ASMT-10 reply for GSTR-9 Table 8D mismatch: format and legal defence

A discrepancy notice in Form GST ASMT-10 for a negative Table 8D in Form GSTR-9 alleges that you claimed excess input tax credit compared to auto-populated figures. You can defend this notice successfully by submitting a point-by-point reply in Form GST ASMT-11 within thirty days, supported by an invoice-level reconciliation showing supplier filing cut-offs, subsequent period reporting, and statutory compliance under Section 16(2). When your reconciliation proves the genuine receipt of goods and tax payment by suppliers, the proper officer must drop the proceedings in Form GST ASMT-12 without issuing a demand order.

Receiving a scrutiny notice in Form GST ASMT-10 causes immediate anxiety for finance teams and tax practitioners. In our practice assisting businesses through departmental return scrutinies, tax officers frequently review the annual return in Form GSTR-9, observe a negative balance in Table 8D, and issue an intimation alleging that the business has wrongly availed input tax credit. To protect your business against arbitrary demands and interest penalties, you need to understand the statutory mechanics of scrutiny under Section 61 of the CGST Act and submit a detailed factual defence in Form GST ASMT-11.

Why Table 8D turns negative in Form GSTR-9

Form GSTR-9 Table 8 establishes a comparative check between the credit communicated by the GST portal and the credit claimed by the taxpayer in Form GSTR-3B. The calculation follows a strict statutory formula defined in the instructions to Form GSTR-9:

Table 8D = Table 8A - (Table 8B + Table 8C)

In this equation, Table 8A represents inward credit auto-populated from supplier returns. Up to financial year 2022-23, Table 8A drew figures from Form GSTR-2A. From financial year 2023-24 onwards, the GSTN GSTR-9 user manual confirms that Table 8A is auto-filled directly from Form GSTR-2B. Table 8B captures eligible credit availed during the financial year via Form GSTR-3B, auto-drawn from Table 6B of GSTR-9. Table 8C records credit on inward supplies received during the financial year but claimed in the subsequent financial year up to the statutory deadline.

When the sum of Table 8B and Table 8C exceeds the amount auto-populated in Table 8A, Table 8D displays a negative value. Proper officers conducting scrutiny under Rule 99 of the CGST Rules routinely treat any negative balance as prima facie evidence of excess, inadmissible credit.

Common mistake: Paying the alleged negative Table 8D difference through Form GST DRC-03 immediately upon receiving Form GST ASMT-10 without verifying invoice dates and supplier filing patterns. A negative Table 8D is an accounting reconciliation gap, not an automatic confirmation of ineligible credit.

Statutory scrutiny framework: Section 61, Rule 99, and CBIC guidelines

Scrutiny of returns is governed by Section 61 of the CGST Act read with Rule 99 of the CGST Rules. Under Section 61(1), the proper officer scrutinizes the return and related particulars to verify correctness and informs the taxpayer of discrepancies noticed, seeking an explanation.

Under Rule 99(1), the proper officer serves this discrepancy intimation in Form GST ASMT-10, quantifying the tax, interest, and penalties payable. The registered person has thirty days from the service of the notice to either accept the discrepancy and pay the dues, or furnish an explanation in Form GST ASMT-11 under Rule 99(2).

The Central Board of Indirect Taxes and Customs standardized this process through CBIC Instruction No. 02/2022-GST, which sets standard operating procedures for return scrutiny. Paragraph 6.4 of the instruction directs officers to ensure that discrepancies communicated in Form GST ASMT-10 are specific and not vague or general. In addition, paragraph 3.2 cautions field officers that automated portal data represents a snapshot generated at a particular point in time, which undergoes change due to subsequent compliances carried out by the taxpayer or their suppliers. Officers are mandated to consider updated records before creating artificial demands.

If the officer finds your explanation acceptable, Rule 99(3) mandates the issuance of an acceptance order in Form GST ASMT-12, concluding the scrutiny. Only if no reply is furnished or the explanation remains unacceptable may the officer initiate proceedings under Section 65, Section 66, Section 67, or issue a show cause notice under Section 73, Section 74, or Section 74A.

Legal defence grounds for negative Table 8D

When responding to an ASMT-10 notice, your reply must build upon verified legal principles, statutory circulars, and factual documentation. You can raise four primary legal defences:

1. Table 8A reflects a frozen cut-off date

The auto-population of Table 8A stops on a specific cut-off date. Invoices uploaded by your suppliers after the due date of furnishing returns for the subsequent period do not enter Table 8A, even though tax was paid to the government. You are entitled to ITC when you hold a valid tax invoice and the supplier has furnished details in their returns, regardless of portal compilation delays.

2. Supplies declared by vendors in subsequent periods

Suppliers frequently make clerical errors in their monthly Form GSTR-1, such as reporting B2B invoices under B2C, using an incorrect GSTIN, or reporting the supply in a subsequent financial year. Where the supplier later rectifies the invoice in Form GSTR-1 or Form GSTR-1A and deposits tax, your entitlement to credit remains valid under Section 16.

