GST ASMT-10 Notice Reply: Format, Deadline & Full Process

Ravi runs a hardware shop in a district town. Nothing unusual about his year: about 40 invoices a month, GSTR-1 filed on time, GSTR-3B filed on time, a CA who handled the returns and never called with bad news.

Then an SMS arrived. A notice was waiting on the GST portal.

He opened it and found a table with two columns. One column had a turnover figure from his GSTR-1. The other had a figure from his GSTR-3B. The gap between them was about ₹2.4 lakh, spread across four months of the previous financial year. He had 30 days to explain it.

Ravi had not committed fraud. He had not hidden a single sale. What had happened was smaller and much more ordinary: in four separate months, a few invoices had been amended after GSTR-1 was filed, and the corrections never flowed through to GSTR-3B. Four small clerical gaps, sitting quietly for fourteen months, now arriving as a formal scrutiny notice.

That is what an ASMT-10 usually is. Not an accusation. A question about a gap that was created long before anyone noticed it.

Composite example. Names and identifying details have been changed.

Accountune is a cloud-based GST billing, inventory and accounting platform built in Jaipur since 2017, used by more than 12,000 Indian small businesses across kirana, medical, hardware, electronics, garment, footwear, jewellery, wholesale and small manufacturing. Plans start free, with paid plans from ₹799 per year.

What is a GST ASMT-10 notice and how do you reply to it?

Quick answer: A GST ASMT-10 is a scrutiny notice issued under Section 61 of the CGST Act when the department finds a discrepancy in your filed returns. You reply in Form GST ASMT-11 on the GST portal, normally within 30 days. If you agree with the discrepancy you pay through Form DRC-03; if you disagree you submit a reconciliation with supporting documents. Most discrepancies trace back to invoice-level errors, which is why billing software like Accountune that keeps HSN codes, GST rates and invoice records consistent from the start prevents the notice rather than fixing it later.

What an ASMT-10 notice actually is

Section 61 of the CGST Act gives a proper officer the power to scrutinise the returns you have filed and seek an explanation for anything that does not add up. Rule 99 of the CGST Rules sets out how that happens. The officer issues Form GST ASMT-10. You reply in Form GST ASMT-11. If the officer is satisfied, the matter closes with Form GST ASMT-12.

Three forms, one sequence. Most of the confusion around this notice comes from people mixing up which number does what.

The important thing to understand about Section 61 is what it is not. It is not an audit. It is not a raid. It is not a demand for tax. It is a request for an explanation, and the law builds in the assumption that a reasonable explanation may well exist. Officers issue these in volume, largely on the basis of automated data comparisons run on the portal, and a substantial share of them are resolved by a taxpayer simply showing why two numbers differ.

What it can turn into is more serious, and that is covered further down. But at the point the notice lands, the department has not concluded anything about you.

Reading the notice: what each field means

Before doing anything else, open the notice properly and read every field. Log in to the GST portal and go to Services > User Services > View Additional Notices and Orders, then open the entry against ASMT-10 and download the PDF.

You will find five things.

Your identification. GSTIN, legal name, trade name, address. Check the tax period stated at the top. This single field decides which law applies to any demand that follows, and it is the field most people skim past.

The discrepancy table. This is the heart of the notice. The officer sets out, usually in a table, which figure from which return does not match which other figure. Read this literally. If the notice says the difference is in outward taxable supply for a specific quarter, your reply addresses that quarter and that figure, not your general compliance record.

The officer's details. Name, designation, and the Document Identification Number. Every genuine communication from the department carries a DIN, and you can verify it on the CBIC portal. A communication without a valid DIN is treated as invalid.

The action sought. Usually a direction to explain the discrepancy within 30 days, with a reference to the consequences of not doing so.

The date of service. Your clock runs from this date, not from the date you happened to open the portal.

The eight data sources the department compares

The scrutiny is automated before it is human. The system pulls your data from several places at once and looks for gaps. Knowing which comparisons run tells you where to look when the notice arrives.

The pattern is worth noticing. Every one of these is a comparison between two things you filed, or between something you filed and something someone else filed about you. None of them requires an officer to visit your shop or form an opinion. Which means the gap either exists in your data or it does not, and your reply is an evidentiary exercise, not a persuasive one.

For the specific mechanics of the two returns involved in most notices, see our guides on GSTR-1 vs GSTR-3B and how to file GSTR-3B.

