How to handle GST Return Scrutiny Notice-ASMT-10?

[Sandeep Saini]

As a registered person under GST, you are required to file GST returns in accordance with the rules and regulations of GST law. However, there may be instances when you may receive a GST return scrutiny notice in ASMT-10. The given notice is issued by the department to verify the accuracy and completeness of your GST returns. Here are points which would be helpful in handling GST return scrutiny notices in ASMT-10:

1. Read and understand the discrepancies highlighted in the notice carefully and accordingly prepare the reply. Generally, the discrepancies are given para-wise, therefore para-wise reply is preferable.
2. The discrepancies which are generally highlighted in the notice pertains to reconciliation issue or any information not provided or wrongly provided in the returns filed on GST portal.
3. In case the discrepancy pertains to reconciliation issue of outward supply, in such case the reason of difference should be find out and the reconciliation in the tabular form along with reason of difference may be provided as reply in respect of such discrepancy. Further, where only the information about outward supply is required then only that information to be provided.
4. In case the discrepancy pertains to excess input tax credit claimed in GSTR-3B as against GSTR-2A. In that case, if the period of scrutiny of return pertains to FY 2017-18 and FY 2018-19, in that case please refer Circular No. 183/15/2022-GST dated December 27, 2022, which clearly says GSTR-2A is not relevant to determine eligibility of input tax credit in FY 2017-18 and FY 2018-19 and the input tax credit is to be availed on self-assessment basis subject to fulfillment of other conditions i.e. Section 16, Section 17 and Section 18. Further, Rule 36(4) may also be referred which came into force only w.e.f. October 9, 2019 and also refer Section 16(2)(aa) of CGST Act, 2017, which also come into force w.e.f. January 1, 2022. While giving reply to said issue, given circular and provisions may be referred.
5. Gather the required documents basis on which you are submitting your reply at one place. Further, the most relevant documents should also be attached as Annexure to your reply and submit on the GST portal.
6. If you think personal hearing would be better to explain the reason of discrepancies to officer, then specifically mention in the reply for personal hearing and also select the option for hearing on the GST portal as well.
7. After submitting the reply follow up with the department for dropping the proceedings or order to be issued by the department.

In conclusion, handling a GST return scrutiny notice in ASMT-10 requires updated knowledge in GST, proper preparation of reply, documentation and cooperation with the GST department. By doing so, you can ensure that the scrutiny process is completed smoothly and without any issue.