ASMT-10 GST Notice: How to File ASMT-11 Reply and Close Scrutiny
Most businesses that receive an ASMT-10 notice assume the worst immediately. The word "scrutiny" appears in the subject line, and the instinct is to panic. But here is what the notice actually is before any conclusions are drawn: it is the GST department flagging a data discrepancy between what you filed and what the department's system is showing, and asking you to explain it.
That is it. At this stage, no demand has been raised. No penalty has been levied. No tax has been assessed. The officer has found something that does not match, and they are giving you the opportunity to either explain it or correct it before any formal proceedings begin.
Section 61 of the CGST Act allows tax officers to scrutinise returns and issue a notice in Form ASMT-10 if discrepancies are found. This notice is not a demand for payment but rather an inquiry into issues such as excess Input Tax Credit claims, under-reported tax liabilities, or mismatches between GSTR-1, e-invoices, and e-way bills.
How you respond in the next 30 days determines whether this stays a routine inquiry or escalates into a full audit or a show-cause notice.
What Is an ASMT-10 Notice Under Section 61?
The provisions of Section 61 deal with the scrutiny of returns and the identification of discrepancies. If a demand for tax or penalties is to be raised, then it needs to invoke the provisions of Section 65 (Audit), Section 66 (Special Audit), Section 67 (Inspection, Search, and Seizure), or Section 73/74 (Tax Determination and Recovery of Dues).
This is the key distinction every taxpayer should understand. An ASMT-10 notice is issued under Section 61 of the CGST Act, 2017, read with Rule 99 of the CGST Rules, 2017. It is a pre-demand inquiry notice. The proper officer is examining your filed returns against data available in the GSTN system and has found one or more points that need explanation.
The notice will contain your GSTIN and legal name, the tax period under scrutiny, a specific description of the discrepancy observed along with the officer's computation of the potential tax, interest, and penalty arising from it, the DIN (Document Identification Number) of the officer, and an instruction to reply within 30 days in Form ASMT-11.
There is no time limit defined for receiving a scrutiny notice. However, a taxpayer should respond to such notice within 30 days from the date of issue, or request for an extension, not more than 15 days.
If you need more time beyond 30 days, you can request an extension of up to 15 additional days. This request does not require a separate form: you mention it in your ASMT-11 response itself.
Eight Common Discrepancies That Trigger an ASMT-10
The GSTN system cross-references data from multiple sources continuously. These are the triggers that generate most ASMT-10 notices in practice:
1. GSTR-1 vs GSTR-3B output tax mismatch: The outward supplies declared in your GSTR-1 do not match the output tax liability you paid through GSTR-3B for the same period. Any gap is flagged as a potential under-payment of tax.
2. ITC claimed in GSTR-3B vs ITC available in GSTR-2B: The Input Tax Credit you claimed in GSTR-3B exceeds what is reflected in your GSTR-2B based on your suppliers' GSTR-1 filings. This is one of the most common triggers in 2024-25 and 2025-26.
3. E-Way Bill turnover vs GSTR-1 turnover: E-Way Bills generated for your outward dispatches show a higher value than the turnover you declared in GSTR-1. This suggests possible under-reporting of outward supplies.
4. Wrong HSN code or tax rate applied: If a business supplies "Automotive Parts" taxable at 28% but uses an HSN code attracting 18%, this discrepancy in the rate of tax will trigger an inquiry.
5. ITC on blocked credits under Section 17(5): Claiming ITC on goods or services prohibited by Section 17(5), for example, food and beverages or personal-use vehicles, is frequently scrutinised if discovered during data analysis.
6. GST turnover vs ITR turnover mismatch: The turnover you declared in your GSTR filings for a financial year differs materially from the turnover shown in your income tax return for the same year. This cross-database check has been systematically enabled.
7. GSTR-1 vs e-invoice data mismatch: For businesses required to generate e-invoices, discrepancies between e-invoice data uploaded to the IRP and GSTR-1 filings are flagged.
8. Reversal of ITC not done for exempt supplies or personal use: Businesses making both taxable and exempt supplies are required to reverse a proportionate share of ITC under Rule 42/43. Where this reversal was not made or was understated, the gap appears in scrutiny.
