How long do I have to respond to a DGTR questionnaire?

The standard period is commonly around 37 days from the date the questionnaire is issued, though the exact period varies by case. DGTR does sometimes grant a short extension on a reasoned request, but that request has to be made before the original deadline expires, not after it.

My company was not named in the initiation notification. Am I still covered?

Very likely yes. If your product falls within the described scope and originates in a country covered by the investigation, you are a covered exporter whether or not you were named individually. Do not treat an absence of direct notice as an exclusion.

Can a foreign exporter respond without appointing Indian counsel?

An interested party needs an authorised representative to file submissions, attend the oral hearing and correspond with DGTR on the case. Foreign producers and exporters routinely appoint Indian counsel for this; it is standard practice in DGTR proceedings, not an exception.

What happens during DGTR verification?

Verification officers check the figures in your questionnaire response against the underlying accounting records, sales invoices and cost sheets, either at your premises or remotely. Every figure submitted should be traceable back to your own books before the visit, not located during it.

What is a disclosure statement and how do I respond to it?

The disclosure statement sets out DGTR’s essential facts and reasoning before the final finding is issued. It should be checked line by line against your own questionnaire response, and comments highlighting any factual or calculation disagreement should be filed within the window DGTR sets, since this is usually the last opportunity to affect the outcome before it becomes final.

What happens if we simply do not respond?

Non-participation is not a neutral choice. Rule 6(8) of the Anti-Dumping Rules, 1995 allows DGTR to base its determination on facts available where a party fails to cooperate, which in practice means the domestic industry’s own figures. An exporter that stays silent typically ends up with a higher duty than one that participates properly.

Can an unfavourable final finding be appealed?

Yes. Section 9C of the Customs Tariff Act, 1975 allows an appeal to the CESTAT against an order relating to anti-dumping or countervailing duty. Note that an appeal does not automatically suspend the duty, so the commercial and the legal timelines both need tracking from the date of notification.

How to Respond to an Anti-Dumping Investigation in India?

Quick answer

How to respond to an anti-dumping investigation in India, in short: read the DGTR initiation notification and confirm whether your product falls within its scope even if you are not named; calendar every deadline the day it is published; appoint an authorised representative in the first week or two; file a complete exporter or producer questionnaire response, commonly due around 37 days from issue; prepare for on-site verification by mapping every figure to its source document; answer deficiency letters with the same urgency as the questionnaire; attend the oral hearing; review the disclosure statement line by line and file comments; track the final finding and the Section 9C appeal to CESTAT; and if duty is imposed, watch the five-year sunset review clock. Non-participation lets DGTR decide on facts available under Rule 6(8), which usually produces a higher duty.

If you are reading this, you have probably just been named in a petition, received a DGTR initiation notification, or been told by a customer or an Indian agent that an anti-dumping case has been filed against your product. This guide answers the question directly: how to respond to an anti-dumping investigation in India, in the order the process actually happens, from the first notification through to the final finding. Marg Tax Advisors handles these matters for foreign producers, exporters and Indian importers, and this is the same sequence we walk clients through when a case starts.

What an Anti-Dumping Investigation in India Actually Is

Anti-dumping duty in India is governed by Section 9A of the Customs Tariff Act, 1975, and the Anti-Dumping Rules, 1995, administered by the Directorate General of Trade Remedies (DGTR) under the Ministry of Commerce and Industry. DGTR has to establish three things before a duty is imposed: a dumping margin (the exported goods are priced below their normal value), material injury to the Indian domestic industry, and a causal link between the two.

Want the legal background instead?

Our Anti-Dumping Duty Process in India page sets out how the investigation is structured start to finish, including how the dumping and injury margins are calculated.

The Ten Steps, in the Order They Happen

The table below is the sequence at a glance, with the timing that actually drives each step. Each one is explained in full underneath.

