Submit an indexed, invoice-level reply that connects every disputed input tax credit (ITC) entry to the notice allegation. The core file should contain the notice and annexures, a disputed-ITC schedule, tax invoices or debit notes, import bills of entry or ISD documents where relevant, purchase and delivery evidence, payment records when non-payment is alleged, and a reconciliation with supplier-reported data and GSTR-3B. Upload only legible PDFs through the workflow named in the notice and retain the acknowledgement and an exact copy of every file.
Start with the notice, not a generic document bundle
A GST ITC denial notice is answered on the facts and legal provision stated in that communication. Before collecting documents, record the communication identifier, issuing authority, tax period, disputed amount, invoice references, cited section or rule, annexure numbers and response deadline. An attachment that proves receipt of goods may not cure a blocked-credit classification, while a supplier-data mismatch may require a different explanation from a non-payment objection.
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Check the identifier before relying on the message. The Directorate General of Intelligence and Enforcement (DGGI) says official communications may be checked using the applicable Document Identification Number (DIN), eOffice issue number or GSTN Reference Number (RFN). Preserve the notice, proof of service and all annexures in their original form.
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For return scrutiny, the proper officer issues FORM GST ASMT-10 describing the discrepancy and quantified amount. The registered person may explain or accept it in FORM GST ASMT-11, after which the officer communicates the result in ASMT-12. The CGST Assessment and Audit Rules state that an ASMT-10 explanation period cannot exceed fifteen days from service. Other proceedings can use different forms and deadlines, so use ASMT-11 only when the notice actually calls for it.
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Build an invoice-level disputed-ITC schedule
Your first annexure should let an officer trace each disputed rupee from the notice to the return and to the supporting evidence. Use one row per invoice or debit note, even when several documents come from the same supplier.
| Column | What to enter | Why it matters |
|---|---|---|
| Notice reference | Notice number, paragraph or annexure row | Shows which allegation the row answers |
| Invoice details | Invoice or debit-note number and date | Matches the primary tax document |
| Supplier identity | Supplier legal name and GSTIN | Connects the claim to supplier-reported data |
| Values | Taxable value, CGST, SGST/UTGST, IGST and total tax | Reconciles the amount claimed and disputed |
| Supply period | Invoice period and return period in which credit was claimed | Exposes timing differences or period errors |
| Supplier reporting | Whether the invoice appears in data available to the recipient, including any amendment or credit note | Answers a mismatch allegation |
| Receipt and use | Goods-receipt or service-acceptance date and business-use description | Supports that the supply occurred and was used for business |
| Payment | Payment or settlement date, method and amount | Addresses a 180-day payment objection |
| GSTR-3B treatment | Return period, table or accounting reference, and any reversal | Shows how the credit was reported |
| Attachment index | File number and page range for each supporting document | Lets the officer verify the answer quickly |
Number the rows and files consistently, for example “Invoice schedule row 07; Annexure 07A, pages 1–4.” If one document answers multiple rows, identify every related row rather than uploading an unlabelled bundle.
Primary tax documents required for ITC
Tax invoices and debit notes
Attach a clear copy of each underlying supplier tax invoice or debit note. Rule 36 of the CGST Rules recognizes prescribed tax documents as the basis for ITC and requires applicable particulars, including the tax amount, description, value, supplier and recipient GSTINs, and place of supply for an inter-State supply. Check that the uploaded copy is readable and that the particulars match the invoice schedule, purchase register and return.
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Where a debit note changes the taxable value or tax, include the original invoice, the debit note and the accounting entry that records the adjustment. For credit notes, show how the reduction was reflected in the purchase register, supplier-reported data and any ITC reversal.
Import and ISD documents
For imported goods, attach the relevant bill of entry showing import IGST and the claimant’s details, together with the accounting or customs record used to post the credit. For credit distributed by an Input Service Distributor, attach the ISD invoice or credit note and the distribution working that links the amount to the recipient registration.
Do not substitute a purchase invoice for an import bill of entry or an ISD document when the notice concerns those categories. Identify the document type in the schedule so the officer can see why it is the applicable basis for that entry.
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Operational evidence that the supply occurred
Rule 36 identifies tax-document categories; operational records are practical evidence used to answer allegations that the transaction was not received, was not used in business or is otherwise doubtful. Attach only records relevant to the allegation, but preserve the complete file in case the officer asks for it.
- Purchase order or contract: Include the order, approved terms, scope, quantity, price and tax treatment.
- Goods receipt: Provide a goods-receipt note, inward register, warehouse record or equivalent showing receipt against the invoice.
- Delivery evidence: Add delivery challans, transporter records and e-way bills where applicable. Match dates, vehicle details and quantities to the invoice.
- Service completion: For services, provide a completion certificate, work acceptance, timesheet, milestone approval, email sign-off or other record showing performance.
- Business use: Explain the business activity or output to which the goods or services relate. Where a notice alleges blocked credit, identify the statutory category and the treatment applied rather than relying only on a generic “business use” statement.
- Accounting trail: Attach the purchase-register entry and relevant general-ledger extract, with a cross-reference to the invoice row.
Label each item with the allegation it answers. A delivery challan should not be presented as proof of payment, and a bank statement should not be presented as proof that a service was completed.
Reconcile supplier data, purchase records and GSTR-3B
Prepare a reconciliation that starts with the purchase register, compares each invoice with supplier-reported invoice data available to the recipient, and ties the result to the ITC actually claimed in the relevant GSTR-3B. Show additions, exclusions, amendments, credit notes, duplicates, blocked-credit classifications and reversals as separate lines.
