ASMT-10 scrutiny notice: how to reply within 30 days

A notice titled FORM GST ASMT-10 has landed on your GST portal. It says the department found a mismatch in your returns. It is not a demand, not a penalty and not a show cause notice. It is a question. How you answer it decides whether the matter ends quietly or turns into a formal demand.

This guide is for a company or business that has just received an ASMT-10. It covers what the notice is, the clock you are on, the exact steps for the reply, and the mistakes that make things worse.

What an ASMT-10 notice actually is

Section 61 of the CGST Act, 2017 lets the "proper officer" (the GST officer in charge of your case) scrutinise your return and related particulars "to verify the correctness of the return". If the officer finds discrepancies, the officer informs you "in such manner as may be prescribed" and seeks your explanation (s.61(1), CGST Act 2017).

The prescribed manner is rule 99 of the CGST Rules, 2017. Where a return is selected for scrutiny and the officer sees a discrepancy, the officer issues a notice in FORM GST ASMT-10 telling you about it and asking for your explanation. The rule adds that, where possible, the notice should quantify "the amount of tax, interest and any other amount payable in relation to such discrepancy" (rule 99(1), CGST Rules 2017).

So the notice has three parts to read carefully: what the discrepancy is, which return periods it covers, and whether an amount has been quantified.

How your return gets selected

For returns from FY 2019-20 onwards, selection is risk-based, by the Directorate General of Analytics and Risk Management (Instruction No. 02/2023-GST, 26 May 2023, paras 2 and 3.1). The officer works from data already on record, and "there should normally not be any need for seeking documents/ records from the registered persons before issuance of FORM GST ASMT-10" (para 5.3). The instruction also expects discrepancies to be specific, not "vague or general", with worksheets uploaded (para 5.4). If your notice is vague or has no worksheet, say so in your reply.

The clock: 30 days

Rule 99(1) says the officer asks for your explanation "within such time, not exceeding thirty days from the date of service of the notice or such further period as may be permitted by him". Section 61(3) uses similar words for the other side of the clock: no satisfactory explanation "within a period of thirty days of being informed by the proper officer or such further period as may be permitted by him".

Count from service of the notice, not from the day you first read it.
An extension depends on the officer permitting it. Ask in writing before the 30 days run out and keep proof.
The notice may state a shorter period. Read it.

CBIC's own internal timeline matches this. It expects the reply in FORM GST ASMT-11 "within a period of thirty days of being informed by the proper officer in FORM GST ASMT-10 or such further period as may be permitted by the proper officer" (Instruction No. 02/2023-GST, para 6.1, item (iv)).

What you can do: two routes

Rule 99(2) gives you two routes. You may:

Accept the discrepancy, pay the tax, interest and any other amount arising from it, and inform the officer; or
Furnish an explanation for the discrepancy.

Either way the reply goes in FORM GST ASMT-11 to the proper officer (rule 99(2), CGST Rules 2017). CBIC's instruction confirms that this is filed "through the common portal" (Instruction No. 02/2023-GST, para 5.6).

Route 1: the discrepancy is real

Sometimes your reconciliation shows the officer is right: output tax was short-reported in GSTR-3B, or input tax credit was claimed that you were not entitled to. In that case:

Work out the tax difference for each period in the notice.
Work out interest under section 50 of the CGST Act for the period the tax stayed unpaid. Section 50(1) makes interest payable "on his own" by the person who fails to pay tax in time, at a rate notified by the Government, not exceeding eighteen per cent. Check the currently notified rate on the GST portal or the CBIC site before computing, as the rate is set by notification.
Pay the tax and interest, and, if you are accepting the discrepancy, also correct it in your return for the month in which you accept it. Section 61(3) specifically refers to a person who, "after accepting the discrepancies, fails to take the corrective measure in his return for the month in which the discrepancy is accepted". Paying without correcting the return leaves you open to further action.
File ASMT-11 stating that you accept the discrepancy and giving payment details.

CBIC's instruction notes that a payment already made through FORM GST DRC-03 after filing the return may be taken into account when the officer communicates discrepancies (Instruction No. 02/2023-GST, para 5.4). So if you have already paid the difference voluntarily, say so in your reply and attach the DRC-03 acknowledgement.

Route 2: the discrepancy is wrong or explainable

Many notices come from data mismatches, not real short payment, for example timing differences between returns, later amendments or credit notes. Your own facts decide.

For an explanation reply:

Take the notice paragraph by paragraph. Answer each parameter separately, using the same headings the notice uses.
Build a short reconciliation, for example a table that ties the figure in the notice to the figure in your books and returns, with the difference explained.
Attach evidence: invoices, credit notes, e-way bills, amended-return references, bank proof of payment, whatever proves the point.
State clearly at the end what you accept, what you dispute and why.
File it in ASMT-11 within the time allowed.

Keep the reply factual and attach evidence.

Step by step on the portal

The exact screen names change, so confirm them on the portal. The general sequence is:

Log in and open the notice. The ASMT-10 reaches you on the common portal; CBIC says the system communicates it to you and no separate manual notice is needed (Instruction No. 02/2023-GST, para 5.4). Also check your registered email for the intimation.
Download the notice and its annexures (the worksheet showing the discrepancy).
Note the service date and reply deadline in your compliance calendar.
Reconcile the periods in the notice against your books, GSTR-1, GSTR-3B, GSTR-2B and, where relevant, e-invoice and e-way bill data.
Decide the route: pay and accept, explain, or a mix of both for different paragraphs.
If you owe money, pay it through the portal and keep the challan or acknowledgement.
File FORM GST ASMT-11 through the portal with your explanation, payment details and attachments.
Track the outcome. If the officer is satisfied, you will be informed in FORM GST ASMT-12 (rule 99(3), CGST Rules 2017) and, under section 61(2), "no further action shall be taken in this regard".

