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First, identify exactly what you received. A GST communication may be an information request, a section 65 audit notice, an audit discrepancy or findings letter, a pre-notice intimation, a demand show-cause notice, or an adjudication order. Each has a different legal route, form and deadline. Read the document and its attachments before deciding how to reply.
Preserve the complete notice, record its service date and stated response deadline, and build your answer around the section, tax period, allegation and evidence actually cited. The process below is general information for GST-registered businesses in India; the notice and the rules applicable to its financial year control the case.
1. Triage the communication before doing anything else
Do not call every GST message an “audit notice.” Start a case file—digital and paper if practical—and copy the communication exactly as it appears on the GST portal. Download every attachment, annexure and calculation sheet. Take a screenshot or export showing the portal reference number, date and service status, then preserve email, SMS and courier records that may establish when it was served.
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Record these particulars
- Issuing authority: identify the central or state GST authority, officer and jurisdiction shown on the document.
- Statutory provision: note the section, rule, notification or order cited. A section 65 audit, section 66 special audit and demand proceedings are not interchangeable.
- Financial year or tax period: write down every month, quarter or year covered and check whether the notice mixes periods.
- Allegation or discrepancy: quote the department’s description and its tax, interest, penalty, input-tax-credit or refund calculation.
- Service date and deadline: record both the date shown on the notice and the date you actually received it. The general section 65 audit timetable is not the reply deadline for every other notice.
- Requested material and channel: list each document, explanation, appearance, upload, form or payment instruction, including file-size or naming requirements on the portal.
- Reference numbers: retain the notice number, ARN, DIN or other identifier so every later submission can be matched to the case.
Check that the communication also appears in the relevant portal section and that the attachments are complete. If the portal record and a downloaded letter differ, preserve both and obtain professional advice promptly rather than silently choosing one version.
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2. Recognise the route: audit, special audit or demand
The purpose of the document determines the response. The following distinctions are the practical starting point.
| Route | What it is for | Typical form identified in the CGST Rules | What your response should address |
|---|---|---|---|
| Section 65 ordinary audit | Verification of a registered person’s records, returns, tax treatment and related matters by an authorised officer. | FORM GST ADT-01 for the audit notice; FORM GST ADT-02 for communicating findings. | Provide access and records, explain each discrepancy, and retain the final findings and your reply. An audit finding is not itself the demand-reply form. |
| Section 66 special audit | Examination ordered when case complexity and revenue interest justify an independent examination. | FORM GST ADT-03 for the direction; FORM GST ADT-04 for findings. | Confirm the Commissioner’s approval, nominated chartered accountant or cost accountant, scope, period and appointment terms. Coordinate access without assuming the engagement is an ordinary audit. |
| Specified demand proceedings | Proceedings alleging tax not paid or short paid, erroneous refund or wrongly availed or utilised input tax credit under the provision stated in the notice. | DRC-01 is the electronic summary accompanying a notice; DRC-02 accompanies a statement; DRC-06 is the representation or reply form in the specified proceedings. DRC-03 is identified for payment intimation in the circumstances described in the applicable rules. | Answer the allegations, computation, legal basis and proposed interest or penalty by the deadline in the notice, using the form and channel it specifies. |
The cited Act text says that an audit detecting unpaid or short-paid tax, erroneous refund or incorrectly availed or used input tax credit may lead the proper officer to action under section 73 or 74. That cross-reference is not a complete analysis for every tax year: provisions and commencement can change. Confirm the section and period in your own communication.
3. Understand the section 65 audit timetable
For an ordinary section 65 audit, the registered person must be informed at least 15 working days before the audit. The statutory audit period is three months from commencement. The Commissioner may extend it by up to six further months when reasons are recorded. The Act describes commencement as the later of the date the records are made available and the date the audit actually starts at the business premises.
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The authorised officer may require access to books and documents, information and assistance. The audit may take place at the business premises or in the tax office. At the end, findings, the registered person’s rights and obligations, and the reasons for the findings are to be communicated within 30 days after the audit concludes. These are statutory time limits, not averages or service-level targets.
Keep these dates in a timeline. The three-month audit-completion period does not tell you how long you have to answer a separate discrepancy letter, show-cause notice or order. Use the specific response date stated in that communication and verify it against the current provision and rules applicable to the relevant period.
4. Build an audit-ready evidence set
Organise records around the checks described in the audit rules, not around the order in which files happen to be stored. Create a master index with document name, period, source system, file path, responsible person and the issue it supports. Use consistent file names and preserve read-only copies of the submitted version.
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Core accounting and tax records
- General ledger, trial balance, journal entries and subsidiary ledgers for the periods under review.
- Sales registers, purchase registers, expense ledgers, debit and credit notes, e-invoice or e-way-bill records where relevant, and invoice series controls.
