Scrutiny of GST Returns | Savlana Init

GST Compliance · Return Scrutiny

GST Return Scrutiny — ASMT-10 Replied. Matter Closed.

Received a GST scrutiny notice in Form ASMT-10? We analyse the discrepancy, prepare a comprehensive ASMT-11 reply with turnover and ITC reconciliation statements, and follow up to ASMT-12 closure — stopping the matter before it becomes a demand.

Scrutiny of GST returns under Section 61 of the CGST Act is the department's primary automated compliance check. The Proper Officer uses the GST system to compare filed returns against each other and against third-party data — GSTR-1 vs. GSTR-3B turnover, GSTR-3B ITC vs. GSTR-2B, e-way bill values vs. GSTR-1, and outward supply figures vs. income tax or TDS data. Where the system flags a discrepancy, the officer issues Form ASMT-10 specifying the discrepancy and giving the taxpayer 30 days to explain or correct it.

The taxpayer must respond in Form ASMT-11 — either accepting the discrepancy and paying the shortfall with interest, or providing a complete explanation with supporting reconciliation data and documents. If the explanation is accepted, the Proper Officer closes the scrutiny in Form ASMT-12. If not satisfied, the officer can escalate to audit proceedings under Section 65 or demand proceedings under Section 73/74. The scrutiny stage is the earliest and most cost-effective point of intervention — a thorough ASMT-11 reply with proper reconciliation and legal submissions is almost always far cheaper than a demand proceeding or appeal.

The most common ASMT-10 discrepancies we address are: GSTR-3B turnover lower than GSTR-1 (timing differences, credit notes, advance adjustment); ITC in GSTR-3B exceeding GSTR-2B (supplier late filing, RCM, or prior period carryover); and e-way bill value inconsistencies (cancelled e-way bills, non-supply movements, or exempt supply transport). We identify the correct explanation for the discrepancy and present it to the officer comprehensively so the ASMT-12 closure can be obtained without further escalation.

Our GST Return Scrutiny Services

ASMT-10 Notice Analysis

Detailed review of the scrutiny notice — identifying the specific discrepancy, period covered, tax computation basis, and the officer's data source for the comparison.

ASMT-11 Reply Preparation

Comprehensive drafting of Form ASMT-11 — the formal reply to the ASMT-10 notice — with reconciliation statements, legal submissions, and supporting documents.

GSTR-1 vs GSTR-3B Turnover Reconciliation

Reconciliation of the turnover difference between GSTR-1 and GSTR-3B — identifying and explaining timing differences, advances, credit notes, and classification variances.

ITC vs GSTR-2B Reconciliation

Reconciliation of ITC claimed in GSTR-3B against GSTR-2B — explaining excess claims through supplier late filing, reverse charge, or prior-period ITC.

E-Way Bill vs GSTR-1 Reconciliation

Reconciliation of e-way bill value vs. GSTR-1 turnover — identifying cancelled e-way bills, exempt supply movements, job work movements, and non-supply returns.

Voluntary Payment Advisory

Advisory on whether to pay the shortfall identified in ASMT-10 voluntarily — triggering the Section 73(5) no-penalty outcome — vs. contesting with a detailed ASMT-11 explanation.

ASMT-11 Filing & Acknowledgement

Filing of Form ASMT-11 on the GST portal within the 30-day response window and obtaining the filing acknowledgement.

Follow-Up to ASMT-12 Closure

Active follow-up with the Proper Officer for issuance of Form ASMT-12 — the order closing the scrutiny proceeding after the explanation is accepted.

Our Process

ASMT-10 Review

The scrutiny notice is reviewed — the specific discrepancy, the comparison data used, and the period covered are identified and mapped to the underlying transaction data.

Data Reconciliation

The discrepancy is reconciled against GSTR-1, GSTR-3B, GSTR-2B, e-way bills, and the books of accounts — producing a complete reconciliation statement that explains every line item.

ASMT-11 Drafting

A comprehensive ASMT-11 reply is prepared — factual reconciliation, legal submissions for contested points, supporting documents as annexures, and clear presentation of the taxpayer's position.

Filing Within 30-Day Window

ASMT-11 is filed on the portal within the 30-day response window and the acknowledgement is retained.

ASMT-12 Follow-Up

The officer is followed up for the closure order. If escalation is signalled, the escalation response strategy is immediately prepared and deployed.

Why It Matters

✓ASMT-10 discrepancy analysed in full before any reply is drafted

✓ASMT-11 filed within 30 days — no deemed escalation due to non-response

✓GSTR-1 vs GSTR-3B turnover difference reconciled line by line

✓ITC vs GSTR-2B gap explained with supplier filing and RCM evidence

✓E-way bill discrepancies explained with cancellation and exempt records

✓Voluntary payment timed to avoid penalty if shortfall is undisputed

✓ASMT-12 closure obtained — scrutiny closed without becoming a demand

✓Escalation to audit or demand prevented with strong ASMT-11 submissions

Frequently Asked Questions

Form ASMT-10 is issued under Section 61 of the CGST Act when the Proper Officer identifies discrepancies in filed returns through automated comparison. It specifies the discrepancy, the period, and the tax impact — and gives the taxpayer 30 days to explain or correct the discrepancy.

The most common triggers are: GSTR-3B turnover lower than GSTR-1 turnover; ITC in GSTR-3B exceeding GSTR-2B; e-way bill value inconsistent with GSTR-1 turnover; outward supply inconsistency with income tax return or TDS data; and RCM liability not paid on reverse charge purchases.

The taxpayer must file Form ASMT-11 within 30 days of receiving the notice. An extension may be requested from the officer. If no response is filed, the officer can proceed to pass an order or escalate to audit or demand proceedings.

If the officer accepts the explanation, Form ASMT-12 is issued closing the scrutiny. If not satisfied, the officer escalates to audit (Section 65) or issues a show cause notice (Section 73 or 74). A well-drafted ASMT-11 with complete reconciliation prevents this escalation in the majority of cases.

Yes. Paying the tax and interest identified in the scrutiny notice before the ASMT-12 order is issued avoids penalty entirely under Section 73(5) — penalty applies only after a show cause notice is issued. Voluntary payment at the scrutiny stage is the most cost-effective resolution when the discrepancy represents a genuine shortfall.

Not necessarily. ASMT-10 is an inquiry — not a demand. If the ASMT-11 explanation is accepted, ASMT-12 closes the matter with no demand. It is only where the officer is unsatisfied with the explanation that escalation to demand proceedings occurs. A comprehensive ASMT-11 closes most scrutiny proceedings without a demand.

Received a GST scrutiny notice (ASMT-10)?

We analyse the discrepancy, prepare a complete ASMT-11 reply with reconciliation statements and legal submissions, and follow up to ASMT-12 closure — preventing escalation to audit or demand.