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Why GST and income tax notices go unanswered, and what it costs

GST and income tax notices are served electronically with short response windows. Missed notices become ex parte orders, and the appeal costs more than the tax. This is an ownership problem, not a tax problem.

Kavita IyerDirector of Solution Architecture3 min read0 views

A manufacturer with registrations in eleven states receives a GST notice on the portal for one of them. The notice allows fifteen days. Nobody logs into that particular portal for six weeks. An ex parte order follows.

The underlying tax position was defensible. It is now a first appeal with a pre-deposit, eighteen months of process, and a provision in the accounts.

This happens constantly, and it is not a tax expertise problem.

Why electronic service changes the operating model

Notices used to arrive physically at a registered address, where a person received them. Electronic service moved delivery to a portal, and the portal does not push — it holds.

For a single-registration business this is fine; somebody logs in weekly. For a multi-state business it produces a specific failure: eleven portals, each requiring credentials, each holding its own notices, and no single view of what has arrived where.

Compound that with income tax e-proceedings, state VAT legacy assessments, customs and DGFT communications, and the number of places a time-limited communication can arrive is substantial.

The three failures, in order of frequency

Nobody logs in. The portal for a small registration in a state with minimal operations is checked rarely, and that is exactly where a notice sits unread.

It is seen and not routed. A finance executive sees the notice, does not appreciate the deadline, and files it for discussion at the monthly review that falls after the response date.

It is routed and not tracked. It reaches the tax team, who engage a consultant, and nobody holds the deadline. The response goes in late or not at all.

All three are ownership and tracking failures. None require better tax knowledge.

What good looks like

A named owner per registration. Every GSTIN, every registration, every portal has one person accountable for checking it, with a named backup. This sounds trivial and is frequently absent.

A defined check cadence, evidenced. Portals checked on a schedule, with the check itself recorded. A weekly check that nobody can prove happened is not a control.

Notice intake as a single register. Every notice, from any authority, logged centrally on receipt with authority, registration, date received, deadline, owner and status. One register, not eleven inboxes.

Deadline-driven escalation. Escalation triggered by proximity to deadline, not by the monthly review calendar. A fifteen-day notice does not survive a monthly cadence.

Linkage to the underlying obligation. A notice about input tax credit mismatch relates to a specific obligation. Linking them means recurring notices reveal an underlying process failure rather than being handled as unrelated events.

That last point is where the value compounds. Organisations that log notices centrally usually discover, within two quarters, that a disproportionate share come from one or two root causes — a reconciliation that is not being done, or a vendor who does not file. That is fixable. Handling each notice individually never surfaces it.

The continuous-testing version

Everything above is process. The measurable version is testing the underlying position against the data continuously: reconciling input tax credit against the auto-populated statement across the full population every month, rather than discovering the mismatch when the notice arrives.

That is what continuous compliance testing means in an Indian tax context, and it is the difference between responding to notices and not receiving them.

TaxGSTOperating model

Written by Kavita Iyer, Director of Solution Architecture

Part of the team that builds and maintains the Regulens obligation library and platform. If you disagree with something here, we would genuinely like to hear it — get in touch.

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