Responding correctly starts with classification, not a template. Preserve the complete communication, identify the issuing authority, statutory section, tax period, allegation, amount, service date, deadline and required filing channel, then build an indexed evidence-backed reply. A section 65 audit, a section 66 special audit, a discrepancy letter and a demand show-cause notice follow different procedures and forms.
First identify what you received
“GST notice” is a broad description, not one legal process. The document may request records for an audit, communicate audit discrepancies, direct a special audit, begin demand proceedings, seek a pre-notice explanation or communicate an adjudication order. Calling every communication an “audit notice” can send a reply to the wrong form or cause a deadline to be missed.
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Read the notice itself and record these particulars before preparing a substantive answer:
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- Statutory section and the financial year or tax period covered.
- Whether the communication is an information request, audit notice, discrepancy or findings letter, show-cause notice, payment intimation or order.
- Alleged mismatch, transaction, return, invoice, credit, refund or exemption at issue.
- Tax, interest, penalty or other amount stated, including the department’s calculation.
- Date and method of service, attachments and any portal reference number.
- Response deadline, permitted extension process and the exact portal form or filing channel.
Download the original notice and every attachment from the GST portal where available. Keep the email, physical delivery record, portal download details, acknowledgements and earlier correspondence in a read-only case folder. The service date can affect limitation and the time available to respond.
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Use this triage workflow in the first 24 hours
- Preserve the evidence. Save the complete PDF, annexures, notices shown on the portal, delivery proof and prior replies. Do not work from a screenshot or an incomplete email.
- Map the legal route. Match the section and wording to an audit, special audit, discrepancy communication, demand proceeding or order. If the document does not clearly state the route, obtain professional advice instead of guessing.
- Calendar the stated deadline. Enter the last date, a personal internal deadline several days earlier and any hearing date. The statutory timing for the department to complete an audit is not automatically the taxpayer’s reply period.
- Assign one owner per request. Allocate sales, purchase, accounts, logistics, refunds and information-technology records to people who can certify what they provide.
- Freeze the relevant data. Preserve accounting ledgers, invoice registers, returns, e-way bill data, contracts and correspondence for the periods named in the notice. Do not overwrite a spreadsheet or alter an invoice without retaining the original.
- Prepare an issue list. Give each allegation a number and identify the records needed to prove or disprove it.
- Escalate disputed exposure. If facts, tax calculation, penalty, limitation, privilege or a possible admission are disputed, have a qualified GST practitioner, chartered accountant or tax lawyer review the position before filing.
Which GST process applies?
| Communication or process | Purpose and authority | Forms identified in the rules | What the recipient should do |
|---|---|---|---|
| Section 65 ordinary audit | Officer examines books, returns and related records of a registered person. | FORM GST ADT-01 for the audit notice; FORM GST ADT-02 for audit findings. | Provide access and information, reconcile the period, answer each discrepancy and retain proof of submission. |
| Section 66 special audit | Where the case is complex and revenue interest warrants it, an officer not below Assistant Commissioner rank, with prior Commissioner approval, directs examination by a nominated chartered accountant or cost accountant. | FORM GST ADT-03 for the direction; FORM GST ADT-04 for findings. | Confirm the direction, scope and nominated professional; supply records consistently and obtain advice on the findings. |
| Specified demand proceedings | Proceedings concerning tax not paid or short paid, erroneous refund or input tax credit allegedly wrongly availed or used, under the provision cited in the notice. | DRC-01 is the electronic summary accompanying a notice; DRC-02 accompanies a statement; DRC-06 is the representation or reply form; DRC-03 is used for payment intimation in the circumstances described by the applicable rules. | Use the form and channel stated in the actual communication. Do not use DRC-06 merely because the matter involves GST. |
| Pre-notice intimation or information request | Seeks clarification or documents before a formal demand or other action. | Not every request uses the demand forms. | Answer the stated questions factually and preserve the response; a later show-cause notice may still follow. |
| Adjudication order | Communicates a decision after proceedings, rather than asking for an initial explanation. | The form and appeal route depend on the order and applicable provision. | Read the operative portion, payment directions and appeal limitation immediately; do not treat it as an ordinary information request. |
The forms above are not interchangeable. An audit findings communication can lead to separate demand action; it is not itself the demand reply. The exact section, period and wording on the notice control.