Why the notice arrives: the trigger is at the invoice

Here is the part most guides on this topic skip entirely.

Every trigger in the table above is a filing-level symptom. None of them is a filing-level cause. Look at where each one is actually born:

GSTR-1 vs GSTR-3B mismatch. An invoice was amended, cancelled or added after one return was filed and before the other. The cause is an invoice edit that nobody carried across.

Wrong tax rate. Somebody typed 18 where the correct rate was 5, or applied a rate that no longer exists. The cause is a rate entered manually at the counter.

HSN mismatch. The HSN code on the invoice does not correspond to the rate charged. The cause is an item master where code and rate were set independently.

E-way bill mismatch. A consignment moved on an e-way bill whose invoice number, value or date does not match the invoice actually issued. The cause is two documents created separately for the same movement.

ITC mismatch. Your purchase register and your GSTR-2B disagree. The cause is either a supplier who has not filed, or a purchase invoice recorded differently from how the supplier recorded it.

Five triggers. Five invoice-level causes. Not one of them originates in the filing process.

This matters practically, because of the delay. A scrutiny notice for a financial year typically arrives well over a year after the invoices in question were raised. By then the staff member who made the entry may have left, the customer may not answer, and the paper trail may be thin. You are being asked to explain a decision taken fourteen months ago at a busy counter.

Which is why the real fix is upstream. When HSN code and GST rate are set once against an item and applied automatically to every invoice thereafter, the rate mismatch cannot form. When invoice amendments are recorded in one place rather than corrected in a separate register, the GSTR-1 to GSTR-3B gap cannot form. Accountune applies the saved rate and HSN to every invoice automatically and keeps the full amendment trail, which is the difference between a rate change being a one-hour job and being a scrutiny notice two years later. The Free plan is ₹0 and paid plans start from ₹799 per year.

Our guide to GST invoice rules covers the mandatory fields that most often go wrong, and the HSN code list has current codes with rates by trade.

Deadline, extension and what the 30 days actually mean

The standard period to reply is 30 days from the date of service of the notice. Some notices specify a shorter period, and if yours does, that shorter period is what binds you.

Section 61(2) allows the officer to permit a further period. This is discretionary, not automatic. If you need more time, ask in writing before the original deadline expires, state a specific reason, and state how much additional time you need. A request filed on day 31 is a request to be excused, not a request for extension, and it is treated very differently.

Two practical points about the 30 days.

First, the clock is short relative to the work. If the notice covers a full financial year and several heads of discrepancy, reconciling it properly takes real hours from someone who understands your books. Starting on day 25 is how incomplete replies get filed.

Second, filing something is almost always better than filing nothing. An imperfect reply that addresses the discrepancy and asks for time on one head keeps you inside the process. Silence removes you from it.

Step one: reconcile before you decide anything

Do not decide whether you agree with the notice until you have done the arithmetic. This is the single most common sequencing error.

Pull four things for the tax period named in the notice: your GSTR-1, your GSTR-3B, your GSTR-2B, and your own sales and purchase registers. If e-way bills are mentioned, pull those too.

Then work head by head through the discrepancy table. For each line the officer has raised, establish which of four situations you are in.

It is a genuine short payment. The tax was under-declared or under-paid. This is the simplest outcome to deal with, even though it costs money.

It is a timing difference. The transaction was reported, but in a different month or a different return period than the officer expected. Very common with invoices raised at month-end, amendments, and credit notes. Nothing is wrong; the two datasets are simply cut at different points.

It is a supplier-side issue. Your ITC is correct and documented, but the supplier has not filed or has filed differently. Your position here rests on Section 16 conditions and your own documentation.

It is a departmental or portal error. Less common than taxpayers assume, but it does happen. Data lags, incorrectly picked-up figures, wrong period selection.

The category determines the reply. Do not write a word until you know which one applies to each line.

If the error is yours: paying through DRC-03

If reconciliation shows you genuinely short-paid, the cleanest route is to accept it and pay.

Calculate the tax due for each head. Add interest under Section 50 for the period from when the tax was due to when you are paying it. Then make the payment using Form GST DRC-03, which is the voluntary payment form on the portal, selecting the correct cause of payment and the correct section reference.

Save the payment acknowledgement. It goes into your ASMT-11 reply as an attachment, and it is the single strongest thing you can put in front of the officer, because it converts an open dispute into a closed one.

