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GST ASMT-10 scrutiny notice: how to reply with a checklist

An ASMT-10 is not a demand – it is the officer asking you to explain discrepancies in your returns. A clear, reconciled reply in ASMT-11 usually closes the matter in ASMT-12. Here is how to read the notice and prepare a reply that works.

Section 61 of the CGST Act and Rule 99 allow the proper officer to scrutinise returns and seek explanations for discrepancies. The notice is issued in FORM GST ASMT-10, and the reply is filed in ASMT-11.

Common discrepancies in ASMT-10

Issue Typical comparison
Outward tax short paid GSTR-1 vs GSTR-3B
Excess ITC GSTR-3B vs GSTR-2A/2B
ITC from cancelled suppliers GSTR-2A vs supplier status
ITC on blocked items Expense heads vs 17(5)
Turnover mismatch GSTR-9 vs income-tax return / e-way bills
RCM not paid Expenses in ITR / financials vs RCM in 3B
Interest on late payment Payment dates vs due dates
E-way bills vs GSTR-1 Goods moved but not reported

How to prepare the reply

  1. Read the notice – period, each discrepancy, amounts and the reply date.
  2. Reconcile each point with monthly working (books, GSTR-1, 3B, 2A/2B, 9/9C).
  3. Classify differences: explained (timing, amendments, data errors), accepted (pay via DRC-03), or disputed (with reasons).
  4. Attach evidence – reconciliation sheets, invoices, credit notes, ledger extracts, payment challans.
  5. Draft ASMT-11 – point-wise, with figures, and a summary table.
  6. File on the portal – Services → User Services → View Notices and Orders → reply.
  7. Track – ASMT-12 closure, or next steps.

Worked example

Example: Narela Agro Enterprises, Narela, receives ASMT-10 for FY 2023-24:

Point Department's figure Pooja's reconciliation Outcome
Tax in GSTR-1 > GSTR-3B by ₹2,40,000 ₹2,40,000 ₹1,90,000 relates to March invoices paid in April 3B; ₹50,000 invoices duplicated in GSTR-1, later amended Explain; no liability
ITC in 3B > 2A by ₹1,10,000 ₹1,10,000 ₹80,000 suppliers filed late (in 2A of later months); ₹30,000 genuinely excess Explain ₹80,000; pay ₹30,000 + interest via DRC-03
ITC from cancelled supplier ₹45,000 ₹45,000 Supplier's registration cancelled after the transaction date; invoice, e-way bill and bank payment available Explain with evidence

The reply sets out each point with annexures and the DRC-03 for ₹30,000 plus interest. The officer issues ASMT-12 accepting the explanation.

Reply drafting tips

  • Answer every point – partial replies invite demands.
  • Use tables; officers handle many files and appreciate clarity.
  • Cite the law correctly (section, rule, circular).
  • Avoid admitting liability without checking – do not pay "to close the matter" if the difference is explained.
  • Ask for a personal hearing if the matter is complex.
  • Keep acknowledgement and all annexures.

Time limits and the next stage

Scrutiny itself has no separate time limit, but any demand must be within the limits of Sections 73/74/74A. If the reply is not accepted, the officer may issue DRC-01A/DRC-01. See Sections 73, 74 and 74A.

Common mistakes

  • Ignoring ASMT-10 because "it is only scrutiny".
  • Replying with a one-line denial without reconciliation.
  • Paying the full amount mentioned without verifying.
  • Missing the reply date and not seeking extension.

Key takeaway

Treat ASMT-10 as an opportunity to close issues early with a reconciled, point-wise reply in ASMT-11. Pay only what is genuinely due. Our GST notice team prepares ASMT-11 replies with full reconciliations; use the Tax Notice Navigator to identify other notices.

Official references

Provisions discussed (summaries in our Law Library):

Official sources to verify the current text, notifications and circulars:

Frequently asked questions

What is the time limit to reply to ASMT-10?

Usually 30 days from the date of the notice, or such further period as the officer allows on request.

Is ASMT-10 a demand notice?

No. It is a scrutiny notice under Section 61 asking for an explanation of discrepancies. If the explanation is accepted, the officer closes the matter in ASMT-12. If not, proceedings under Sections 73/74/74A may follow.

Can I pay tax in response to ASMT-10?

Yes. If you accept a discrepancy, pay the tax with interest through DRC-03 and mention it in your ASMT-11 reply.

What if I do not reply to ASMT-10?

The officer may proceed to audit, inspection or a show cause notice for demand. Not replying usually leads to a demand.

Can ASMT-10 be issued for FY 2017-18 now?

Scrutiny itself has no separate limitation, but any resulting demand must be within the time limits of Sections 73/74. For many early years those limits have expired, which should be raised in the reply.

Should I attend in person?

Replies are filed online. If you request a hearing or the officer calls you, attend with reconciliations; most matters are closed on the written reply.

What is ASMT-12?

The order accepting your explanation and closing the scrutiny proceedings.

This article is general information on the law as on 10 November 2026, written for educational purposes. It is not professional advice for your case. Section numbers under the Income-tax Act, 2025 should be confirmed with the official section mapping on the Income Tax Department website before use in filings.

CA Dilbagh Singh
CA Dilbagh SinghChartered Accountant in practice and Member of the Institute of Chartered Accountants of India, with 15 years in practice in income tax, GST, audit and company compliance. Office: Rohini, Delhi.Related service: GST notice replies & appeals · Tools: free tax tools · Law Library

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