GST Audit & Assessment Support Services

GST Audit & Assessment Support is the end-to-end professional defence of a registered taxpayer during every stage of tax scrutiny under the CGST Act, 2017 — from the initial scrutiny of returns under Section 61 (ASMT-10), through departmental audits under Section 65 (ADT-01 / ADT-02), special audits under Section 66, provisional and summary assessments under Sections 60 and 64, best-judgment assessment under Section 62, and demand proceedings under Sections 73 and 74 culminating in DRC-01 / DRC-07. Every one of these proceedings has a defined statutory form, timeline, and consequence — and the quality of the taxpayer's response at each stage directly drives whether the matter closes at that level or escalates into a full-blown demand and appeal.

Modern GST audits are sharply data-driven. Officers now use GSTN analytics, Rule 88C / 88D mismatches, GSTR-1 vs 3B gaps, GSTR-2B vs 3B ITC differences, e-way bill vs invoice deviations, e-invoice vs GSTR-1 mismatches, and cross-GSTIN data of the same PAN to identify areas of concern well before they issue a single notice. For the taxpayer, this means a GST audit is rarely a surprise — it is the culmination of patterns visible in the data for months. Strong, structured audit & assessment support therefore begins long before the first ADT-01 lands — with clean reconciliation, well-maintained working papers, and a strategy that is legally defensible at every stage.

We offer end-to-end GST Audit & Assessment Support — from pre-audit diagnostic reviews, preparation of working papers and reconciliations, responses to ASMT-10 and DRC-01A, representation during departmental audits under Section 65, replies to DRC-01 show cause notices, personal hearings before the adjudicating officer, drafting of DRC-07 and DRC-03 strategy, and seamless transition into first appeal under Section 107 if needed — so every scrutiny, audit, or assessment is handled with clean documentation, strong legal arguments, and a clear plan to protect ITC, minimise demand, and close the matter at the earliest viable stage.

Sec 61-75
Scrutiny to adjudication
Sec 65 / 66
Departmental & special audits
3 Months
Typical Section 65 audit window
Full Defence
Notice to appeal coverage
Laws & Frameworks We Work Under
CGST Act – Sec 61 (Scrutiny)
CGST Act – Sec 62 / 63 / 64
CGST Act – Sec 65 / 66
CGST Act – Sec 73 / 74 / 75
Form ASMT-10 / 11 / 12
Form ADT-01 to ADT-04
Form DRC-01 / 01A / 03 / 07
Rule 88C / 88D (DRC-01B / 01C)

Key GST Proceedings We Defend

Sec 61

Scrutiny of Returns

Preliminary scrutiny of GST returns by the proper officer where discrepancies trigger an ASMT-10 notice.

  • GSTR-1 vs 3B mismatches
  • GSTR-2B vs 3B ITC gaps
  • Notice in Form ASMT-10
  • Reply in Form ASMT-11
  • Closure in Form ASMT-12
  • First line of defence
Sec 65

Departmental Audit

Full-scope audit of the taxpayer's business under Section 65 — onsite or at the officer's place.

  • Intimation in Form ADT-01
  • Completion within 3 months
  • Extension of 6 months permitted
  • Audit findings in Form ADT-02
  • Record inspection onsite
  • Core audit-defence engagement
Sec 66

Special Audit

Special audit by a nominated CA / CMA under Section 66 where the Commissioner finds complexity warranting deeper review.

  • Ordered in Form ADT-03
  • Conducted by nominated CA / CMA
  • Report in Form ADT-04
  • Usually complex / high-value
  • Fees borne by Government
  • Requires structured defence
Sec 73 / 74

Tax Demand Proceedings

Adjudication proceedings under Sections 73 (non-fraud) or 74 (fraud) leading to a demand order.

  • Pre-SCN intimation in DRC-01A
  • Show cause notice in DRC-01
  • Reply in DRC-06
  • Personal hearing
  • Demand order in DRC-07
  • Leads to first appeal

Key Audit & Assessment Forms We Handle

ASMT-10

Scrutiny Notice

Notice issued by the proper officer on identification of discrepancies during return scrutiny.

Sec 61 Notice
ASMT-11

Reply to Scrutiny

Taxpayer's reply to ASMT-10 with reconciliations, working papers, and legal submissions.

Reply Defence
ASMT-12

Scrutiny Closure

Order accepting the reply and closing the scrutiny — the most favourable outcome at this stage.

Closure No Demand
ADT-01

Audit Intimation

Formal intimation to the taxpayer of initiation of a Section 65 departmental audit.

Sec 65 Intimation
ADT-02

Audit Report

Report of audit findings issued by the audit team at the conclusion of the Section 65 audit.

Findings Report
DRC-01A

Pre-SCN Intimation

Intimation of tax ascertained before issuing a formal show cause notice — opportunity to pay with DRC-03.

Pre-SCN Opportunity
DRC-01

Show Cause Notice

Formal SCN under Section 73 or 74 proposing demand of tax, interest, and penalty from the taxpayer.

