GST
ASMT-10 with vague or unquantified points
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Facts
The SOP says discrepancies should be specific and quantified where possible. Ask the officer for the working, and still give your reconciliation.
Provisions and law
- Instruction 02/2022-GST (22 March 2022)SOP for scrutiny: one ASMT-10 per GSTIN per year, specific and quantified discrepancies, DRC-03 payments to be considered, timelines for ASMT-12 or further action
- Rule 99, CGST Rules 2017Discrepancies notified in ASMT-10, reply in ASMT-11 within 30 days or allowed time, acceptance in ASMT-12
Analysis
Instruction 02/2022-GST asks officers to quantify tax and interest where possible and avoid vague points. Example: a notice that only says 'ITC mismatch' for FY 2021-22; write asking for the figures used, and meanwhile file your own reconciliation showing ITC per books, GSTR-3B and GSTR-2A.
Conclusion
- Write asking for the data and working.
- Prepare your own reconciliation for the issue.
- File a reply within time noting the request.
- Follow up for the officer's working.
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