Scrutiny of Returns
Handling scrutiny of the returns you have already filed, including notices in Form GST ASMT-10 and replies in Form GST ASMT-11.
Scrutiny is a desk verification of returns already filed. Where the officer finds a discrepancy, a notice is issued in Form GST ASMT-10 asking you to explain it within the time allowed, and the explanation is filed in Form GST ASMT-11. An explanation the officer accepts closes the matter through an intimation in Form GST ASMT-12, while an unsatisfactory reply, or no reply at all, opens the door to audit, inspection or a demand.
What our scrutiny service covers
Understanding the discrepancy, evidencing the answer, and closing the file.
- Analysing each discrepancy listed in the notice and tracing it back to the underlying records
- Reconciling outward supplies between GSTR-1 and GSTR-3B for the period
- Reconciling input tax credit availed in GSTR-3B against the auto-generated GSTR-2B
- Explaining differences thrown up by e-way bill data, import data and tax deducted at source credits
- Drafting and filing the reply in Form GST ASMT-11 with indexed annexures
- Paying and intimating accepted differences through Form GST DRC-03 and following the file through to Form GST ASMT-12
What scrutiny notices usually raise
The four comparisons that generate most discrepancy notices.
GSTR-1 versus GSTR-3B
Differences between outward supplies declared in the statement and the liability discharged in the summary return.
Input Tax Credit Mismatch
Credit availed in the return compared against the credit appearing in the auto-generated statement for the same period.
E-Way Bill Comparison
Value of consignments moved under e-way bills compared against outward turnover declared for the period.
ASMT-11 Reply
A written explanation with reconciliations and documents attached, filed within the time allowed in the notice.
Our process
From initial consultation to completion.
Discrepancy Analysis
Breaking the notice into individual items and identifying what each figure has been compared against.
Reconciliation
Reconstructing the numbers from the books so that each difference has a documented explanation.
Reply Drafting
Filing the reply in Form GST ASMT-11 with a schedule for every item raised.
Closure
Following up for acceptance in Form GST ASMT-12, or preparing for the next stage where the officer is not satisfied.
Why scrutiny notices should not be treated as routine
What sets our approach apart.
Most differences are explainable but must be evidenced
Timing differences, credit notes and amendments explain the bulk of mismatches, but only if the reconciliation is put on record.
The reply window is short
The period allowed in the notice is measured in days, and extensions are discretionary rather than assured.
An unclosed scrutiny becomes a demand
Where the explanation is not accepted or not filed, the same figures reappear in a show cause notice with interest and penalty attached.
Scrutiny of returns questions answered
What people ask before engaging us.
Holding an ASMT-10 with the clock running?
We will reconcile the figures and file a reply that closes the file rather than opening the next stage.