What happens after you reply

If the officer accepts your explanation or your payment, rule 99(3) requires the officer to inform you in FORM GST ASMT-12, and section 61(2) closes the matter for that notice. CBIC's internal timeline expects that order "within thirty days from receipt of reply" (Instruction No. 02/2023-GST, para 6.1, item (v)). That is an instruction to its officers, not a time limit you can enforce in court, so treat it as a guide only.

If the officer is not satisfied, section 61(3) lets the officer "initiate appropriate action including those under section 65 or section 66 or section 67, or proceed to determine the tax and other dues under section 73 or section 74 or section 74A". In plain words, that can mean an audit (s.65), a special audit (s.66), an inspection or search (s.67), or a formal show cause notice for demand.

CBIC's instruction expects action to determine tax and dues within thirty days of an unsatisfactory ASMT-11, or within fifteen days after the thirty-day period where no reply was filed (Instruction No. 02/2023-GST, para 6.1). The instruction speaks only of sections 73 and 74, because it pre-dates section 74A.

Again, these are internal targets. The point for you is that silence does not make the notice go away. It speeds up the next stage.

If it becomes a show cause notice

A demand notice under section 73, section 74 or section 74A is a separate document, issued after scrutiny. Which section applies depends on the financial year. Sections 73 and 74 apply to tax for the period up to FY 2023-24; section 73 is for cases other than fraud, wilful misstatement or suppression of facts, and section 74 is for those cases. Section 73 applies to tax "pertaining to the period upto Financial Year 2023-24" (s.73(12), CGST Act 2017), while section 74A, inserted by the Finance (No. 2) Act, 2024 with effect from 1 November 2024, covers "Financial Year 2024-25 onwards" (s.74A, CGST Act 2017).

Time limits differ too: the order under section 73(10) is due within three years from the due date of the annual return, while a section 74A notice is due within forty-two months from that date (s.74A(2)).

Paying early can reduce the cost. Under section 73(8), if tax and interest are paid within thirty days of the show cause notice, no penalty is payable and proceedings on that notice are deemed concluded. Under section 74A(8)(ii) the window for the same relief is sixty days where the reason is other than fraud or wilful misstatement. Section 73(5) and section 74A(8)(i) also let you pay before the notice is served and inform the officer in writing, in which case the officer "shall not serve any notice" for the tax so paid. Which of these options fits you depends on the year and the facts, so get this checked before paying.

A formal show cause notice needs its own, separate reply.

What not to do

Do not ignore the notice because it says it is only a scrutiny. Silence leaves the officer free to move to section 73, 74 or 74A, or to audit, as section 61(3) allows.
Do not wait for the last day. The portal, the payment and your own reconciliation can all go wrong. File early and keep the acknowledgement.
Do not pay blindly. An ASMT-10 quantification is the officer's working. If it is wrong, paying it and accepting it in ASMT-11 puts the error on your record.
Do not accept and then forget the return. If you accept a discrepancy, correct it in the return for the month of acceptance, as section 61(3) expects.
Do not send a reply with no evidence. A bare statement that "the figures are correct" gives the officer nothing to accept under rule 99(3).
Do not miss the extension request. An extension exists only if the officer permits it (rule 99(1)); ask in writing and in time.

What to do now

Next step: download the ASMT-10 and its worksheet from the portal today, and reconcile each paragraph to your books and returns (rule 99(1), CGST Rules 2017).
Deadline: the time stated in the notice, which cannot exceed thirty days from service unless the officer permits more (rule 99(1), CGST Rules 2017; s.61(3), CGST Act 2017). Ask for any extension before that date.
Consequence of not replying: the officer may start audit, inspection or search, or determine the tax and dues under section 73, 74 or 74A, with interest under section 50 (s.61(3), CGST Act 2017).

Have a CA review your facts before you act or file.

FAQs

Is an ASMT-10 notice the same as a show cause notice?

No. ASMT-10 is the scrutiny stage under section 61 and rule 99. It informs you of a discrepancy and asks for your explanation. A show cause notice for demand is issued under section 73, 74 or 74A, and the section 61(3) text shows those sections come into play only if no satisfactory explanation is given or the discrepancy is accepted but not corrected.

Can I get more than 30 days?

The rule caps the officer's time at thirty days from service "or such further period as may be permitted by him" (rule 99(1), CGST Rules 2017). So an extension is the officer's call. Request it in writing before the deadline.

Which form do I use to reply?

FORM GST ASMT-11, filed on the common portal (rule 99(2), CGST Rules 2017). It covers both accepting the discrepancy with payment and giving an explanation.

I already paid the difference through DRC-03. Do I still need to reply?

Yes. Reply in ASMT-11 and refer to the DRC-03 payment with proof. CBIC's instruction says payments already made through DRC-03 may be taken into account in the notice (Instruction No. 02/2023-GST, para 5.4), but your reply is what puts your position on record.

What if the officer accepts my reply?

The officer informs you in FORM GST ASMT-12 (rule 99(3), CGST Rules 2017) and, under section 61(2), no further action is taken in that regard.

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