stages of representation for GST and Income Tax matters.

GST Appeal Channels

Stage 1: Adjudicating Authority Superintendent / Assistant Commissioner / Joint Commissioner issuing original order.
Stage 2: First Appellate Authority Commissioner (Appeals) or Joint Commissioner (Appeals) — filing GST APL-01 within 3 months.
Stage 3: GST Appellate Tribunal (GSTAT) The statutory second appeal forum for disputes on facts and law.
Stage 4: Judicial Review Hon'ble High Court of Gujarat and eventually the Supreme Court of India.

Income Tax Appeal Channels

Stage 1: Assessing Officer (AO) Assessment Unit / National Faceless Assessment Centre (NFAC) passing order under Section 143(3) / 147.
Stage 2: First Appellate Authority Commissioner of Income Tax (Appeals) or Joint Commissioner (Appeals) — filing Form 35 within 30 days.
Stage 3: Income Tax Appellate Tribunal (ITAT) The final fact-finding authority. Appeals are filed under Section 253.
Stage 4: Judicial Review Hon'ble High Court of Gujarat (substantial questions of law) and Supreme Court of India.
Methodology

Our Response Preparation Workflow

A system-driven process to ensure documentation trails are accurate and robust.

Fact & Data Review

Analyze notices/orders in detail. Reconcile matching records (e.g., GSTR-2B matching) and compile supporting invoices to verify actual numbers.

Statutory Research

Identify applicable provisions, relevant notifications, department circulars, and matching judicial precedents from Hon'ble High Courts and Supreme Court.

Response Drafting

Prepare structured, point-by-point replies detailing preliminary submissions, facts, and legal contentions, supported by clear document index arrays.

Coordination

Coordinate portal submissions, track hearing calendars, and support qualified independent CAs/Advocates in representing the case.

Regulatory Disclosure & Scope of Services

Numero One Tax and Legal Private Limited is a corporate consulting and business support firm. We are not a practicing Chartered Accountant firm or legal advocacy partnership under the regulatory purview of the Institute of Chartered Accountants of India (ICAI) or the Bar Council of India.

All statutory audit functions, independent attest certifications, and direct representations before appellate authorities or judicial bodies are handled strictly by independent, practicing CAs and Advocates engaged specifically for those engagements. Our role is limited to data analysis, documentation preparation, drafting support, and general coordination.

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