Responding to a DGTR investigation: the sequence and its timing
Step	What You Do	When
1. Read the notification	Confirm whether your product and country fall within the scope, named or not	Day it is published
2. Calendar deadlines	Map every DGTR date before anything else is done	Same day
3. Appoint representation	Authorised representative to file, appear and correspond	First 1 to 2 weeks
4. File the questionnaire	Complete response, every figure traceable to your books	Commonly ~37 days from issue
5. Prepare for verification	Map each answer to its supporting document in advance	Before the visit date
6. Answer deficiency letters	Full responses to DGTR queries on your submission	Within the letter's own deadline
7. Attend the oral hearing	Reinforce the written record, not introduce new arguments	As scheduled by DGTR
8. Comment on disclosure	Check the essential facts line by line against your response	Within DGTR's stated window
9. Track finding and appeal	Section 9C appeal to CESTAT where the finding is wrong	From the date of notification
10. Watch the sunset clock	Duty runs 5 years unless a sunset review extends it	Start watching in year 4

Step 1: Read the initiation notification carefully and confirm your status

The investigation formally begins with an initiation notification, published in the Gazette of India and on the DGTR website, naming the product under investigation, the countries covered, and in many cases specific exporters or producers. The first thing to establish is whether you are named directly, whether your product falls within the described scope even if you are not named, and what deadline the notification sets for your first response. Do not assume a notification that does not name your company does not apply to you; if your product matches the description and country of origin, you are very likely a covered exporter even without being named individually. Many companies first learn of an investigation from an Indian buyer, an industry association circular, or a trade lawyer monitoring DGTR's public case list, rather than direct notice from DGTR itself, so it is worth checking the DGTR website's own case database periodically if your product is one that has faced scrutiny before.

Step 2: Calendar every deadline the same day the notification is published

DGTR investigations run on strict, largely non-negotiable timelines. The standard period to file a questionnaire response is commonly around 37 days from the date the questionnaire is issued, though the exact number can vary by case and DGTR does sometimes grant a short extension on a reasoned request submitted before the original deadline expires, not after. Missing this window is one of the most common and most costly mistakes an exporter can make.

Step 3: Appoint legal representation early, not after the first deadline slips

An interested party in a DGTR investigation, whether a foreign producer, exporter or Indian importer, needs an authorised representative to file submissions, attend the oral hearing and correspond with DGTR on the case. Appointing counsel in the first one to two weeks after the notification, rather than waiting until a deadline is close, gives your legal and accounting team enough time to gather and review data before the questionnaire response is due, which is usually the single biggest factor in how strong that response ends up being.

Step 4: Complete and file the exporter or producer questionnaire accurately

The questionnaire response is the core of your case. It covers company structure, related party relationships, domestic and export sales data, cost of production, and the basis for the price at which the goods were sold to India. Incomplete answers, inconsistent figures between sections, or unexplained related party transactions are the most common reasons DGTR issues deficiency letters or, in more serious cases, treats a response as insufficiently cooperative. Every figure in the questionnaire should be traceable back to the company's own books, since DGTR verifies this data on site.

Step 5: Prepare supporting documents and get ready for on-site verification

DGTR typically conducts an on-site verification of the data submitted, either at the exporter's or producer's premises or remotely where a physical visit is not practical. This is not a formality: verification officers check the questionnaire figures against the underlying accounting records, sales invoices and cost sheets. Preparing a clear file that maps each questionnaire answer to its supporting document before the verification date, rather than searching for documents during the visit itself, materially affects how the verification goes.

Step 6: Respond to deficiency letters promptly and fully

If DGTR finds gaps or inconsistencies in a submission, it issues a deficiency letter asking for clarification or additional data, usually with its own short deadline. Treat a deficiency letter with the same urgency as the original questionnaire deadline. A pattern of late or incomplete responses to deficiency letters can affect how DGTR weighs your data even where the original questionnaire response was reasonable.