- Bank statements, cash books, fixed-asset registers and stock or production records when they explain turnover, purchases or credits.
- Contracts, purchase orders, delivery evidence, customer correspondence and proof of supply or receipt supporting material transactions.
- GST returns and amendments, including outward-supply, summary and payment returns, together with workings used to prepare them.
- Tax-rate, exemption, deduction and place-of-supply analyses for the supplies selected by the officer.
- Input-tax-credit registers, supplier invoices, receipt and payment evidence, reversals, blocked-credit reviews and reconciliations to auto-populated statements for the relevant period.
- Refund applications, statements, sanction or deficiency memos, payment proofs and correspondence if a refund is in scope.
- Prior notices, replies, orders, appeal filings, payment challans and undertakings concerning the same issue or period.
Reconcile before the officer asks
Prepare a period-by-period reconciliation linking the books to filed returns and then to the department’s figure. Explain every bridge item: credit notes issued after the reporting month, advances, exports, branch or stock transfers, exempt or non-GST income, valuation adjustments, rounding, reversals and amendments. For input tax credit, reconcile the purchase ledger, eligible-credit computation, reversals and returns; retain the invoice-level population behind every total.
Index each number to a source record and a return table or invoice range. A reviewer should be able to start with the amount in your response, open the index, and reach the underlying ledger entry or document without asking you to reconstruct the calculation.
5. Create a controlled response workflow
- Open the case file. Save the notice, attachments, portal history and service proof in an access-controlled folder. Record the statutory section, period, deadline, officer and requested output in a one-page cover sheet.
- Assign ownership. Give a named owner to each request—sales, purchases, finance, tax, legal, IT or an external adviser—and set an internal deadline earlier than the notice deadline.
- Map each allegation. Number the department’s points exactly as they appear. If a calculation has multiple components, reproduce the components in a separate reconciliation rather than answering with one net figure.
- Prepare the response schedule. Use columns for issue raised, department calculation or assertion, factual response, legal position to be reviewed, supporting record and any correction or payment already made.
- Validate facts and arithmetic. Have someone independent of the preparer reperform totals, check period filters, inspect invoice samples and confirm that every attachment is legible and complete.
- Decide the position on each point. State whether the fact is accepted, partly accepted, disputed or not determinable from the records. If a correction or payment has been made, identify the date, amount, challan and accounting treatment without implying that payment resolves a disputed legal issue.
- Obtain advice where exposure is material. A qualified GST practitioner, chartered accountant or tax lawyer should review disputes involving classification, place of supply, limitation, privilege, penalty, large credit reversals or an admission that could affect other periods.
- Submit through the specified route. Use the form, portal tab, email or physical channel named in the communication. Do not substitute DRC-06 merely because the matter concerns tax, and do not use an audit findings form as a demand reply.
- Lock the final record. Save the signed response, annexure index, uploaded files, acknowledgement, ARN and any error message. If an upload fails, capture the failure and contact the stated help or officer channel before the deadline.
6. How to write the explanation for a discrepancy
Answer one issue at a time. Begin with a short statement of the conclusion, then show the facts, calculation and evidence. Avoid a blanket denial such as “the notice is incorrect” without explaining which transaction, period or assumption fails.
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A practical issue-by-issue format
- Issue: quote the notice paragraph or annexure reference and identify the tax period.
- Department’s figure: reproduce the turnover, tax, credit, refund, interest or penalty amount and the calculation supplied.
- Factual correction: explain differences in period, duplicate invoices, credit notes, cancelled documents, exempt supplies or data extraction.
- Tax treatment: state the classification, rate, eligibility or reversal position that follows from the verified facts. Cite the provision used in your analysis, but have a professional check the law for the relevant year.
- Evidence: list annexure numbers and the exact ledger, invoice, contract, return table or payment record supporting the statement.
- Action requested: specify the amount that should be deleted, revised or kept open for verification, and identify any correction or payment already completed.
Separate facts from legal submissions. If the record is incomplete, say what is missing and provide a timetable only if the officer or rule allows it; do not invent a transaction history. Where confidentiality, legal privilege or personal data is involved, seek advice before uploading unrestricted copies.
7. Preparing for the audit meeting or site visit
Nominate one coordinator who can answer procedural questions and bring the relevant subject-matter owner into the meeting. Keep a visitor or document-log showing what was requested, what was supplied, by whom and on what date. Provide copies or controlled electronic access rather than surrendering originals unless the law or officer’s written direction requires otherwise.
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Before the officer arrives
- Confirm the date, location, officer identity, scope and period in writing.
- Test access to accounting, billing, inventory and document systems that may be required; create a read-only export where possible.
- Prepare a room or secure virtual workspace, an index of records and a contact list for finance, tax, IT and management.
