GST
Keeping scrutiny records for future audits
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Facts
Keep the ASMT-10, ASMT-11, attachments, DRC-03 proofs and ASMT-12 with the year's records. GST records must be kept for 72 months from the annual return due date, and longer if proceedings are pending.
Provisions and law
- Sec 36, CGST Act 2017Records are kept for 72 months from the annual return due date; longer where an appeal or proceeding is pending
- Rule 99, CGST Rules 2017Discrepancies are sent in ASMT-10; reply in ASMT-11 within 30 days or extended time; ASMT-12 closes the matter
Analysis
A closed scrutiny can be cited if the same issue is raised again in an audit under Sec 65 or a demand. Example: an audit in 2028 asks about FY 2023-24 ITC that was explained in ASMT-11 and closed in ASMT-12; the closure order answers it. Store the case file digitally with the GSTIN and period in the file name.
Conclusion
- Download ASMT-12 and all filed replies
- Save them with the year's GST records
- Note the issue in your compliance tracker so it does not repeat
- Keep records at least 72 months
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Scrutiny of returns
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