Step 7: Prepare for and attend the oral hearing

DGTR holds an oral hearing where interested parties present their case and respond to questions from the Designated Authority and from opposing parties. This is where a well-prepared written record pays off: the hearing is largely an opportunity to reinforce and clarify the position already built through the questionnaire response and subsequent submissions, not to introduce an entirely new argument DGTR has not seen in writing.

Step 8: Review the disclosure statement and file comments within the window

Before issuing a final finding, DGTR issues a disclosure statement setting out its essential facts and the reasoning behind its proposed determination. This is the last real opportunity to argue against a finding before it becomes final. Read the disclosure statement against your own questionnaire response line by line: this is where calculation errors, misapplied data or a misunderstanding of your company structure are most commonly identified and can still be corrected before the final finding is issued.

Step 9: Track the final finding and decide whether to appeal

DGTR issues a final finding, and if a duty is recommended, the Department of Revenue notifies it separately, which is the point the duty actually takes legal effect. If the final finding is unfavourable and you believe DGTR's determination on dumping margin, injury or causation was wrong on the facts or the law, Section 9C of the Customs Tariff Act, 1975 allows an appeal to the CESTAT (Customs, Excise and Service Tax Appellate Tribunal). An appeal does not pause the duty automatically, so the practical and the legal timeline both need to be tracked from the day the notification is issued, not just the legal deadline for filing the appeal itself.

Step 10: If a duty is imposed, track the 5-year sunset review clock

An anti-dumping duty normally stays in force for five years from the date of notification, unless a sunset review extends it. If you continue to export the product to India, mark the fourth year on your own calendar, since the domestic industry can apply for a sunset review before the duty expires, and the review process itself follows a similar questionnaire and hearing structure to the original investigation.

Common Mistakes Companies Make When Responding to a DGTR Investigation

Treating the initiation notification as something to deal with later, rather than calendaring every deadline the day it is published.
Filing a questionnaire response with figures that do not reconcile with the company's audited accounts or export documentation.
Under-explaining related party transactions, which almost always draws closer scrutiny rather than less.
Assuming that not responding at all is a safe or neutral option.
Waiting until close to the oral hearing to organise legal representation, leaving too little time to build the underlying data record.

What Happens If You Do Not Respond

Non-participation is not a neutral choice. Rule 6(8) of the Anti-Dumping Rules, 1995 broadly mirrors Article 6.8 of the WTO Anti-Dumping Agreement, allowing DGTR to base its determination on facts available where an interested party fails to cooperate or provide the requested information. In practice, this usually means DGTR relies on the information submitted by the domestic industry petitioner, which is generally less favourable to the non-cooperating exporter than a well-prepared questionnaire response of its own would have been. An exporter that stays silent through an entire investigation typically ends up with a higher duty than one that participates properly, even where a full and accurate response would have supported a lower margin.

How Marg Tax Advisors Helps Companies Respond to a DGTR Investigation

Marg Tax Advisors supports foreign producers, exporters and Indian importers through every one of the ten steps above: reviewing the initiation notification, preparing and filing the questionnaire response, coordinating the verification visit, drafting deficiency letter responses, representing clients at the oral hearing, filing comments on the disclosure statement and, where needed, taking a final finding into appeal before the CESTAT. The team pairs lawyers with chartered accountants, since a questionnaire response is as much a costing and accounting exercise as a legal submission, and the two rarely hold up well when handled separately.

Who You'll Work With

Shashank Shekhar Gupta

Founder, Chartered Accountant and Lawyer

DGTR matters at Marg Tax Advisors are led by Shashank Shekhar Gupta, founder of the firm, a Chartered Accountant and a lawyer who chairs the International Trade Law Committee of the Indian Industries Association. Before founding Marg Tax Advisors, he worked with Deloitte and other consulting practices, which is also where his combination of the legal and the accounting sides of a trade remedy case comes from.

How to Respond to an Anti-Dumping Investigation in India