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When is GST Audit Required?

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WHAT IS GST AUDIT?

A GST Audit is a systematic and independent examination of a registered taxpayer’s books of accounts, GST returns, records, and supporting documents to verify the correctness of turnover, tax liability, Input Tax Credit (ITC), refunds, and overall compliance with the provisions of the GST law.

GST Audit ensures that businesses are accurately complying with GST regulations as prescribed under the CGST Act, 2017 and Rules made thereunder.

TYPES OF GST AUDIT

1. GST Audit by Tax Authorities (Section 65) This audit is conducted by GST officers authorised by the department.
1. GST Audit by Tax Authorities (Section 65)

This audit is conducted by GST officers authorised by the department.
Key features:
• Conducted at the taxpayer’s place of business or tax office
• Prior notice is issued
• Audit must be completed within prescribed timelines
• Findings are communicated to the taxpayer
Coverage includes:
• Returns filed
• Input Tax Credit (ITC) availed
• Tax payments
• Refunds claimed
2. Special GST Audit (Section 66)

A Special Audit may be ordered when:
• Transactions are complex
• Input Tax Credit (ITC) availed is excessive
• Valuation or classification issues exist
Important points:
• Conducted by a Chartered Accountant (CA) or Cost Accountant (CMA) nominated by the department
• Cost of audit is borne by the Government
• Audit report forms the basis for further
proceedings
3. Scrutiny of Returns (Section 61)

Scrutiny is a preliminary compliance check conducted by GST authorities.
Key aspects:
• Focuses on discrepancies in GST returns
• Taxpayer is issued a notice seeking explanation
• Can lead to audit, investigation, or demand proceedings if discrepancies persist

Note: Mandatory statutory GST audit by professionals has been removed; however, departmental audits, scrutiny, and special audits continue under GST law.

OUR GST AUDIT SERVICES

We assist businesses through every stage of the GST audit process, including:

• Review of GST returns (GSTR-1, GSTR-3B, GSTR-9, etc.)
• Reconciliation of turnover, ITC, and tax liability
• Verification of books of accounts and supporting documents
• Identification of errors, mismatches, and potential risks
• Drafting replies to GST audit notices and queries
• Representation before GST authorities
• Assistance in tax payment, refund issues, and rectifications

CONSEQUENCES OF GST AUDIT

When a GST audit (by tax authorities or special audit) is completed, the department issues audit findings. Based on these findings, the following consequences may arise:
A. Additional Tax Demand

If the audit reveals:
• Short payment of tax
• Excess Input Tax Credit (ITC) claimed
• Incorrect classification or rate
The taxpayer must pay the differential tax.
B. Interest Liability

Interest is charged if tax was paid late or short-paid.
• 18% per annum – normal cases
• 24% per annum – undue or excess Input Tax Credit
(ITC) wrongly availed and utilized Interest is mandatory and cannot be waived.
C. Penalty Proceedings

If discrepancies are due to:
• Negligence, or
• Incorrect interpretation, or
• Suppression or fraud
Penalty proceedings may be initiated under Section 73 or 74.
D. Recovery Proceedings

If the taxpayer does not pay dues:
• Bank account attachment
• Recovery from debtors
• Sale of goods or property
E. Prosecution (Serious Cases)

In cases involving fraud, fake invoices, or tax evasion, prosecution may be initiated, including:
• Fines
• Imprisonment (for large tax evasion cases)

PENALTIES UNDER GST LAW

Penalties depend on the nature of default.
A. General Penalty – Section 125

Applicable when no specific penalty is prescribed.
• Up to ₹25,000 (CGST ₹12,500 + SGST ₹12,500)
B. Penalty for Short Payment / Wrong ITC

• Penalty: 10% of tax due or ₹10,000 (whichever is higher)
• If tax + interest paid before notice → No penalty

📌 Section 74 – Fraud / Willful Misstatement (Intentional tax evasion)

• Penalty: 100% of tax due
• Reduced penalty available if paid early:
o 15% before notice
o 25% within 30 days of order
C. Penalty for Incorrect Returns

Late filing of returns:
o ₹50 per day (₹20 per day for Nil returns)
o Maximum: ₹5,000 (subject to notifications)
D. Penalty for Fake Invoices / Input Tax Credit (ITC) Fraud

• Penalty equal to tax amount involved
• Cancellation of GST registration
• Possible arrest in high-value cases

GST AUDIT COMPLIANCES

To remain audit-ready, taxpayers must ensure:

• Proper maintenance of books of accounts as prescribed
• Accurate and timely filing of:

 GSTR-1
 GSTR-3B
 Annual Return (where applicable)

• Monthly and annual reconciliation of data
• Correct classification of goods/services and GST rates
• Proper documentation for:

