Notices and scrutiny

ASMT-10 scrutiny notice reply format: how to draft Form ASMT-11

By gstr2bmatch.in Editorial Team · Updated 14 October 2026 · 7 min read

A notice in Form GST ASMT-10 is a discrepancy intimation issued under Section 61 of the CGST Act after desktop scrutiny of your GST returns. You have thirty days under Rule 99 to file your point-by-point explanation in Form GST ASMT-11. Submitting a clear reconciliation statement, invoice annexures, and challans leads to an order in Form GST ASMT-12 dropping the proceedings without a formal show cause notice.

Receiving an email or SMS notification about an order or notice under Scrutiny of Returns often causes panic in the accounts department. Many taxpayers confuse Form GST ASMT-10 with a demand notice. Form GST ASMT-10 is not an assessment order or a final tax demand. It is an opportunity to explain apparent discrepancies spotted by the system or the tax officer between your returns before any formal demand is raised.

Understanding the statutory workflow under Section 61 of the CGST Act and Rule 99 of the CGST Rules allows you to draft a factual defense, close the scrutiny, and avoid escalation into costly show cause notices under Section 73, Section 74, or Section 74A.

What is Form GST ASMT-10 and why is it issued?

Under Section 61(1) of the CGST Act, the proper officer may scrutinize returns and related particulars furnished by a registered person to verify their correctness. When the officer detects differences, they issue a notice in Form GST ASMT-10 pointing out specific discrepancies and quantifying tax, interest, and penalties where possible.

Common triggers for scrutiny notices under Rule 99 include:

1. Outward liability differences: turnover reported in GSTR-1 does not match tax paid in GSTR-3B Table 3.1(a).

2. ITC mismatches: input tax credit claimed in GSTR-3B Table 4(A)(5) exceeds ITC auto-populated in GSTR-2B or available in GSTR-2A.

3. E-way bill and e-invoice variations: outward taxable values in GSTR-1 are lower than the total value of e-way bills generated during the financial year.

4. Ineligible ITC claims: credit claimed on blocked items under Section 17(5) such as motor vehicles, works contracts, or personal expenses.

5. ITC timing differences: credit availed in GSTR-3B in one tax period while the supplier reported the invoice in a different period or after the Section 16(4) cutoff date.

Statutory difference: Form GST ASMT-10 is purely an intimation of discrepancies. If you answer all queries satisfactorily, the officer drops the matter. It does not automatically create a recoverable liability on the electronic liability ledger.

Statutory timeline and procedure under Rule 99

The entire scrutiny workflow follows a three-step statutory process laid down in Rule 99 of the CGST Rules:

ASMT-10 issued by officer → ASMT-11 reply within 30 days → ASMT-12 acceptance order
  1. Notice in Form GST ASMT-10: Issued under Rule 99(1). Specifies the parameters examined, the exact figures questioned, and the explanation required within thirty days from service.
  2. Reply in Form GST ASMT-11: Filed by the taxpayer under Rule 99(2). You can accept the discrepancy in full, accept it in part and pay tax with interest via Form GST DRC-03, or contest the discrepancy with facts and documents.
  3. Order in Form GST ASMT-12: Issued under Rule 99(3) if the officer finds your reply acceptable. The order states that the explanation has been accepted and no further action is taken.

Notice risk: Under Section 61(3) of the CGST Act, if you fail to submit a satisfactory explanation within thirty days or do not pay accepted dues, the officer can initiate departmental audit under Section 65, special audit under Section 66, inspection under Section 67, or issue a summary show cause notice under Section 73, Section 74, or Form GST DRC-01 under Section 74A.

How to navigate and download ASMT-10 on the GST portal

Taxpayers often miss scrutiny notices because ASMT-10 does not appear in the standard View Notices section. As outlined in the official portal return filing guidance on tutorial.gst.gov.in, notices and return orders are housed under specific user services menus.

  1. Log in to the GST portal at gst.gov.in.
  2. Navigate to Services → User Services → View Additional Notices and Orders.
  3. Locate the row showing Type as Scrutiny of Returns.
  4. Click View to open the case details page.
  5. Under the NOTICES tab, click the attachment link to download the PDF copy of Form GST ASMT-10 and any annexures.

Worked example: defending an ITC discrepancy

Consider an actual business scenario for M/s Apex Engineering Solutions, a registered manufacturer in Pune. For the financial year 2024-25, the proper officer issued Form GST ASMT-10 pointing out an alleged excess ITC claim of ₹1,62,000 in GSTR-3B compared to GSTR-2B.