SCN Sec 73 / 74
DRC-07

Demand Order

Final demand order after adjudication — appealable under Section 107 before the Appellate Authority.

Demand Appealable

What Our Audit & Assessment Engagement Covers

Prep

Pre-Audit Preparation

Diagnostic review of returns, books, and working papers before any notice is issued — building the defence early.

  • Year-wise return scrub
  • GSTR-1 vs 3B tie-out
  • GSTR-2B vs 3B ITC working
  • ITC eligibility review
  • HSN / SAC mapping
  • Pre-audit risk memo
Response

Notice Response & Representation

Drafting structured replies to every form — ASMT-10, ADT-01 / 02, DRC-01A, DRC-01 — with evidence and law.

  • ASMT-11 / DRC-06 drafting
  • DRC-01A settlement strategy
  • Case-law compilation
  • Reconciliation working papers
  • Personal hearing representation
  • Written submissions
Closure

Closure & Transition to Appeal

Driving closure at the lowest possible forum, and seamless transition to first appeal where needed.

  • DRC-03 voluntary payments
  • DRC-07 demand order review
  • Appeal strategy under Sec 107
  • Pre-deposit computation
  • APL-01 filing support
  • Post-order compliance

Our GST Audit & Assessment Services

01

Pre-Audit Health Check

Proactive diagnostic of GST filings, reconciliations, and ITC positions before any notice is received.

02

ASMT-10 / 11 Defence

Structured reply to scrutiny notices under Section 61 to close the scrutiny at source with ASMT-12.

03

Section 65 Audit Support

End-to-end support for departmental audits — data packs, onsite coordination, reply to ADT-02 findings.

04

Section 66 Special Audit

Coordinating with the Government-nominated CA / CMA during special audits ordered under Section 66.

05

DRC-01A Negotiation

Strategic handling of pre-SCN intimations — accept, contest, or partly settle to avoid full adjudication.

06

DRC-01 SCN Reply

Drafting detailed DRC-06 replies with legal submissions, case law, and documentary evidence.

07

Personal Hearing

Attending personal hearings, presenting arguments, and filing additional submissions before adjudication.

08

DRC-07 Order Review & Appeal

Detailed review of DRC-07 demand orders and seamless transition into first appeal under Section 107.

When You Need GST Audit & Assessment Support

ASMT-10 Scrutiny Notice

You have received a Section 61 scrutiny notice flagging GSTR-1 vs 3B or ITC mismatches.

ADT-01 Audit Intimation

Intimation of departmental audit under Section 65 has been issued for one or more financial years.

DRC-01A Pre-SCN

You have received a pre-show-cause intimation ascertaining tax and interest, with a DRC-03 window.

DRC-01 SCN Received

A formal show cause notice under Section 73 or 74 has been issued proposing demand and penalty.

DRC-01B / 01C Issued

Rule 88C / 88D system-generated mismatch intimations on GSTR-1 / 3B / 2B requiring reply.

Best-Judgment Assessment

Ex-parte assessment under Section 62 / 63 / 64 on account of non-filing or non-compliance.

Special Audit (Sec 66)

Special audit ordered by the Commissioner where complexity or high values warrant independent review.

M&A / IPO Due Diligence

Pending GST audits or notices flagged during transaction diligence needing strategic closure.

Information & Documents We Typically Need

Returns & Portal Data

  • GSTR-1 / 3B / 2A / 2B (all years)
  • GSTR-9 / 9C filed
  • Electronic cash / credit ledgers
  • DRC-03 challans, if any
  • Notices received (ASMT / ADT / DRC)
  • Prior replies & correspondence
  • GSTIN portal login / access

Books & Registers

  • Audited financial statements
  • Trial balance & ledgers
  • Sales & purchase registers
  • Stock register (if applicable)
  • ITC register & reversal log
  • E-invoice / IRN data
  • E-way bill data

Legal & Policy

  • Sample contracts / POs
  • Pricing & rate policy
  • HSN / SAC classification
  • Board / partner resolutions
  • Authorisation / POA
  • DSC of authorised signatory
  • Prior appeals / orders, if any

Our End-to-End Audit & Assessment Approach

1

Notice Review

Review of every notice / order received, mapping applicable sections, timelines, and risk zones.

2

Data & Reconciliation

Pulling returns, books, registers, and building reconciliations for each issue raised.

3

Reply Drafting

Drafting ASMT-11 / DRC-06 / ADT responses with legal arguments and documentary evidence.

4

Hearing & Submission

Personal hearings before the officer, additional submissions, and response to queries in real time.

5

Closure / Appeal

Driving closure via ASMT-12 / DRC-05 / favourable DRC-07 or seamless transition to appeal.