Your Three Response Options in ASMT-11
After reading the ASMT-10 notice carefully and identifying exactly which discrepancy is being raised, your ASMT-11 reply should fall into one of three approaches:
Option 1: You Fully Disagree with the Discrepancy
If the discrepancy identified by the officer is incorrect or results from a data reconciliation issue that has a clear explanation, respond entirely by explanation with supporting documentation. No payment is required at this stage.
A typical example: the officer flags an ITC mismatch because a supplier filed their GSTR-1 late. Your GSTR-2B showed lower ITC because the supplier had not yet filed. You have the invoices, you made the payment, and the supplier has since filed. Explain this clearly in ASMT-11, attach the relevant invoices and payment proof, and note that the ITC was legitimately availed.
Option 2: You Partially Agree
If some portion of the discrepancy is valid and some portion has an explanation, split your response. For the portion you agree with, make the payment through Form DRC-03 and mention the payment details (ARN, challan number, date, and amount) in your ASMT-11 reply. For the portion you dispute, provide a written explanation with documentary support.
If the registered person agrees to the discrepancy and pays the tax due, they may mention the agreed amount paid and enter the payment particulars in the reply in Form ASMT-11. If yet to pay the admitted amount, payment can be made using Form DRC-03 or by furnishing outward supply invoices in GSTR-1 or by paying tax in GSTR-3B, in reply to the notice.
Option 3: You Fully Agree
If after reviewing the notice, you conclude the discrepancy is correct and you owe the tax identified, pay the full amount through Form DRC-03, and report the payment details in your ASMT-11. This closes the matter at the lowest cost with no further proceedings.
How to File ASMT-11 on the GST Portal: Step by Step
Step 1: Log in to the GST portal at gstin.gov.in using your credentials.
Step 2: Go to Services → User Services → View Notices and Orders. Find the ASMT-10 notice for the relevant tax period. Note the reference number.
Step 3: Go to Services → Returns → View Notices Under Return Processing. Alternatively, navigate directly to the ASMT-11 filing option through Services → User Services → Reply to Notice.
Step 4: Open the ASMT-11 response form. The system auto-populates the GSTIN, name, and notice reference details.
Step 5: For each discrepancy point raised in the ASMT-10, provide a specific, written response. Address every point individually. Do not give a single combined response for multiple discrepancies.
Step 6: Upload supporting documents. Attach reconciliation statements, supplier-wise ITC workings, invoices, e-Way Bill reconciliations, or any other evidence that supports your position. Label each attachment clearly.
Step 7: If you have made a DRC-03 payment for any agreed portion, enter the ARN of the DRC-03 in the payment details section of ASMT-11.
Step 8: Submit the ASMT-11 using DSC (Digital Signature Certificate) or EVC. Download and preserve the acknowledgement with the ARN.
Keep the ARN and acknowledgement of ASMT-11. Track the status of scrutiny on the GST portal under View Additional Notices and Orders. If ASMT-12 closure is issued, preserve it safely. If further proceedings such as DRC-01, audit, or inspection are initiated, prepare a defence using the earlier reply and documentation.
What Happens After You Submit ASMT-11
If the officer is satisfied with your reply: The officer will issue a closure order in Form ASMT-12. This formally closes the scrutiny proceedings for that period. No further action is taken by the department on that specific discrepancy.
If the officer is not satisfied or you did not reply: The officer may proceed with further actions, including an audit under Section 65, inspection and seizure under Section 67, or the determination of tax not paid under Sections 73, 74, or 74A.
Escalation to DRC-01 (formal show cause notice) under Section 73 or 74A means a demand with penalties is now on the table. This is the path every business wants to avoid, and a thorough, well-documented ASMT-11 response is the primary way to prevent it.
ASMT-10 vs DRC-01: Understanding the Escalation Path
These two notices are often confused because both relate to discrepancies in GST returns. They are very different in what they mean.
An ASMT-10 under Section 61 is an inquiry notice. No demand has been raised. The officer is asking questions. You have 30 days to explain.
A DRC-01 under Section 73, 74, or 74A is a formal Show Cause Notice. A demand has been quantified. Tax, interest, and penalty are being claimed. You have 30 days to reply in DRC-06, and ignoring it results in an assessment order under DRC-07.
If adjudication proceeds without issuance of ASMT-10, there may be legal ground to challenge on procedural fairness, as seen in several court judgments. This means the ASMT-10 stage is not just an administrative formality: it has legal significance. Where the department skips ASMT-10 and goes directly to DRC-01 without having raised the discrepancy through Section 61 scrutiny, the resulting proceedings may be procedurally vulnerable.