Upon internal verification and invoice-level reconciliation, the accounts team discovered the discrepancy consisted of three distinct components:

ParameterIn disputeActual findingsLegal position
Supplier delayed filing ₹90,000 Supplier filed GSTR-1 on 15 April 2025 instead of 11 March 2025 Reflected in GSTR-2B of April 2025; Section 16(2)(aa) satisfied
Capital goods credit ₹54,000 Machinery purchase invoice omitted in vendor GSTR-1, amended in GSTR-1A Valid tax invoice held, full payment verified via bank statement
Inadvertent clerical claim ₹18,000 Personal car repair bill mistakenly coded to factory maintenance Blocked under Section 17(5)(ab); voluntarily reversed via DRC-03

Instead of submitting a vague narrative, M/s Apex drafted Form GST ASMT-11 conceding ₹18,000 with applicable interest under Section 50(3), and providing clear mathematical reconciliation for the remaining ₹1,44,000.

Complete ASMT-11 reply format to copy and adapt

When drafting your reply on the GST portal, prepare your narrative in a professional, structured document. Upload this document as an attachment (PDF up to 5 MB) while entering a concise summary in the portal description box.

BEFORE THE PROPER OFFICER / SUPERINTENDENT OF CENTRAL TAX RANGE-II, DIVISION-IV, CGST COMMISSIONERATE, PUNE Reference Number: ZA2710260012345 Date of Notice: 20 September 2026 IN THE MATTER OF: M/s Apex Engineering Solutions GSTIN: 27AABCA1234F1Z5 Financial Year: 2024-25 SUBJECT: REPLY TO NOTICE IN FORM GST ASMT-10 ISSUED UNDER SECTION 61 READ WITH RULE 99 OF CGST RULES, 2017 Respected Sir / Madam, We write with reference to your notice in Form GST ASMT-10 dated 20 September 2026, pointing out an apparent discrepancy of Input Tax Credit (ITC) amounting to Rs 1,62,000 between Form GSTR-3B and Form GSTR-2B for the financial year 2024-25. In accordance with Rule 99(2) of the CGST Rules, 2017, we respectfully submit our itemized explanation and reconciliation statement below: 1. BRIEF BACKGROUND OF THE TAXPAYER: The Taxpayer is engaged in the manufacturing of precision industrial valves, holding active GST registration. The Taxpayer has been regular and compliant in filing monthly returns in Form GSTR-1 and Form GSTR-3B within the statutory due dates. 2. POINT-BY-POINT RECONCILIATION AND DEFENSE: Discrepancy Parameter: Excess ITC claimed in GSTR-3B over GSTR-2B (Rs 1,62,000). (a) Timing difference regarding supplier filing (Rs 90,000): Out of the alleged excess, an amount of Rs 90,000 pertains to three tax invoices issued by M/s Steel Kraft Alloys (GSTIN: 27AABCS9876E1Z2). The Taxpayer received the goods in March 2025 and availed ITC in March 2025 GSTR-3B. The supplier filed GSTR-1 for March 2025 after the due date, on 15 April 2025. Consequently, these invoices auto-populated in Form GSTR-2B for April 2025 rather than March 2025. The Taxpayer is in lawful possession of genuine tax invoices, proof of receipt of goods, and bank payment records. A complete invoice-level statement along with GSTR-2B extract of April 2025 is annexed as Annexure-A. (b) Upward amendment by supplier in Form GSTR-1A (Rs 54,000): An amount of Rs 54,000 relates to Invoice No. EXP/24-25/112 dated 10 February 2025 from M/s Precise Tools Pvt Ltd (GSTIN: 27AABCP5432G1Z8). The supplier initially omitted this invoice in GSTR-1 but subsequently reported it through Form GSTR-1A prior to filing GSTR-3B. The corresponding tax has been discharged by the supplier to the Government. Copies of the invoice, bank payment advice, and supplier declaration are enclosed as Annexure-B. (c) Voluntary reversal of inadvertent claim (Rs 18,000): An ITC of Rs 18,000 on repair of a passenger vehicle was inadvertently entered in Table 4(A)(5) instead of being treated as ineligible under Section 17(5)(ab). Upon receipt of the scrutiny notice, the Taxpayer immediately accepted this discrepancy and deposited the tax of Rs 18,000 along with applicable interest of Rs 1,480 calculated under Section 50(3) at 18 percent per annum. Payment has been made through Form GST DRC-03 vide ARN AD2710260045678 dated 05 October 2026. A copy of Form GST DRC-03 and bank receipt is enclosed as Annexure-C. 3. PRAYER: In view of the detailed factual submissions, reconciliation statements, and tax payment made, we respectfully pray that: (a) The explanation submitted in respect of Rs 1,44,000 be found satisfactory; (b) The voluntary payment of Rs 18,000 along with interest be taken on record; (c) The scrutiny proceedings initiated vide Form GST ASMT-10 be closed by issuing an order in Form GST ASMT-12 under Rule 99(3) of the CGST Rules, 2017. We request your good office to grant us an opportunity of personal hearing before taking any adverse view. Yours faithfully, For M/s Apex Engineering Solutions Authorized Signatory Enclosures: As above