 Input Tax Credit (ITC) claims
 Exempt supplies
 Reverse Charge Mechanism (RCM)

• Preservation of records for at least 72 months
• Prompt and complete response to audit notices

SCOPE OF GST AUDIT

The scope of a GST audit is wide and covers multiple compliance areas, including:
S. No.Area of ReviewScope / Activities
1Turnover Verification
  • Reconciliation of books with GST returns
  • Verification of taxable, exempt, zero-rated, and non-GST supplies
  • Identification of under-reported turnover
2Tax Liability Review
  • Correct GST rate application
  • Place of supply determination
  • Reverse charge compliance
  • Interest and late fee applicability
3Input Tax Credit (ITC) Examination
  • Eligibility under Section 16
  • Blocked credits under Section 17(5)
  • ITC reversals under applicable rules
  • Matching ITC with GSTR-2B
4Return & Reconciliation Review
  • GSTR-1 vs GSTR-3B matching
  • Books vs returns reconciliation
  • Annual return consistency
5E-Invoicing & E-Way Bill Compliance
  • Applicability checks
  • IRN generation
  • Invoice and transport document matching
6Refunds & Adjustments
  • Verification of refund claims
  • Supporting documents and eligibility
  • Incorrect or excess refund identification

BENEFITS OF GST AUDIT

A properly conducted GST audit provides multiple advantages:
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WHY PROFESSIONAL GST AUDIT SUPPORT IS IMPORTANT?

GST law is technical and evolving. Professional GST audit support helps businesses:
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GST AUDIT CHECKLIST

Area Compliance Task Frequency / Timeline Responsible Person
GST Registration Verify registration details & amendments Annual / As needed Accounts / Compliance
Books of Accounts Maintain purchase, sales, ledger, and journal Ongoing Accounts
Invoices Issue GST-compliant invoices & e-invoices Per transaction Accounts
Input Tax Credit (ITC) Verify eligibility, blocked credits, and reversals Monthly / Quarterly Accounts
GSTR-1 & GSTR-3B Reconcile returns with books Monthly Accounts
Annual Return (GSTR-9/9C) Prepare and file annual return Yearly Accounts / CA
E-Way Bill Ensure generation & validity for goods movement Per dispatch Logistics / Accounts
Refunds & Adjustments Verify eligibility & supporting documents As applicable Accounts
Payment of Tax Timely payment of GST & interest Monthly / Quarterly Accounts
Audit Records Preserve records for at least 72 months Ongoing Accounts
Scrutiny / Notices Track and respond to notices As received Compliance / CA
Internal Controls Conduct periodic review and reconciliation Quarterly Accounts / Audit

FREQUENTLY ASKED QUESTIONS (FAQs)

A GST Audit is an examination of a taxpayer’s books, returns, and records to verify correctness of turnover, tax paid, Input Tax Credit (ITC) claimed, and overall compliance under GST law.

  • Businesses with turnover exceeding the threshold (as per the CGST Act)
  • Businesses selected by authorities for special audit or scrutiny
  1. Audit by Tax Authorities (Sec 65)
  2. Special Audit by CA/CMA (Sec 66)
  3. Scrutiny of Returns (Sec 61)
  • Turnover verification
  • Tax liability assessment
  • ITC eligibility & reversals
  • Return reconciliation
  • E-invoice & e-way bill compliance
  • Refunds & adjustments
  • Maintain accurate books and invoices
  • Perform periodic reconciliations
  • Respond to notices on time
  • Retain all supporting documentation
  • Ensures compliance and accuracy
  • Minimizes penalties and interest
  • Improves internal controls
  • Reduces audit risk and litigation

At least 72 months from the due date of filing the annual return for the relevant financial year.

Ordered under Section 66, it is conducted by a Chartered Accountant or Cost Accountant appointed by the tax authorities for complex or high-risk transactions.

Yes, GST audit examines ITC claims for eligibility, blocked credits, and reversals to avoid mismatches with returns.

Statutory audit by professionals is no longer mandatory for all. However, departmental audits and scrutiny may still be conducted.

By ensuring accurate reporting reconciliation, ITC verification, and timely compliance, businesses reduce risk of penalties and interest.

Yes, the audit reviews e-invoice generation, IRN, validity, and matching with e-way bills for compliance.

Internal GST reviews or mock audits are recommended quarterly or before year-end filing to identify and rectify issues.

  • Tax authorities for official audits
  • Chartered Accountants (CA) / Cost Accountants (CMA) for special audits or voluntary review

Professional advisory helps in:

  • Reviewing records and returns
  • Performing reconciliations
  • Preparing audit-ready documentation
  • Responding effectively to notices

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