Received a scrutiny notice in Form GST ASMT-10 under Section 61? The officer has compared your returns against the CBIC scrutiny parameters and listed discrepancies – you have 30 days to reply in Form ASMT-11, explain or pay each point, and seek closure through ASMT-12. This free CA-built tool drafts a professional parameter-wise reply covering all 13 standard scrutiny parameters from CBIC Instruction 02/2022, with reconciliation annexure formats, current case law, admitted-amount handling via DRC-03, and the prayer for dropping proceedings – ready to attach to your online ASMT-11.
1Taxpayer and notice details
2Preliminary objections (tick if applicable)
3Discrepancies raised in the notice (select all that apply)
These are the 13 standard scrutiny parameters from Annexure B of CBIC Instruction 02/2022-GST – ASMT-10 notices are built from this list. For each: the amount alleged, any amount you admit (0 = fully contested), and your specific facts.
4Payment of admitted amounts (if any)
How GST return scrutiny works (Section 61)
Under Section 61 read with Rule 99, the proper officer scrutinises the returns you have furnished and, if discrepancies appear, issues Form ASMT-10 – quantifying the tax, interest and other amounts where possible. You respond in Form ASMT-11 within 30 days (or such further time as the officer permits): accept a discrepancy and pay through DRC-03, explain it, or do both for different points. If your explanation is found acceptable, the officer must drop the proceedings in Form ASMT-12 – and Section 61(2) bars any further action on those discrepancies. If not, the matter can move to audit (Section 65), special audit (66), inspection (67) or a demand under Section 73/74.
The department’s own SOP binds the officer to timelines too: ASMT-12 within 30 days of your reply, and any Section 73/74 action within 30 days of the reply (or 15 days after your reply window lapses unanswered). Since May 2023 scrutiny runs through the automated ACES-GST module – notices are served only via the portal, one consolidated ASMT-10 per GSTIN per financial year.
The 13 standard scrutiny parameters (CBIC Instruction 02/2022)
| # | Parameter | What the officer compares |
|---|---|---|
| 1 | Outward liability: GSTR-1 vs 3B | Tables 3.1(a)/(b) of 3B vs GSTR-1 tables 4-11 net of amendments |
| 2 | RCM liability and RCM ITC | 3B 3.1(d) vs RCM ITC in 4(A)(2)/(3), vs 2A RCM-flagged supplies, and cash payment in 6.1 |
| 3 | ISD credit | 3B 4(A)(4) vs GSTR-2A Table 7 |
| 4 | All other ITC | 3B 4(A)(5) vs GSTR-2A/2B – the most common notice |
| 5 | TDS/TCS turnover cross-check | 3.1(a) taxable value vs GSTR-2A Table 9 (GSTR-7/8 data) |
| 6 | E-way bill vs returns | Liability per e-way bills vs 3.1(a)/(b) |
| 7 | ITC from retrospectively cancelled suppliers | Invoices dated after supplier’s effective cancellation date |
| 8 | ITC from GSTR-3B non-filer suppliers | 2A rows with 3B filing status “No” |
| 9 | Section 16(4) time-barred ITC | 3B filed after the last availment date |
| 10 | Import IGST credit | 4(A)(1) vs 2A Tables 10/11 (ICEGATE) |
| 11 | Rules 42/43 reversals | Whether exempt/personal-use reversals made in 4(B) |
| 12 | Interest under Section 50 | Delayed filing / delayed cash set-off |
| 13 | Late fee under Section 47 | Delayed returns |
Do’s and don’ts for an ASMT-11 reply
- Do reply parameter-wise, in the same order as the notice, with a reconciliation annexure for every numeric point – assertion without workings persuades no one.
- Do pay genuinely admitted points via DRC-03 with interest and quote the ARN – partial admission is expressly supported, and it builds credibility for the contested points.
- Do seek closure: pray specifically for the proceedings to be dropped under Form ASMT-12 – acceptance bars re-agitation of the same points (Section 61(2)).
- Do ask for an extension in writing before day 30 if you need time – the rule permits further period at the officer’s discretion.
- Don’t ignore vagueness – if the notice does not quantify or specify discrepancies, say so: the SOP itself requires notices to be “specific in nature and not vague or general”.
- Don’t answer beyond the returns – scrutiny under Section 61 is confined to the returns and particulars furnished; document-fishing beyond that scope has been held without jurisdiction (Jharkhand High Court, 2025).
- Don’t miss that an order ignoring your reply is challengeable – orders passed without considering the ASMT-11 response are routinely quashed for non-application of mind.
Frequently asked questions
What happens if I do not reply to ASMT-10 within 30 days?
The officer can initiate audit, inspection or Section 73/74 proceedings – the SOP directs action within 15 days of the window lapsing. Always reply, or at least seek an extension in writing before the deadline.
Can I accept some points and contest others?
Yes. Pay the admitted points via DRC-03 (with interest) and explain the rest – the ASMT-11 form has per-discrepancy amount fields, and partial admission is normal practice.
What if my explanation is accepted?
The officer must issue Form ASMT-12 dropping the proceedings, and under Section 61(2) no further action can be taken on those discrepancies – which is why a thorough first reply matters.
Can the officer demand documents unrelated to my returns in scrutiny?
Section 61 scrutiny is confined to the returns and the particulars furnished with them. Courts have quashed scrutiny notices used as roving inquiries beyond that scope – though genuine return discrepancies must still be answered on merits.
Is ASMT-10 compulsory before a Section 73 demand?
Where the demand arises from scrutiny of returns, the Madras High Court has held ASMT-10 mandatory (Vadivel Pyrotech; Mandarina Apartment). The position is arguable rather than absolute – a demand can also arise independently of scrutiny – but skipping ASMT-10 in a scrutiny-triggered case is a ground worth taking.
Can I attach documents to ASMT-11?
Yes – unlike the DRC-01B/01C intimations, ASMT-11 accepts attachments (PDF, up to 5 MB per file). The detailed reply letter generated here, with annexures, is attached and a short summary goes in the reply box.