Common mistakes accountants make when replying to ASMT-10

A poorly drafted reply often leads the proper officer to reject Form ASMT-11 and issue a show cause notice. Avoid these common blunders:

Submitting generic replies: Writing vague statements such as "All returns were filed correctly according to books" without invoice numbers, dates, and mathematical tables guarantees rejection.

1. Ignoring the thirty-day statutory window: If your reconciliation takes time, file an interim letter on the portal requesting a fifteen-day extension under Rule 99(1). Do not let thirty days lapse in silence.

2. Not paying interest on accepted errors: If you accept that an invoice was claimed twice or was ineligible under Section 17(5), reversing only the tax principal is insufficient. Calculate interest at 18 percent per annum from the date of return filing to the date of payment and attach the DRC-03 receipt.

3. Overlooking circular provisions: For past years, check applicable administrative circulars (such as Circular 183/15/2022-GST for FY 2017-18 and 2018-19, or Circular 193/05/2023-GST for later periods) that allow CA certificates or supplier confirmations to validate bona fide discrepancies.

4. Failing to track automated intimations: Taxpayers receiving system-generated mismatch notices in Form GST DRC-01C often ignore them, which triggers manual Section 61 scrutiny in Form ASMT-10 in subsequent months. Understanding the full GSTR-2B reconciliation timeline 14th to 20th helps prevent these mismatches before filing.

Step-by-step: how to file Form GST ASMT-11 online

Once your reply document, reconciliation tables, and DRC-03 challans are ready, follow these portal steps to file Form GST ASMT-11:

  1. Go to Services → User Services → View Additional Notices and Orders.
  2. Click View against the Scrutiny notice reference number.
  3. Under the REPLIES tab, click Add Reply.
  4. Select the reply option: Accepted, Partially Accepted, or Not Accepted.
  5. If payment was made, enter the Challan ARN of Form GST DRC-03. The system verifies the payment details.
  6. In the explanation text box, type a concise summary of your reply.
  7. Attach your detailed reply document and annexures using the Choose File button (PDF format).
  8. Check the declaration box, select the Authorized Signatory, and submit using DSC (for companies and LLPs) or EVC (for proprietorships).

After submission, monitor the ORDERS tab. When the officer verifies your reply, they issue Form GST ASMT-12, concluding the scrutiny.

Related guides

Frequently asked questions

What is the timeline to reply to a Form GST ASMT-10 notice?

Under Rule 99(1) of the CGST Rules, you must reply within thirty days from the date of service of the notice, or within such further period as the proper officer may permit upon request.

Which form is used to file a reply to Form GST ASMT-10?

Under Rule 99(2) of the CGST Rules, the taxpayer must furnish their explanation or payment intimation in Form GST ASMT-11 on the GST portal.

What order does the tax officer issue if the ASMT-11 explanation is accepted?

Under Rule 99(3) of the CGST Rules, when the proper officer finds the explanation furnished in Form GST ASMT-11 acceptable, an order dropping further proceedings is issued in Form GST ASMT-12.

What happens if no reply is filed to Form GST ASMT-10?

Under Section 61(3) of the CGST Act, if no satisfactory explanation is furnished within thirty days or permitted extension, the officer can initiate audit under Section 65, special audit under Section 66, inspection under Section 67, or proceed to issue a demand notice under Section 73, Section 74, or Section 74A.

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Last checked: 14 October 2026. Sources: Section 61, CGST Act, Rule 99, CGST Rules, GSTN Returns User Guide.