Answer

GST

GSTR-1 and GSTR-3B mismatch in scrutiny

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  1. Facts

    Most such gaps come from amendments, invoices reported in a different month, advances or credit notes. Show a month-wise reconciliation for the year.

  2. Provisions and law

    • Sec 61, CGST Act 2017Officer may scrutinise returns, inform discrepancies and seek an explanation; if accepted, no further action; if not, action under Sec 65, 66, 67, 73 or 74
    • 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
  3. Analysis

    Instruction 02/2022-GST lists GSTR-3B versus GSTR-1, adjusted for amendments and advances, as a common parameter. Example: FY 2022-23 GSTR-1 shows ₹1.02 crore and GSTR-3B ₹98 lakh; ₹3 lakh is invoices of March reported in April GSTR-3B and ₹1 lakh is credit notes. Show both with invoice lists, and pay any real shortfall.

  4. Conclusion

    1. Prepare a month-wise table of GSTR-1 and GSTR-3B values.
    2. Mark amendments, timing differences and credit notes.
    3. Attach invoice lists for the differences.
    4. Pay any genuine shortfall with interest.

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Scrutiny of returns, ASMT-10 notice and ASMT-11 reply

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