Section 65 audit: statutory timing and taxpayer obligations
Notice before the audit
Under section 65 of the CGST Act, the registered person must be informed at least 15 working days before the audit. This is a statutory notice period for the audit process. It does not establish a universal 15-day reply period for every GST communication.
When the audit starts and how long it may take
The statutory commencement date is the later of the date on which the required records are made available and the date on which the audit actually begins at the business premises. The audit is to be completed within three months from that commencement. The Commissioner may extend it by up to six further months where reasons are recorded.
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Findings after completion
Findings, the taxpayer’s rights and obligations, and the reasons for those findings are to be communicated within 30 days after the audit concludes. These periods regulate the department’s audit process; the response deadline for a particular discrepancy or demand must still be read from that communication and the provision applicable to its tax period.
Where the audit can occur
An authorised officer may require access to books and documents, information and assistance. The audit may take place at the registered person’s business premises or in the tax office, as directed. Arrange a secure room, a document index and an employee who can explain the accounting system without making unsupported legal concessions.
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Build an audit-ready record set
The audit rules describe verification of the books and documents supporting accounts, returns and statements. They also identify turnover, exemptions and deductions, tax rates, input tax credit availed and utilised, refunds and other relevant issues. Organise records around those checks rather than sending an unstructured data dump.
Core accounting and registration records
- General ledger, trial balance, chart of accounts and audited or management financial statements for the named periods.
- Sales and purchase registers, debit and credit notes, journal vouchers and fixed-asset registers.
- GST registration details, amendments, additional places of business and authorised-signatory records.
- Bank statements and payment evidence that tie material invoices to the books.
Returns and tax calculations
- Filed returns and statements for each relevant tax period, together with filed-versus-books reconciliations.
- Output-tax computation by rate, place of supply, reverse-charge treatment and exempt or non-GST turnover.
- Interest or late-fee workings where a correction or delayed payment is acknowledged.
- Electronic liability, cash and credit ledger extracts, with dates and reference numbers.
Input tax credit support
- Tax invoices, debit notes, receipt or service-completion evidence and payment records.
- Vendor-level reconciliation to the relevant auto-populated statement where relied upon, with explanations for timing differences.
- Blocked-credit analysis, reversals, reclaims and proportionate reversals for exempt or non-business use.
- Import documents, bills of entry and documents supporting input services or capital goods.
Turnover, exemptions, refunds and commercial evidence
- Customer contracts, purchase orders, delivery records, e-way bills and proof of export or zero-rated supply where relevant.
- Exemption notifications or classification analysis used for each material category.
- Refund applications, statements, sanction or rejection orders and bank-realisation evidence.
- Inter-unit, related-party and branch-transfer workings, including valuation support.
Use a naming convention such as 01_Returns_FY2024-25 and a master index with document owner, date, period and issue number. Keep a copy of what was handed over; an auditor’s working copy should not become the only copy of the business record.
Reconcile before you explain
A reconciliation lets the officer trace a reported figure to its source and lets you find errors before they become admissions. Prepare one schedule for each material issue rather than one unexplained net difference.
