Scrutiny of GST Returns is the first formal point of contact between a taxpayer and the department on the accuracy of their self-assessed returns. It is carried out by the proper officer under Section 61 of the CGST Act, 2017 read with Rule 99 of the CGST Rules, and operationalised through CBIC instructions and the standard operating procedure laid down by Instruction No. 02/2022-GST and subsequent guidelines. Where discrepancies are noticed — typically in GSTR-1 vs GSTR-3B, GSTR-2B vs GSTR-3B, RCM declarations, interest under Section 50, or turnover / ITC mismatches with e-way bill and GSTR-9 data — the officer issues Form ASMT-10 asking the taxpayer to explain the variance within 30 days (extendable).
Scrutiny is meant to be a narrow, issue-specific review — not a full audit. Yet in practice, a weak or delayed response to an ASMT-10 can quickly escalate into a Section 65 audit, a Section 73 / 74 SCN, or a best-judgment assessment. A carefully drafted ASMT-11 reply, backed by proper reconciliations and supporting documents, closes the matter in the most favourable way — with an ASMT-12 order of "no further action". Where the officer is not satisfied, the next stage is audit or assessment, with substantially higher rupee and procedural exposure. In that sense, ASMT-10 is not just a notice; it is the final, quiet opportunity to resolve an issue before it formally becomes a demand.
We offer end-to-end Scrutiny of GST Returns Support — from health-check of your GST returns before any notice is received, interpretation of the specific parameters flagged in ASMT-10, preparation of issue-wise reconciliations for every variance, drafting of the ASMT-11 reply with legal arguments and documentary support, voluntary discharge of any shortfall through DRC-03 where appropriate, representation before the proper officer, and closure through ASMT-12 — so that a scrutiny notice ends at the scrutiny stage itself, without escalating into an audit, SCN, or demand order.
GSTN and BIFA / ADVAIT analytics flag returns with risk indicators — mismatches, ratios, and exceptions — for officer review.
Proper officer issues Form ASMT-10 under Section 61 / Rule 99 listing specific discrepancies to be explained.
Taxpayer files a detailed reply — acceptance with DRC-03 payment, or reasoned explanation with reconciliation.
If satisfied, officer closes with ASMT-12; if not, the matter escalates to audit or assessment proceedings.
Outward supplies and tax reported in GSTR-1 not matching with liabilities discharged in GSTR-3B.
ITC claimed in GSTR-3B exceeding the amount reflected in GSTR-2B by more than the prescribed threshold.
Reverse charge liability on specified services / imports not declared or under-reported in GSTR-3B.
Interest on delayed tax payment or excess ITC utilisation not deposited as required under Section 50.
Invoices on which e-way bills were raised but corresponding outward supplies not declared in GSTR-1.
E-invoices generated via IRP not matching with corresponding supplies reported in GSTR-1.
Blocked / ineligible input tax credit claimed on motor vehicles, food, CSR, or construction services.
Variances between annual return totals and the sum of monthly / quarterly GSTR-3Bs filed during the year.
Proactive review of returns, reconciliations, and ITC positions to identify risks before any notice is issued.
Preparation of issue-wise reconciliations and drafting of ASMT-11 reply with full documentary backing.
Driving clean ASMT-12 closure, and managing escalation to DRC-01A / audit / SCN if the officer is not satisfied.
Proactive review of 2+ years of GST returns to identify scrutiny risk zones before any notice is issued.
Parameter-wise analysis of the scrutiny notice to translate officer language into specific tax issues.
Detailed reconciliations for each flagged discrepancy — GSTR-1 vs 3B, 2B vs 3B, RCM, interest, and more.
Structured ASMT-11 reply with legal submissions, factual rebuttals, and documentary support.
Advising on where voluntary payment through DRC-03 is commercially wise to avoid full-blown litigation.
Attending personal appearances and follow-up meetings with the proper officer for clarification.
Driving the scrutiny to a clean ASMT-12 "no further action" order — the most favourable outcome.
If escalated to DRC-01A, audit, or SCN, seamless transition of the matter to our audit / assessment team.
You have received a formal scrutiny notice in Form ASMT-10 listing specific GST return discrepancies.
System-generated mismatch intimations under Rule 88C / 88D often precede or accompany scrutiny.
Large variance between reported turnover in GSTR-1 / 3B and annual financial statements.
ITC claimed in 3B materially higher than what is reflected in 2B across multiple periods.
RCM-applicable expenses not captured — legal, GTA, director's services, import of services, etc.
EWBs raised for supplies where corresponding outward tax has not been fully discharged.
Large adjustments in the annual return that are visible as variances in the scrutiny data.
Business expecting a Section 65 audit and wanting to resolve scrutiny-level issues in advance.
Parameter-wise decoding of ASMT-10 and mapping each point to the underlying tax position.
Issue-wise reconciliation between returns, books, 2B, e-way bill, and e-invoice data.
Deciding for each issue — defend with explanation, pay via DRC-03, or partially settle.
Drafting and filing a structured ASMT-11 reply with working papers and documentary support.
Driving ASMT-12 closure, or transitioning cleanly into audit / SCN / appeal stream if needed.
Partner with our specialists for end-to-end Scrutiny of GST Returns Support — ASMT-10 decoding, issue-wise reconciliations, ASMT-11 drafting, DRC-03 strategy, and ASMT-12 closure — all under one roof.
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