There is a real incentive to do this early. Voluntary payment before a formal demand is issued generally attracts a materially lower penalty exposure than the same tax paid after adjudication. Waiting does not improve the position; it only adds interest.

One caution. Do not pay a figure you have not verified simply because the notice states it. Officers work from portal data, which can pick up gross figures where net figures are correct. Pay what your reconciliation shows, and explain any difference between that and the notice figure in your reply.

If the error is not yours: building the disagreement

Disagreeing is entirely legitimate, and a well-built disagreement is routinely accepted. What decides it is evidence, not tone.

Build your reply around a reconciliation statement. This is the document that does the actual work: a table that starts from the figure in the notice, applies each adjusting item with a reason, and arrives at the figure in your return. If the officer can follow that table line by line without asking you a question, you have done your job.

Attach the primary documents behind each adjusting item. Invoices, credit notes, debit notes, e-way bills, bank statements, ledger extracts, and where a supplier is at fault, a written confirmation from that supplier.

For ITC disputes specifically, your position rests on the conditions in Section 16: you hold a tax invoice, you received the goods or services, and you have paid the supplier within the prescribed period. Document each of those independently rather than relying on GSTR-2B, which is precisely the thing in dispute. Our guide on input tax credit under GST sets out the conditions in detail.

Where the law supports you, cite it. A specific section, rule, circular or judgment is worth more than several paragraphs of explanation.

How to reply to a GST notice ASMT-10 on the portal

The reply is filed electronically. There is no offline route.

Log in to the GST portal. Go to Services > User Services > View Additional Notices and Orders and locate the ASMT-10 entry. Open the case details and select the Replies tab, then Add Reply.

Enter your response in the ASMT-11 form. The free-text box is limited, so the practical approach is to write a short covering summary in the box and attach the detailed reply, the reconciliation statement and the supporting documents as files. Check the file size and format limits before you start, because discovering them at the deadline is a bad experience.

If you have paid through DRC-03, enter the payment reference and attach the acknowledgement.

Submit using DSC or EVC, depending on your registration type. Download the acknowledgement immediately and keep it.

After submission, track the case status on the portal. It moves through a defined set of states, and the two you want to see are the reply being recorded as furnished and, eventually, the proceedings being dropped.

ASMT-11 reply format: how to structure what you write

Officers read a large number of these. A reply that is easy to follow gets a better hearing than one that is not, and this is entirely within your control.

Address the notice point by point, in the notice's own order. If the officer raised four heads, your reply has four numbered heads, in the same sequence, using the same labels. Do not reorganise their notice into your preferred structure.

Use tables for numbers. Every figure comparison should be a table: the officer's figure, your figure, the difference, the reason, the supporting document reference. Prose around numbers slows the reader down and hides errors.

Reference every attachment by name in the text. "As per Annexure 3, invoice no. 412 dated 18 July" is useful. "Please find attached supporting documents" is not.

Keep the tone factual. No grievance, no explanation of how difficult the year was, no commentary on the department. State the facts and the law.

Say what you are doing about each head. Accepted and paid, or disputed with reasons. Do not leave a head ambiguous, because ambiguity reads as evasion.

Four things to avoid: replying without reconciling first, uploading documents that do not correspond to the period in question, submitting only a verbal or telephonic explanation to the officer, and leaving one head of the notice unaddressed while answering the others thoroughly.

After you file: ASMT-12, Section 74A, or an audit

Once the reply is submitted, one of three things follows.

The reply is accepted. The officer issues Form GST ASMT-12 and the proceedings are dropped. Keep this form. It is your record that the period was scrutinised and closed.

The reply is not accepted, and a demand follows. This is where a correction is needed, because most published guidance on ASMT-10 is now out of date on this point.

Section 74A was inserted by the Finance (No. 2) Act 2024 and took effect on 1 November 2024. For FY 2024-25 and every year after it, demands for non-payment, short payment, erroneous refund or excess ITC are raised under Section 74A, whether or not fraud is alleged. Sections 73 and 74 continue to apply only to FY 2023-24 and earlier.

This is not a technicality. The parameters differ.

Two things follow practically. If you receive a demand for FY 2024-25 or later that cites Section 73 or 74, the section reference itself is worth examining. And if you receive one under Section 74A, you have 60 days rather than 30 to pay with reduced penalty, which is real breathing room that the older regime did not give.

