How to Reply to ASMT-10 GST Notice — Time Limit, Format & Sample

What is ASMT-10 in GST

Under Section 61, the proper officer may scrutinise the returns furnished by a registered person and related particulars. Where discrepancies are noticed, the officer issues a notice in Form GST ASMT-10 informing the taxpayer of the discrepancies and seeking an explanation.

ASMT-10 is not a demand notice by itself. It is the first stage — if the reply in ASMT-11 is accepted, the officer drops the proceedings by an intimation in Form GST ASMT-12. If not accepted, the officer may proceed under Sections 65, 66, 67 or issue a Show Cause Notice under Section 73 or 74.

How the ASMT-11 reply should be structured

A defensible reply addresses each discrepancy separately, with the taxpayer's stance, the statutory basis, and documentary evidence.

• Introduction identifying the taxpayer, GSTIN and the notice being replied to
• Discrepancy-wise reply — agree, partially agree, or disagree, with reasons
• Reconciliation of GSTR-1 vs GSTR-3B vs GSTR-2A/2B vs books, where relevant
• Reliance on Sections, Rules, Circulars and case law
• Payment details in DRC-03 (if any) — tax, interest, penalty, late fee separately
• Verification and authorised signatory block

Common grounds relied on in ASMT-11

Beyond the numerical reconciliation, several procedural and substantive grounds are commonly relied on — mismatch is a valid trigger for enquiry, not for demand; the officer must consider the reply on merits; and reliance on GSTR-2A/2B for restricting ITC prior to 09.10.2019 is not sustainable in law.

A defensible reply combines procedural safeguards with grounds on merits. Use this checklist as the skeleton of every ASMT-10 reply.

1. 1. Proper officer & jurisdiction
   Verify that the officer issuing the ASMT-10 has monetary and territorial jurisdiction under the CBIC circulars. A notice issued without jurisdiction is void.
2. 2. Statutory time limits
   Check whether the ASMT-10 is within limitation under Section 73/74/74A (or the applicable rule). A time-barred notice is liable to be dropped as a threshold ground.
3. 3. Natural justice
   Confirm that the SCN is not vague, that relied-upon documents are enclosed, and that opportunity of personal hearing under Section 75(4) has been granted.
4. 4. Statement of facts
   A clean, chronological narrative — parties, GSTIN, period, returns, audit / scrutiny trigger, prior correspondence and payments made.
5. 5. Grounds on law and merits
   Discrepancy-wise reply — agreed, partly agreed, or disagreed, with the section, rule, circular and case law relied on. Reconciliations attached as annexures.
6. 6. Correct form & payments
   File the reply in the prescribed form on the GST portal. Any admitted tax is paid through DRC-03 with interest, penalty and late fee shown separately.
7. 7. Prayer & hearing request
   End the reply with a specific prayer (drop proceedings / grant hearing / accept payment) and expressly request a personal hearing.

Frequently asked questions

Related notices & orders