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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
Pre-Audit Health Check
Proactive diagnostic of GST filings, reconciliations, and ITC positions before any notice is received.
ASMT-10 / 11 Defence
Structured reply to scrutiny notices under Section 61 to close the scrutiny at source with ASMT-12.
Section 65 Audit Support
End-to-end support for departmental audits — data packs, onsite coordination, reply to ADT-02 findings.
Section 66 Special Audit
Coordinating with the Government-nominated CA / CMA during special audits ordered under Section 66.
DRC-01A Negotiation
Strategic handling of pre-SCN intimations — accept, contest, or partly settle to avoid full adjudication.
DRC-01 SCN Reply
Drafting detailed DRC-06 replies with legal submissions, case law, and documentary evidence.
Personal Hearing
Attending personal hearings, presenting arguments, and filing additional submissions before adjudication.
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
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End-to-end notice-to-appeal defence
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Robust reconciliation & working papers
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Strong Section 61 / 65 / 66 experience
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Case-law driven submissions
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DRC-01A settlement strategy
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Effective personal hearing advocacy
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Seamless appeal transition
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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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