Why Choose Us for GST Audit & Assessment

End-to-end notice-to-appeal defence
Robust reconciliation & working papers
Strong Section 61 / 65 / 66 experience
Case-law driven submissions
DRC-01A settlement strategy
Effective personal hearing advocacy
Seamless appeal transition
Commercial, closure-focused advice

FAQs on GST Audit & Assessment Support

What is the difference between GST scrutiny, audit, and assessment?
Scrutiny under Section 61 is a preliminary review of a taxpayer's returns to identify discrepancies, communicated through Form ASMT-10 with a reply in ASMT-11. Audit under Section 65 is a much deeper, full-scope examination of the taxpayer's records, returns, and books, usually spread across specified financial years, intimated via ADT-01 and concluded with ADT-02. Assessment is the broader adjudication outcome — self-assessment under Section 59, provisional under Section 60, summary under Section 64, or best-judgment under Section 62 / 63 — culminating in a formal order. Scrutiny and audit often feed into assessment proceedings and demand notices under Sections 73 / 74.
How long does a Section 65 GST audit take?
A departmental audit under Section 65 is required to be completed within three months from the date of commencement of the audit, which is reckoned from the date on which the officer gains access to the records requested. If the Commissioner is satisfied that the audit cannot be completed within this period for reasons recorded in writing, an extension of up to six months can be granted. In practice, the effective timeline is driven by the quality of data and reconciliations submitted by the taxpayer — a well-prepared data pack significantly shortens the cycle and reduces downstream demand risk.
What is DRC-01A and why does it matter?
DRC-01A is a pre-show-cause intimation under Rule 142(1A) in which the proper officer communicates the tax, interest, and penalty ascertained as payable before issuing a formal show cause notice. It gives the taxpayer an opportunity to accept and pay the amount through Form DRC-03 — thereby avoiding a formal SCN, full adjudication, and potentially higher penalty under Section 74. In matters with limited disputable exposure, DRC-01A is often the smartest place to close a matter. In matters with real legal positions worth defending, it is also the right place to place your counter-narrative on record formally.
What is the difference between Section 73 and Section 74 proceedings?
Section 73 deals with determination of tax not paid, short-paid, or ITC wrongly availed / utilised, where there is no element of fraud, wilful misstatement, or suppression of facts — attracting a lower penalty, typically up to 10% of tax or ₹10,000, whichever is higher. Section 74 covers the same issues where fraud, wilful misstatement, or suppression is alleged — attracting a penalty up to 100% of tax. The section quoted in the SCN is very important, because it affects not only the quantum of penalty but also the limitation period and the settlement window under Section 73(5) / 73(8) versus Section 74(5) / 74(8).
Can we pay tax during audit to reduce penalty?
Yes. Sections 73 and 74 both encourage voluntary payment of tax and interest before a formal SCN is issued — Section 73(5) allows payment with no penalty before SCN, while Section 74(5) allows payment with 15% penalty before SCN. Even after SCN, Section 73(8) / 74(8) and related subsections provide reduced-penalty windows if the payment is made within prescribed periods. Strategic use of DRC-03 during audit can therefore materially reduce the final liability. We evaluate this on the basis of merits — paying where defensibility is low, and contesting where the law is clearly on the taxpayer's side.
What is the limitation for issuing a demand under Sections 73 and 74?
Under Section 73, the proper officer is required to issue an order within three years from the due date for furnishing the annual return for the financial year to which the tax relates, with the SCN to be issued at least three months before this order deadline. Under Section 74, the order is to be issued within five years from the same reference date, with the SCN to be issued at least six months in advance. Any SCN or order issued beyond these limitation periods is legally vulnerable, and raising limitation as a defence is often an important part of the assessment strategy.
How do we handle multiple notices across years and GSTINs together?
Large taxpayers often receive multiple notices across years, issues, and GSTINs simultaneously — e.g., ASMT-10 on FY 2017-18, ADT-01 on FY 2018-19 and 2019-20, DRC-01A on FY 2020-21, all alongside regular filings. We handle this through a central case-management framework — a master tracker of every open proceeding, a consistent narrative across replies (so positions are not contradicted), a joint working paper set that feeds all replies, and a defined internal calendar for each deadline. This prevents the common failure mode of being procedurally strong in one case but weak in another due to scattered record keeping.
What happens after a DRC-07 demand order?
A DRC-07 demand order crystallises the tax, interest, and penalty payable and is an appealable order under Section 107 of the CGST Act. The taxpayer can either pay the demand through DRC-03 and close the matter, or file a first appeal in Form GST APL-01 before the Appellate Authority within three months (extendable by one month) from the date of service of the order, along with 10% pre-deposit of disputed tax. Recovery of the balance is automatically stayed once a valid appeal with pre-deposit is filed. Our audit and assessment engagements are always run with an eye on how cleanly the record will transition if an appeal becomes necessary.

Handle Every GST Notice & Audit With Confidence

Partner with our specialists for end-to-end GST Audit & Assessment Support — scrutiny, departmental audit, special audit, SCNs, DRC-07, and first appeal — all under one roof.

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