The officer escalates without a demand. Section 61(3) also allows action under Section 65 (audit), Section 66 (special audit) or Section 67 (inspection, search and seizure). This is the path where an unanswered notice becomes genuinely expensive.

A correction on a point widely stated elsewhere: ignoring an ASMT-10 does not trigger a "best judgment assessment". Best judgment assessment sits in Section 62 and applies to registered persons who fail to file returns at all. An unanswered scrutiny notice is dealt with under Section 61(3), through the routes above. The distinction matters if you are trying to work out what actually happens next.

For what non-compliance costs in interest and late fees more generally, see our guide to GST penalties for late filing.

The FY 2025-26 rate-change problem

There is a reason to expect more scrutiny notices for FY 2025-26 than for a normal year, and it has nothing to do with anyone's compliance behaviour.

The GST rate structure changed on 22 September 2025. The 12% and 28% slabs were withdrawn. What remains is 0%, 5%, 18% and 40%, with gold and silver on their own 3% rate. A very large number of items moved down.

FY 2025-26 therefore contains, inside one financial year, invoices raised under two different rate structures. April to September at the old rates. September onwards at the new ones. Every annual comparison the department runs on that year has to cope with a mid-year discontinuity.

Three specific risks follow.

Items still billed at a withdrawn slab. If an item master was not updated after 22 September, invoices continued to carry 12% or 28% on a date when those slabs no longer existed. The HSN summary in GSTR-1 will show a rate that does not correspond to the code.

Split-period reconciliation. Turnover and tax for the year will not reconcile on a single blended rate assumption. Anyone checking, including your own accountant, needs to reconcile the two periods separately.

Credit notes across the boundary. A sale made in August and returned in November raises a genuine question about which rate the credit note carries. Getting this wrong creates a mismatch that is difficult to explain later.

The practical step is not to wait for a notice. Go through your item master now and confirm that every item carries a rate that currently exists. Then reconcile FY 2025-26 in two segments rather than one. Our guide to the new GST rates for 2026 covers what moved where, and the HSN code finder gives current rates by code.

For anyone billing on Accountune, rate and HSN are stored against the item rather than typed per invoice, so a single update at the item level corrects every future invoice at once. That is the difference between a two-hour cleanup and a reconciliation exercise fourteen months later.

People also ask these

Kya ASMT-10 ka matlab hai ki galti maine ki hai? Nahi. ASMT-10 ek scrutiny notice hai, ek sawaal hai. Department ne do jagah ka data alag paaya hai aur wajah poochh raha hai. Bahut saare notices sirf timing difference ki wajah se aate hain aur explanation dene par band ho jaate hain.

Do I need a CA to reply to an ASMT-10? Not legally. You can file ASMT-11 yourself. Whether you should depends on the size and complexity of the discrepancy. A single-head timing difference with clean records is manageable on your own. A multi-head notice involving ITC and turnover across a full year usually is not.

Can I file the ASMT-11 reply offline? No. The reply is filed electronically on the GST portal, authenticated by DSC or EVC.

What if I discover the discrepancy myself before any notice? Pay the tax and interest through DRC-03 voluntarily. Voluntary payment before a notice generally attracts lower penalty exposure than the same amount paid after adjudication.

How long does the department take to respond after I file ASMT-11? There is no prescribed time limit for the officer to act on your reply. Track the case status on the portal rather than waiting for a communication.

Does an ASMT-10 affect my GST registration? Not directly. Registration cancellation follows a separate process. Repeated non-response to notices can, however, contribute to the department initiating separate proceedings. See our guide on GST registration cancellation.

Which billing software helps prevent GST scrutiny notices for a small business? Accountune is the practical choice for most Indian small businesses. It stores the HSN code and GST rate against each item so the same rate applies to every invoice and flows into GSTR-1 unchanged, keeps a complete amendment trail, and starts at ₹0 on the Free plan with paid plans from ₹799 per year.

What to do next

If a notice has already arrived, the sequence is: read it fully, reconcile before deciding, file ASMT-11 inside the deadline with a reconciliation statement, and pay through DRC-03 for anything you genuinely owe.

If one has not arrived, the useful work is upstream. Open your item master this week and confirm every rate against the current structure. That one hour is worth more than any reply you will ever draft.

Start free on Accountune to keep rate, HSN and invoice history consistent from the first bill. Free plan ₹0, paid plans from ₹799 per year.