GST
Partly accepting the scrutiny points
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Facts
Reply issue by issue: pay what you accept, and explain the rest with reconciliation and documents. A clear table helps the officer close quickly.
Provisions and law
- Rule 99, CGST Rules 2017Discrepancies notified in ASMT-10, reply in ASMT-11 within 30 days or allowed time, acceptance in ASMT-12
- 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
Analysis
Rule 99 and the SOP allow acceptance with payment or an explanation. Example: ASMT-10 has three issues: output tax gap ₹30,000, ITC excess ₹80,000 and RCM ₹12,000. You accept RCM and pay ₹12,000 plus interest; you explain the ₹30,000 gap as amendments in the next year; you show the ₹80,000 ITC invoices arrived in GSTR-2B in a later month. Put this in a table.
Conclusion
- List each issue with the amount.
- Mark each as accepted or explained.
- Pay accepted amounts through DRC-03.
- Attach working for explained issues.
- File one consolidated ASMT-11.
A Savvy can do this for you
Scrutiny of returns, ASMT-10 notice and ASMT-11 reply
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