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| Reconciliation item | Evidence and explanation |
|---|---|
| Invoice appears in both records | Invoice number, date, GSTIN and tax amount agree; cite the schedule row and reporting period |
| Timing difference | State the supplier-reporting period, recipient-claim period and why the credit moved between returns |
| Amendment | Show original and amended values, amendment period and the net amount claimed |
| Duplicate entry | Identify the duplicate, remove or reverse it, and show the resulting calculation |
| Credit note | Match the supplier credit note to the original invoice and quantify the reduction |
| Blocked or ineligible credit | Identify the classification, exclude or reverse the amount and cite the working |
| Reversal already made | Provide the GSTR-3B period, accounting entry, amount and any interest calculation |
Rule 36 links ITC to prescribed documents and supplier-furnished details. Scrutiny procedure also requires an explanation of quantified discrepancies. Therefore, do not attach only a total-level reconciliation: show the invoice rows that add to the amount in the notice and explain every variance.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.If the objection alleges non-payment
When the officer says consideration was not paid, provide a vendor ledger, bank statements, payment vouchers and evidence of set-off, credit adjustment or another documented settlement. Mask unrelated account information only if the remaining record still shows account holder, date, payee, amount and reference clearly.
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Prepare the 180-day calculation
Create a separate calculation for each affected invoice: invoice date, value of supply, tax amount, payments made within 180 days, unpaid balance, date of any later payment and the ITC reversal and re-availment treatment used in your books and returns. The CBIC ITC rules provide reporting and reversal consequences, together with interest, when the recipient fails to pay the supplier the value and tax within the prescribed period. Reconcile your calculation to the vendor ledger and bank entries; explain any netting or set-off in a signed statement from the parties or the underlying contract.
If the objection alleges supplier non-reporting
Attach supplier correspondence, a corrected invoice or return evidence, and a chronology showing when the invoice was issued, when it first appeared in recipient-available data, and when any amendment was made. Include screenshots or downloaded records only when they are legible and identify the relevant GSTIN, invoice number, period and tax amount.
A supplier correction by itself does not guarantee ITC. State which statutory conditions are satisfied, identify the period in which the credit was claimed, and explain any remaining difference. If the supplier has not corrected the data, say so plainly and identify the corrective action requested or already taken instead of asserting that the mismatch is immaterial.
Write the point-by-point reply
Use the notice’s paragraph numbering. Each response should contain four short parts:
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- Allegation: Quote or accurately paraphrase the disputed point and amount.
- Facts: State what happened for the invoice or group of invoices, including dates and return periods.
- Evidence: Cite the schedule row and attachment number and explain what the document proves.
- Relief requested: Ask for withdrawal or correction of the proposed denial, or state the amount voluntarily accepted, reversed or payable.
Add a short statement of facts, a tax and interest calculation where relevant, and a signed authorization letter if a GST practitioner or other representative files. Keep legal submissions separate from factual annexures so the officer can follow the evidence without searching through correspondence.
Upload, preserve and prove filing
- Convert documents to legible PDFs, rotate pages correctly and use descriptive filenames such as
Annexure_07A_Tax_Invoice.pdf. - Arrange the files in the same order as the index and verify that every attachment opens, is complete and corresponds to the cited invoice row.
- Use the portal workflow and form named in the notice. Do not file an ASMT-11 response for a proceeding that does not call for ASMT-11.
- Submit before the stated deadline, allowing time for portal authentication, file-size limits and an electronic verification step.
- Download the ARN or acknowledgement, the submitted reply, the upload list and every final PDF. Store a local copy with the notice and proof of service.
If the portal rejects a file, retain the error message, reduce the PDF size without making pages illegible, and use the channel specified in the notice for technical escalation. A technical problem does not automatically extend a statutory deadline; document each attempted submission and obtain professional advice promptly where time is critical.
Choose the response based on the defect
| Notice issue | Best-supported response | Records to emphasize |
|---|---|---|
| Missing or defective invoice particulars | Provide corrected or complete tax documents and explain the discrepancy | Invoice, debit note, supplier confirmation and schedule |
| Supplier-reporting mismatch | Reconcile periods and amendments; provide correction chronology | Supplier data, correspondence, amended return evidence |
| Non-payment | Prove settlement or calculate reversal and interest | Bank statement, vendor ledger, vouchers, 180-day working |
| Non-receipt or no business use | Establish delivery or service acceptance and business connection | Purchase order, GRN, e-way bill, challan, completion record |
| Blocked or otherwise ineligible credit | Address the cited category and quantify any voluntary reversal | Invoice classification, usage records, reversal and tax workings |
| Import or ISD credit questioned | Use the document category prescribed for that transaction | Bill of entry, ISD invoice or credit note, distribution working |
Also compare the proposed denial with the tax period, any limitation issue, the correction or reversal route, the need for professional representation and the appeal consequences stated in the notice. A high-value or contested matter merits review by a GST practitioner or chartered accountant before filing.
Quick Recap
Master checklist before submission
- Notice, annexures, proof of service and verified communication identifier.
- Signed authority or authorization, when a representative files.
- Indexed point-by-point reply, statement of facts and requested relief.
- Invoice or debit-note copies containing the applicable Rule 36 particulars.
- Bills of entry for import IGST, or ISD invoices and credit notes where applicable.
- Purchase orders, contracts, delivery challans, e-way bills, goods-receipt notes and service-acceptance records relevant to the allegation.
- Purchase register, supplier-reported data, GSTR-3B extracts, credit-note details and reversal reconciliation.
- Vendor ledger, bank statement, payment voucher and 180-day analysis if non-payment is raised.
- Supplier confirmation, corrected-return evidence and chronology for reporting mismatches.
- Tax, interest and reversal workings, plus prior correspondence.
- Portal ARN or acknowledgement and a local copy of every uploaded file.
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