People Also Ask: ASMT-10 GST Scrutiny Notice
What is an ASMT-10 notice in GST? ASMT-10 is a scrutiny notice issued under Section 61 of the CGST Act, 2017, read with Rule 99 of the CGST Rules, 2017. It is issued when the proper officer finds discrepancies in a taxpayer's filed GST returns. It is not a demand notice. It gives the taxpayer 30 days to file a reply in Form ASMT-11 explaining the discrepancy or paying the difference.
What is the deadline to reply to an ASMT-10 notice? 30 days from the date of issue of the notice. If more time is needed, an extension of up to 15 additional days can be requested, and this request can be mentioned in the ASMT-11 form itself without filing a separate application.
What form is used to reply to ASMT-10? Form ASMT-11 is the prescribed reply form. It is filed on the GST portal and should address each discrepancy point raised in the ASMT-10 individually, with supporting documents attached.
What happens after ASMT-11 is filed? If the officer is satisfied with the explanation or payment, a closure order is issued in Form ASMT-12. If the officer is not satisfied, the matter can be escalated to a formal audit under Section 65 or a show cause notice under Section 73, 74, or 74A.
Is payment mandatory when filing ASMT-11? No. Payment is required only if you agree with the discrepancy raised, either fully or partially. If you disagree entirely and have a documented explanation, you can file ASMT-11 without any payment.
What is Form ASMT-12 in GST? ASMT-12 is the closure order issued by the proper officer after being satisfied with the taxpayer's ASMT-11 reply. It formally closes the Section 61 scrutiny proceedings for the tax period in question.
Real Questions People Ask When They Receive This Notice
"I got an ASMT-10 notice for an ITC mismatch, but the supplier has since filed their GSTR-1 and the credit now shows in my GSTR-2B. What do I do?" This is one of the most common situations. File your ASMT-11 with a clear written explanation: your supplier filed their GSTR-1 late, the ITC was not available in your GSTR-2B at the time you filed GSTR-3B, but the credit is now reflected. Attach your GSTR-2B for the corrected period, the relevant invoices, and the payment proof showing the GST was paid to the supplier. In most cases where the ITC is legitimate and the supplier has since filed, this explanation is accepted at the ASMT-11 stage itself.
"The ASMT-10 lists five separate discrepancy points. Do I need to address all five or just the main one?" Every single point must be addressed individually. An ASMT-11 that handles only two of five points and ignores the rest will typically not result in ASMT-12 closure. It will result in follow-up queries or escalation. Go through each point in sequence, number your responses to match the notice, and provide documentation for each.
"I partially agree with the ASMT-10. Can I pay for the agreed portion and dispute the rest?" Yes, and this is often the cleanest approach. Pay the agreed amount via DRC-03 before submitting your ASMT-11. Then in ASMT-11, enter the DRC-03 payment details for the agreed portion and provide your written explanation with documents for the disputed portion. This shows good faith and limits the interest exposure on the amount you accept.
"I missed the 30-day deadline for ASMT-11. What can I do?" The portal may still allow submission after the deadline in some cases, though this depends on system settings at the time. If the portal blocks the submission, reach out directly to your jurisdictional GST officer with a written explanation for the delay and request that they allow the late filing of ASMT-11. Courts have generally taken the view that taxpayers should not be denied the opportunity to explain before a demand is formalised. If escalation to DRC-01 has already happened, your reply opportunity now shifts to the DRC-06 stage.
"My ASMT-10 mentions a GSTR-1 vs e-invoice mismatch. I never issued e-invoices for that period. Is this notice valid?" If your turnover was below the e-invoice threshold for that period, this discrepancy may be based on incorrect data in the GSTN system. In your ASMT-11, clearly state that you were not required to generate e-invoices for the relevant period based on your aggregate turnover, provide the applicable threshold notification, and include your turnover details. This type of notice occasionally arises from system errors and is resolved at the ASMT-11 stage with a clear, documented reply.
Got an ASMT-10 notice and unsure whether the discrepancy is correct or how to reconcile your GSTR-1 vs GSTR-3B vs GSTR-2B data? Upload your notice to our AI tool. It reads the specific discrepancy raised, identifies whether it is a legitimate mismatch or a system data issue, and builds a point-by-point ASMT-11 response draft with the right reconciliation statements.