GST
Officer asking for many documents in scrutiny
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Facts
The SOP says there should normally be no need to ask for documents before issuing ASMT-10. In your reply, give documents that support your explanation, and ask the officer to specify any others.
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 favours minimal interface and data-based scrutiny. Large requests can be met with summaries and sample documents. Example: instead of 4,000 invoices, give a reconciliation and the 20 invoices that make up the gap. Offer the rest on request.
Conclusion
- Give a summary reconciliation.
- Attach documents only for the differences.
- Offer full records for inspection if needed.
- Ask the officer to specify any further items in writing.
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Scrutiny of returns, ASMT-10 notice and ASMT-11 reply
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