Start from the existing-law order
CGST Rule 142A deals with amounts that become recoverable from proceedings launched under an existing law before, on or after the appointed day. Unless recovered under that law, they are recoverable under GST through the applicable transitional mechanism. The recovery authority may upload the order summary in DRC-07A; the demand is posted in Part II of the electronic liability register, PMT-01. Section 142(8)(a), for example, provides for recovery as arrears under GST of qualifying sums from existing-law assessment or adjudication if not recovered under the existing law, and denies input tax credit for the amount so recovered. The upload does not create a fresh adjudication under GST or change the law governing the underlying dispute.
Read the applicable text: CGST Act, section 142 transitional provisions; Notification No. 60/2018–Central Tax of 30 October 2018: Rule 142A, PMT-01 Part II and DRC-07A/08A; CBIC consolidated forms and instructions.
Reconcile the opening posting
Identify the old registration, GSTIN, governing enactment, authority, original order and latest operative order. Match tax, interest, penalty, fee and other dues to the posted heads and dates. The DRC-07A instructions capture amounts already paid under the existing law up to the upload date. Reconcile Table 19 (demand) less Table 20 (existing-law payments) to Table 21 (balance). Verify recoverability, service, any stay and amounts already credited under the old law. Resolve any head-mapping gap without changing the total debt.
Use DRC-08A for a supported later change
Rule 142A(2) addresses rectification, modification, quashing or recovery under the existing law after upload. The summary is uploaded in DRC-08A and Part II of PMT-01 updated accordingly. Link it to the original DRC-07A reference and the operative order or evidence of recovery. An appeal filing and an order granting relief are different events. Use the legally operative position at the reconciliation date.
Track one debt across both systems
Keep a schedule of original demand, later legally effective changes, recovery under the existing law, GST recovery credits and closing recoverable amount. Show unallocated remittances separately. If the portal still shows a superseded amount, preserve the order and credit evidence and take the discrepancy to the competent authority. Do not assume a payment is allocated from its bank date alone or that a GST portal entry creates an input tax credit entitlement.
Six worked illustrations
All facts and amounts are fictional. Calculations illustrate the stated assumptions, not a predetermined legal outcome.
Illustrative example 1: Opening amount already partly paid
A legacy order shows ₹4,50,000 tax and ₹90,000 interest. With ₹1,40,000 credited under the old law before upload, the balance for reconciliation is ₹4,00,000 rather than ₹5,40,000.
Illustrative example 2: Later appellate reduction
Original recoverable dues were ₹6,00,000, of which ₹1,00,000 had been credited. An operative appellate order reduces gross dues by ₹1,50,000. On these assumptions the revised unpaid balance is ₹3,50,000.
Illustrative example 3: Old-law payment after posting
₹3,20,000 was correctly posted and ₹80,000 is later recovered under the existing law. The remaining amount is ₹2,40,000; reconcile the DRC-08A update to the new credit.
Illustrative example 4: Duplicate recovery record
Against ₹2,75,000, one payment of ₹55,000 appears in both systems with the same underlying receipt. It reduces the balance once, to ₹2,20,000.
Illustrative example 5: Quashed order
An operative order quashes the entire ₹1,90,000 uncollected demand. On the stated facts the resulting recoverable balance is nil; compare it with the portal and obtain the appropriate update.
Illustrative example 6: Head-mapping gap
An order has ₹1,50,000 tax, ₹24,000 interest and ₹6,000 penalty. A portal summary shows ₹1,50,000 tax and ₹30,000 interest. Both total ₹1,80,000, but ₹6,000 is misclassified. Flag the component mismatch despite a matching total.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Obtain the original demand | Existing-law order and registration. |
| 2 | Identify the operative latest order | Orders, service and current legal position. |
| 3 | Verify recoverability and stays | Case status and supporting directions. |
| 4 | Reconcile credits before upload | Old-system payment and recovery evidence. |
| 5 | Verify DRC-07A identity fields | Original references, GSTIN and old registration. |
| 6 | Tie posting to PMT-01 Part II | Head and amount comparison. |
| 7 | Identify later changes | Rectification, modification, quashing or recovery proof. |
| 8 | Match the DRC-08A reference | Original posting and later summary. |
| 9 | Reconcile both recovery channels | Single demand and unique collection references. |
| 10 | Archive the signed remaining balance | Latest ledger and unresolved exception log. |
Sixteen practitioner FAQs
1. Is a DRC-07A upload a new tax demand under GST?
It is a summary of an order under an existing law for recovery purposes.
2. Must proceedings have started before GST?
Rule 142A covers qualifying existing-law proceedings launched before, on or after the appointed day.
3. Can a demand already recovered in full be recovered again?
No. Verify and reconcile the recovery evidence.
4. Who posts the summary?
The authorised recovery authority uploads the order summary; the taxpayer reconciles the posting.
5. Which register is updated?
Part II of PMT-01.
6. What is DRC-08A used for?
It records a later change of the kind set out in Rule 142A(2).
7. Is DRC-08A the same as DRC-08?
No. The forms concern different underlying proceedings.
8. What if a prior appeal modifies only interest?
Update that component on the basis of the operative order.
9. Can a stayed amount be treated as freely recoverable?
Review the operative stay and its scope.
10. Should pre-upload payments be captured?
Yes. Reconcile them separately from later recovery.
11. What if a later payment appears in both ledgers?
Use unique references and count the credit once.
12. What if the old registration and GSTIN names differ?
Establish legal identity and registration mapping before attributing the debt.
13. Can total agreement conceal a mistake?
Yes. Verify tax, interest, penalty and other components.
14. What if a quashing order has not reached the portal?
Retain the operative order and seek a supported update.
15. Does the posting establish ITC eligibility?
No. Review the statutory transition and credit rules separately.
16. What belongs in a close file?
Underlying orders, summary references, credited recoveries and a documented remaining balance.
Official sources
CGST Act, section 142 transitional provisions; Notification No. 60/2018–Central Tax of 30 October 2018: Rule 142A, PMT-01 Part II and DRC-07A/08A; CBIC consolidated forms and instructions