- Brief staff not to speculate. They should answer from records, note unanswered questions and route commitments through the coordinator.
- Run a sample check from return amount to invoice and from invoice to ledger, bank or delivery evidence.
During and after the audit
- Ask the officer to identify the record or calculation supporting each discrepancy.
- Keep a contemporaneous minutes file for requests, explanations, data transfers and agreed follow-up dates.
- Do not alter or backdate records. If a corrected document is issued, preserve the original and the reason for correction.
- Review the written discrepancies promptly. The rules permit the registered person to reply, and the officer is to finalise findings after considering that reply.
- When findings are communicated, compare them with your submission and preserve the stated rights, obligations and reasons. A finding that suggests tax exposure may be followed by separate demand action.
8. Special audit under section 66: what changes
A special audit is distinct from an ordinary section 65 audit. The cited Act text describes an officer not below Assistant Commissioner rank, with prior Commissioner approval, directing examination by a nominated chartered accountant or cost accountant when the case’s complexity and revenue interest warrant it. The audit rules associate the direction with ADT-03 and the findings communication with ADT-04.
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When you receive such a direction, confirm the nominated professional, scope, period, records requested, access arrangements and how questions will be communicated. Treat the engagement as an additional examination, not as permission to ignore the department’s notice or deadlines. Preserve the professional’s requests and your responses separately, and obtain advice on confidentiality, management representations and any disagreement with the scope.
9. Demand show-cause notices and DRC forms
A demand notice requires a different response from an audit information request. Read the section and the proposed consequence: tax, interest, penalty, erroneous refund or input-tax-credit issue. Check whether the communication is a notice, a statement summary, an intimation or an order, and whether it identifies the period, calculation and hearing or reply opportunity.
The rules excerpt identifies DRC-01 as the electronic summary accompanying specified notices, DRC-02 as a summary accompanying a statement and DRC-06 as the representation or reply form in the specified proceedings. DRC-03 is identified for payment intimation in the circumstances described in that excerpt. These forms do not apply to every GST communication. Use DRC-06 only when the notice and applicable rules make it the correct channel, and attach the detailed submission and indexed evidence required by the communication.
If the alleged amount arose from an audit, keep the audit response and demand response cross-referenced but separate. Explain why an audit observation is factually or legally wrong, and address the demand’s own computation, limitation, interest and penalty basis. Do not assume that agreeing to provide records is an admission of tax liability.
10. Common mistakes and how to avoid them
- Missing the actual deadline: relying on the three-month audit period instead of the reply date in a show-cause notice or discrepancy letter. Calendar the stated deadline and verify the applicable rule.
- Sending an incomplete file: uploading a spreadsheet without invoices, ledgers or reconciliation support. Use an annexure index and check every reference before submission.
- Mixing years: applying a current rate, limitation rule or form to an earlier period without checking amendments and commencement. State the period beside every legal conclusion.
- Using the wrong form: treating ADT-02 as a demand reply or DRC-06 as a universal GST response. Match the form to the provision and proceeding named in the notice.
- Giving a net answer: responding to a total discrepancy without addressing each invoice group or adjustment. Number the issues and show a bridge from the department figure to your figure.
- Making unsupported admissions: agreeing with an officer’s description before checking source records. Use qualified factual language and obtain advice where exposure is significant.
- Ignoring portal evidence: failing to save the acknowledgement, upload receipt or error message. The final case file should prove what was submitted and when.
- Overlooking earlier correspondence: contradicting a prior reply or payment without explaining the change. Include earlier notices, submissions and challans in the chronology.
11. A reusable final-submission checklist
- The notice, attachments, service proof and portal reference are preserved.
- The section, authority, tax period, allegation, amount and deadline are stated on the response cover sheet.
- Every issue has a numbered factual answer and a clearly identified legal position.
- Books, invoices, contracts, returns, reconciliations, credit support and refund records are attached only to the extent relevant, with an index.
- Calculations can be traced from the department’s figure to the taxpayer’s figure and then to source records.
- Any correction, payment or request for clarification includes its date, amount and reference.
- A qualified adviser has reviewed material disputes, limitation, penalty, privilege or high-value exposure.
- The submission uses the form and channel named in the actual communication.
- The complete filed package, acknowledgement and any technical-failure evidence are stored in the case file.
12. Keeping the position current
GST procedures and forms can be amended. The official material underlying the statutory points above includes an Act page, audit rules and a CBIC-hosted demand-rules extract published or crawled at different times; the demand extract is historical, and the material does not establish every later amendment or portal instruction. Before filing, check the consolidated CGST Act, current CGST Rules, applicable notifications and the GST portal instructions for the relevant financial year. If no actual notice, tax period and service date are available, no one can determine the precise reply deadline from a generic description alone.
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