Answer

GST

Partly accepting and partly disputing scrutiny points

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  1. Facts

    Yes. You can accept some discrepancies, pay for them, and dispute others with reasons in the same ASMT-11 reply. Each point is examined separately.

  2. Provisions and law

    • 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
    • Rule 142(2), CGST Rules 2017Tax and interest accepted can be paid in DRC-03 and intimated to the officer
    • Sec 61(3), CGST Act 2017If no satisfactory explanation or payment, the officer may proceed under Sec 65, 66, 67, 73 or 74
  3. Analysis

    Example: ASMT-10 lists three points worth Rs 4 lakh. You accept point 1 for Rs 50,000 and pay with interest, dispute point 2 as a timing difference, and dispute point 3 because the credit is from a valid supplier who filed returns. Paying the accepted part shows good faith and narrows any later proceeding to the disputed points.

  4. Conclusion

    1. Classify each point as accepted or disputed
    2. Pay accepted points through DRC-03
    3. Give evidence for disputed points
    4. File one consolidated ASMT-11 covering all points

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