3. Historical protection under Circular No. 183 and Circular No. 193

For discrepancies pertaining to older tax periods, the CBIC issued binding administrative relief. CBIC Circular No. 183/15/2022-GST clarified the treatment of differences between Form GSTR-3B and Form GSTR-2A for financial years 2017-18 and 2018-19. Under paragraph 4.1.1, if the difference exceeds Rs 5,00,000 for a supplier in a financial year, the taxpayer can submit a certificate from a Chartered Accountant or Cost Accountant certifying actual supply and tax payment by the vendor. For differences up to Rs 5,00,000, a direct confirmation certificate from the supplier suffices under paragraph 4.1.2.

This exact verification procedure was extended to the period from 1 April 2019 to 31 December 2021 by CBIC Circular No. 193/05/2023-GST, subject to the progressive rule 36(4) caps of 20%, 10%, and 5% applicable during those respective intervals.

4. Fulfillment of all substantive conditions under Section 16(2)

Under Section 16(2) of the CGST Act, a registered recipient is entitled to ITC when four baseline conditions are satisfied: possession of a tax invoice under clause (a), physical receipt of goods or services under clause (b), payment of tax to the government by the supplier under clause (c), and filing of the return under clause (d). Providing complete proof of invoice receipt, e-way bills, bank payment proofs, and vendor compliance confirms substantive compliance that overrides mere portal mismatches.

Worked example: resolving a negative Table 8D discrepancy

Consider Apex Precision Works Private Limited, an industrial engineering firm in Pune. In its Form GSTR-9 for the financial year, the portal reports a negative Table 8D variance of Rs 1,44,000. The Superintendent of Central Tax serves a notice in Form GST ASMT-10 demanding Rs 1,44,000 in tax plus interest under Section 50.

Form GSTR-9 Table IGST (₹) CGST (₹) SGST (₹) Total ITC (₹)
Table 8A (Inward credit auto-populated) 4,50,000 6,25,000 6,25,000 17,00,000
Table 8B (Credit availed in GSTR-3B) 4,90,000 6,77,000 6,77,000 18,44,000
Table 8C (Inward supplies availed in next FY) 0 0 0 0
Table 8D Difference [8A - (8B + 8C)] -40,000 -52,000 -52,000 -1,44,000

Upon conducting an invoice-level reconciliation, the company identifies the exact transactions causing the negative variance:

Supplier GSTIN & Name Invoice No. & Date Tax Amount (₹) Filing Status & Reason for Variance Finding
27AAACG1111A1Z1 (Delta Steels) INV-882 (12-Feb) 54,000 Supplier filed GSTR-1 after 30 November annual cut-off date Valid ITC, taxes paid by vendor
27AAACH2222B1Z2 (Omega Tools) OT-409 (28-Mar) 90,000 Supplier mistakenly reported in GSTR-1 as B2C, rectified in next FY CA Certificate obtained per Cir 183/193
Total Reconciled Difference 2 Invoices 1,44,000 Full reconciliation established with official proof Zero liability

By compiling the vendor filing proofs and CA verification certificate, Apex Precision Works reconciles 100% of the negative variance and drafts its response in Form GST ASMT-11.

Complete reply format for Form GST ASMT-11

When drafting your reply, use clear legal terminology, refer to the notice reference number, cite statutory provisions, and enclose structured annexures. Copy and adapt the following formal template:

To, The Superintendent of Central Tax / Proper Officer, Range-II, Division-IV, GST Commissionerate, Pune, Maharashtra. Subject: Reply in Form GST ASMT-11 to Scrutiny Notice in Form GST ASMT-10 bearing Reference No. ZA2710260012345 dated 05 October 2026. Respected Sir/Madam, 1. Preliminary Submission: We refer to the scrutiny notice in Form GST ASMT-10 issued under Section 61 of the Central Goods and Services Tax Act, 2017 read with Rule 99 of the Central Goods and Services Tax Rules, 2017. The said notice alleges a discrepancy of input tax credit amounting to Rs 1,44,000 on account of negative variance in Table 8D of Form GSTR-9 for Financial Year 2022-23. 2. Factual Submissions and Reasons for Discrepancy: We submit that the alleged discrepancy between Table 8A and Table 8B of Form GSTR-9 arises purely due to reporting and timing differences on the common portal, and does not represent any inadmissible or excess credit. The registered person has complied with all conditions stipulated under Section 16(2) of the CGST Act: (a) Delayed Filing by Supplier (Rs 54,000): Invoice No. INV-882 dated 12 February 2023 issued by M/s Delta Steels (GSTIN: 27AAACG1111A1Z1) was reported by the supplier in Form GSTR-1 after the portal cut-off date for Table 8A auto-population. The supplier has duly filed Form GSTR-3B and discharged the output tax. Proof of GSTR-1 filing and tax invoice is enclosed as Annexure A. (b) Typographical Reporting Error by Supplier Rectified Subsequently (Rs 90,000): Invoice No. OT-409 dated 28 March 2023 issued by M/s Omega Tools (GSTIN: 27AAACH2222B1Z2) was inadvertently reported by the supplier under B2C supplies in their initial GSTR-1. The supplier rectified this error in the subsequent return period and discharged full tax liability. In terms of CBIC Circular No. 183/15/2022-GST and Circular No. 193/05/2023-GST, we enclose a Chartered Accountant Certificate bearing valid UDIN confirming supply and tax remittance as Annexure B. 3. Legal Grounds and Circular Protection: We place reliance on CBIC Instruction No. 02/2022-GST dated 22 March 2022, which emphasizes that portal data represents a static snapshot and officers must evaluate subsequent supplier compliances before confirming demands. The registered person is in possession of genuine tax invoices, has received the underlying goods in terms of Section 16(2)(b), made full payment through banking channels within 180 days, and filed regular returns under Section 39. 4. Prayer: In light of the factual reconciliation and supporting documents submitted herewith, we respectfully pray that: (i) The explanation submitted in Form GST ASMT-11 be accepted in full. (ii) The proceedings initiated vide Form GST ASMT-10 be dropped. (iii) An order of acceptance be issued in Form GST ASMT-12 in terms of Rule 99(3) of the CGST Rules. (iv) If the proper officer proposes to take any adverse view, a personal hearing be granted before passing any order. Yours faithfully, For Apex Precision Works Private Limited, Authorized Signatory

