"GST audit" and "GST assessment" get used loosely, but they're legally distinct processes with different triggers, timelines and consequences — and knowing which one you're facing changes how you should respond. Here's a plain-language map of scrutiny, audit and the four types of assessment under the CGST Act.
Quick Summary
- Scrutiny (Sec 61): lightweight check of filed returns, notice in ASMT-10, respond in ASMT-11
- Non-filer assessment (Sec 62): best judgment order if you don't file after being reminded — withdrawn if you file within 30 days
- Unregistered person assessment (Sec 63): for those liable but never registered, or operating after cancellation
- Summary assessment (Sec 64): urgent, ex-parte action to protect revenue — used sparingly
- Departmental audit (Sec 65): officers examine your books directly, notice in ADT-01
- Special audit (Sec 66): department-appointed CA/CMA examines complex cases, at department's cost
Scrutiny of Returns (Section 61)
This is usually the first sign something's flagged in your filings — a routine, desk-based check comparing your returns for inconsistencies, not a full audit.
- Officer identifies a discrepancy and issues Form ASMT-10, explaining what looks off
- You respond in Form ASMT-11 within 30 days (usually extendable) — explain the discrepancy, or pay the shortfall with interest
- If your explanation is accepted, the officer closes the matter with Form ASMT-12 — no further action
- If not satisfied, the matter can escalate to audit (Section 65/66), inspection (Section 67), or a formal demand notice (Section 73 for genuine errors, Section 74 for suspected fraud)
Why an ASMT-10 Is Worth Taking Seriously
It looks routine, and often is — but an ignored or poorly documented response is exactly what escalates a minor discrepancy into a formal audit or demand notice. A clear, well-supported reply within the deadline closes most scrutiny matters at this first stage.
The Three Assessment Types (Sections 62-64)
| Section | Applies To | Key Point |
|---|---|---|
| 62 — Best judgment (non-filers) | Registered persons who don't file despite a Section 46 reminder | Order (ASMT-13) deemed withdrawn if valid return filed within 30 days |
| 63 — Unregistered persons | Those liable to register but didn't, or operating after cancellation | Notice ASMT-14, order ASMT-15; can involve heavy demand + penalty |
| 64 — Summary assessment | Urgent cases needing immediate revenue protection | Needs Additional/Joint Commissioner approval; order ASMT-16, can be withdrawn via ASMT-17/18 |
Departmental Audit (Section 65) vs Special Audit (Section 66)
| Section 65 — Departmental Audit | Section 66 — Special Audit | |
|---|---|---|
| Conducted by | Commissioner or authorised GST officers | Independent CA/CMA appointed by the department |
| When used | Any registered person, often risk-based selection (high ITC, mismatches, turnover spikes) | Complex valuation disputes or unusually high ITC claims flagged during scrutiny/audit |
| Notice | Form ADT-01, 15 working days' advance notice | Form ADT-03 order |
| Timeline | 3 months, extendable by 6 months | 90 days, extendable by another 90 |
| Report | Form ADT-02 | Form ADT-04; audit cost borne by the department |
In either case, if the audit finds no discrepancy, it simply closes with no further action. If issues are found, the next step is a show-cause notice under Section 73 (genuine error — lower penalty) or Section 74 (fraud/suppression — steep penalty), though paying the tax and interest voluntarily before a notice is issued can avoid formal proceedings altogether.
Received a GST Notice? Get It Reviewed Before Responding
Rajput Lalit & Associates handles GST notice replies, scrutiny responses and audit representation for businesses across India, with in-person support for clients in Ambala. Book a free consultation or see our GST Notice Reply service.
Frequently Asked Questions
What is the difference between GST scrutiny, audit and assessment?
Scrutiny (Section 61) is a lighter, preliminary check of your filed returns for discrepancies — it doesn't itself create a tax demand. Audit (Sections 65/66) is a deeper examination of your books and records, either by department officers or a specially appointed CA/CMA. Assessment (Sections 62-64) is what happens when there's no return at all, or urgent action is needed — the officer determines your tax liability using available information or their own judgment.
I received an ASMT-10 notice — what does it mean and what should I do?
ASMT-10 is a scrutiny notice under Section 61, pointing out specific discrepancies the officer found in your filed returns (mismatches, unusual ratios, etc.). You get 30 days (usually extendable) to respond in Form ASMT-11 with an explanation or by paying the shortfall. Ignore it, and the matter typically escalates to audit or a formal demand notice under Section 73/74 — so a prompt, well-documented response matters.
What happens if I don't file my GST returns at all?
After a reminder notice under Section 46, the officer can pass a best judgment assessment under Section 62, estimating your tax liability using whatever data is available (past returns, e-way bills, bank data, etc.) — often on the higher side. The good news: if you file the actual valid return within 30 days of that order, the assessment is automatically deemed withdrawn. Filing late is always better than not filing.
Is a GST department audit the same as GSTR-9C?
No. GSTR-9C is a self-certified reconciliation statement you file yourself (mandatory only above ₹5 crore turnover) alongside your annual return. A Section 65 audit is a separate process where department officers actively examine your books, invoices and returns on-site or through document calls — it can happen to any registered business regardless of turnover, usually selected based on risk indicators like high ITC claims, frequent return revisions, or turnover mismatches.
How long does a departmental GST audit take, and what notice do I get?
You get at least 15 working days' advance notice in Form ADT-01. The audit itself is expected to conclude within 3 months, extendable by up to 6 more months by the Commissioner for reasons recorded in writing. Findings are communicated in Form ADT-02, typically within 30 days of the audit's conclusion.
Can I be assessed for GST even if I was never registered?
Yes — Section 63 covers exactly this: a person who should have registered but didn't, someone whose registration was cancelled retrospectively but who kept operating, or an unregistered supplier discovered to be liable. The officer issues a notice (Form ASMT-14), and after considering any response, passes an assessment order (Form ASMT-15). This can carry serious consequences including penalty and, in fraud cases, prosecution.
Disclaimer: This article is for general information based on the CGST Act, 2017 (Sections 61-66) and related rules as of September 2026. Every notice is fact-specific and deadlines are strict — please consult a professional promptly on receiving any GST notice rather than relying solely on general guidance.