| Reconciliation | Minimum fields | Typical explanation for a difference |
|---|---|---|
| Books to outward supplies and returns | Ledger turnover, invoice series, return taxable value and tax rate by period. | Timing, credit note, place-of-supply correction, exempt turnover or an omitted invoice. |
| Books to tax payment | Output liability, cash paid, credit utilised, interest and ledger references. | Amendment in a later period, reverse charge, rate correction or payment already made. |
| Purchase register to input credit | Supplier GSTIN, invoice number and date, taxable value, tax amount, eligibility and return period. | Invoice timing, duplicate entry, blocked credit, reversal or supplier amendment. |
| Refund claim to books and bank | Claim period, export or eligible turnover, net ITC, sanctioned amount and realisation evidence. | Unrealised proceeds, ineligible invoice, calculation adjustment or a sanctioned amount different from the claim. |
For every difference, state whether it is a timing difference, a factual error, a legal position requiring review or an amount already corrected. Avoid a blanket statement that “all records are correct” when one invoice or period remains unresolved.
How to draft the response
Use a numbered response schedule that mirrors the notice. This makes it possible for the officer to connect each answer to the allegation and attachment.
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| Column | What to write |
|---|---|
| Issue number | Copy the notice’s paragraph, annexure or transaction reference. |
| Department assertion | Quote or accurately summarise the calculation, period and provision without changing its meaning. |
| Factual response | State what happened, with dates, invoice numbers, ledger accounts and responsible records. |
| Legal position | Explain the provision or interpretation being relied on; obtain advice where tax, penalty, limitation or privilege is disputed. |
| Evidence | Give an attachment number and page range. Cross-reference the reconciliation and source file. |
| Correction or payment | State any amendment, reversal or payment already made, with the electronic reference and date, without implying agreement beyond what was actually corrected. |
Use precise admissions and disagreements
If an invoice was omitted, say which invoice, tax period and amount are involved and what correction was made. If the allegation is wrong, identify the exact ledger, return field, contract clause or invoice that disproves it. Explain why a proposed tax calculation double-counts a transaction or applies the wrong rate. Unsupported denials and broad admissions both make later proceedings harder to defend.
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Number files consistently, add a short description and state the relevant period. For large exports, provide a filtered schedule that shows the answer and retain the underlying data. Redact personal information only where legally appropriate and ensure that redactions do not hide a number needed to verify the claim.
Submitting the reply and proving submission
- Check whether the notice requires a portal response, an upload in a named form, an email, a physical submission or attendance at a hearing.
- Use the exact GSTIN, notice reference, period and form shown in the communication.
- Upload readable files within the portal’s size and format limits. Split large evidence into clearly labelled parts and mention the complete index in the response.
- Preview the final text and attachments before signing or submitting. A draft saved in the portal is not proof of filing.
- Download the acknowledgement, ARN or submission receipt immediately. Save the final submitted PDF or generated form, attachment list and timestamp in the case folder.
- If the portal fails, capture the error, time and reference number and follow the alternative channel or escalation instruction in the notice. Do not silently wait until the deadline expires.
DRC-06 is identified in the rules for the specified demand proceedings to which it applies. The existence of a DRC form does not mean every audit response belongs in DRC-06. Follow the notice-specific instruction.
Audit findings are not automatically a demand order
After an audit, the officer may communicate discrepancies and consider the registered person’s reply. If the audit detects tax not paid or short paid, an erroneous refund or input tax credit allegedly wrongly availed or used, the cited Act text says the proper officer may initiate action under section 73 or section 74. The provision applicable to a particular financial year can depend on amendments and commencement dates, so the audit finding should not be treated as a complete current analysis of every case.
Read any later demand notice independently. Check its section, tax period, computation, limitation, interest and penalty basis, and the form or hearing procedure stated there. A response to ADT-02 does not replace a response to a subsequently issued demand notice.
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Special audit under section 66
A special audit is distinct from the ordinary section 65 audit. The cited Act text describes a direction by an officer not below Assistant Commissioner rank, with prior approval of the Commissioner, where the case’s complexity and revenue interest justify examination by a nominated chartered accountant or cost accountant. The rules associate the direction with ADT-03 and the findings communication with ADT-04.