Structure of the invoice reconciliation annexure

Your ASMT-11 submission should always include a detailed invoice reconciliation annexure. Officers rarely accept broad summaries without document-level backing. Organize your Excel annexure using this verified seven-column layout:

Col 1: Supplier GSTIN & Legal Name Col 2: Document Number & Date Col 3: Taxable Value & GST Claimed Col 4: Bank Payment Date & Reference Col 5: Inward Register vs GSTR-2B Status Col 6: Supplier GSTR-3B ARN & Date Col 7: Specific Defence Category
27AAACG1111A1Z1 (Delta Steels) INV-882 (12-Feb-2023) ₹3,00,000 (GST ₹54,000) 20-Feb-2023 (NEFT/UTR 99281) Reflected in Purchase Register AA270323049182C (18-Apr-2023) Filed by vendor after 8A cut-off date
27AAACH2222B1Z2 (Omega Tools) OT-409 (28-Mar-2023) ₹5,00,000 (GST ₹90,000) 05-Apr-2023 (RTGS/UTR 88102) Reflected in Purchase Register AA270423081923D (20-May-2023) Rectified in subsequent GSTR-1, CA Cert attached

Portal submission steps for Form GST ASMT-11

Follow these portal navigation steps to upload your written submission and annexures:

  1. Log in to the GST portal using your credentials.
  2. Navigate to Services > User Services > View Additional Notices and Orders.
  3. Locate the case reference corresponding to Form GST ASMT-10 and click on View.
  4. Open the notice tab to review the officer's quantified discrepancy and verify all attached documents.
  5. Click on Replies and select Add Reply to open Form GST ASMT-11.
  6. In the explanation field, paste the concise executive summary of your reply.
  7. Under supporting documents, upload your signed reply letter, invoice reconciliation annexure, CA certificates, and bank payment proofs as PDF files. The portal permits attachments up to 5 MB per file.
  8. Select the authorized signatory, tick the declaration checkbox, and file Form GST ASMT-11 using DSC or EVC.

Related guides

Frequently asked questions

Why do tax officers issue Form GST ASMT-10 for GSTR-9 Table 8D mismatch?

A negative value in Table 8D indicates that the input tax credit availed in Form GSTR-3B exceeds the inward credit auto-populated in Table 8A. Tax authorities treat this negative variance as an alleged excess claim of ITC under Section 61 of the CGST Act.

What is the time limit to reply to an ASMT-10 scrutiny notice?

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

Can an ASMT-10 discrepancy notice be raised solely because Table 8A is less than Table 8B?

No. Table 8A is a dynamic or frozen portal view that often excludes invoices filed late by suppliers or reported in subsequent tax periods. When you satisfy Section 16(2) conditions and submit invoice reconciliation annexures, the discrepancy must be dropped in Form GST ASMT-12.

What circulars protect taxpayers for legacy GSTR-2A vs GSTR-3B differences?

CBIC Circular No. 183/15/2022-GST for financial years 2017-18 and 2018-19, and Circular No. 193/05/2023-GST for the period 1 April 2019 to 31 December 2021 allow verification of supplier tax payment through CA or supplier certificates.

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For more guidance on managing scrutiny proceedings and annual return reconciliations, read our guide on ASMT-10 scrutiny notice reply format and our breakdown on GSTR-9 Table 8D lapsed ITC calculation.

Last checked: 18 October 2026. Sources: Section 61 CGST Act, Rule 99 CGST Rules, CBIC Instruction No. 02/2022-GST, CBIC Circular No. 183/15/2022-GST, CBIC Circular No. 193/05/2023-GST.