When you receive a special-audit direction, verify the approving authority, nominated professional, scope, records requested and period covered. Establish one controlled channel for providing data, keep a delivery log and ask for clarification in writing when a request is ambiguous. Have an adviser review the findings before accepting a calculation or signing a statement that could affect later demand proceedings.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What to do during an audit visit or records review
- Nominate a finance lead and a substitute who know the ledger, return process and document index.
- Provide records through the agreed index; keep a copy of each file and note the date supplied.
- Answer questions from verified records. If the answer requires checking, say so and provide a written follow-up rather than guessing.
- Separate factual explanations from legal submissions. A staff member should not concede taxability or ineligibility without authority.
- Record requests, explanations given, outstanding items and promised follow-up dates in meeting notes.
- Protect confidential third-party information and personal data while complying with a lawful request for records.
Common mistakes and how to correct them
| Mistake | Why it causes trouble | Better practice |
|---|---|---|
| Calling every letter an audit notice | The wrong form, provision or deadline may be used. | Classify it by section, purpose and requested action before drafting. |
| Using the three-month audit period as the reply deadline | Department completion timing and taxpayer response timing are different. | Calendar the deadline printed in the communication and verify the governing rule. |
| Sending raw spreadsheets without an index | The officer cannot trace totals and material evidence may be overlooked. | Submit an issue-based schedule with attachment numbers and page references. |
| Making a blanket denial | It fails to answer the transaction-level allegation and can undermine credibility. | Address each invoice, period, calculation and legal reason separately. |
| Admitting an amount to end the discussion | An imprecise admission may affect tax, interest, penalty or later proceedings. | State only verified facts; obtain professional advice before a disputed admission or payment. |
| Relying on an email draft or portal screenshot | There may be no proof that the complete response was filed. | Download the final acknowledgement and submitted attachment list. |
| Ignoring a later demand notice after an audit | Audit findings and demand proceedings have separate procedural steps. | Review and answer the later notice under its own section and deadline. |
When professional advice is prudent
Get qualified GST, accounting or legal assistance promptly when the notice alleges fraud or suppression, covers multiple years or registrations, proposes a large tax or penalty, questions limitation, involves related-party valuation, seeks privileged material, or follows a special-audit direction. Advice is also sensible when the notice is unclear, the portal deadline conflicts with the document, records are incomplete, or the business is considering payment while disputing liability.
A professional cannot cure a missed deadline by itself. Send the adviser the original notice, service proof, portal history, response deadline, issue schedule and reconciliations at the first meeting.
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Keep the system ready for the next notice
- Close each month with a books-to-returns and purchase-register-to-credit reconciliation.
- Maintain an invoice, contract and payment trail for material or unusual transactions.
- Document exemption, classification, reverse-charge and credit-eligibility decisions when made.
- Keep a register of notices, hearings, replies, acknowledgements and payments by GSTIN and period.
- Review the consolidated CGST Act, Rules, notifications and portal instructions applicable to the relevant financial year; printed bare-act editions can become outdated after amendments.
Official legal material and portal procedures can change, and a demand-rules publication may not reflect every later amendment. For a live case, verify the current consolidated provisions and the notice-specific deadline rather than relying on a general checklist.
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Frequently Asked Questions
Does a section 65 audit notice always give me 15 days to reply?
No. The 15-working-day rule concerns advance information before the audit. The response deadline for a discrepancy, demand notice or other communication is controlled by that document and its applicable provision.
Is ADT-02 the same as a demand notice?
No. ADT-02 communicates section 65 audit findings. A later demand proceeding has its own statutory basis, notice and reply procedure; the applicable rules identify DRC forms for specified demand proceedings.
Can I file DRC-06 for any GST letter?
No. DRC-06 is identified for the specified proceedings covered by the demand rules. Use the form and channel stated in the actual communication.
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What if the GST portal does not accept my response?
Capture the error and time, preserve the complete response and attachments, and use the alternative filing or escalation channel stated in the notice. Keep the resulting acknowledgement or reference number.
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