The Ten Records an Officer Asks For First

Ten Records an Officer explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.

An audit under s.65 begins with a notice in ADT-01 and a list. The list is remarkably consistent, and it is not the general ledger.

The opening request tests whether the statutory registers exist, not whether the numbers are right. Ten records answer that: the stock account, the monthly production account, the document register, the advances account, the storage address list, the contract-wise accounts, the ITC reversal working, the e-way bill register, the edit log, and the reconciliation between books, returns and the financial statements.

1. The stock account — Rule 56(2)

Opening balance, receipts, supplies, goods lost, stolen, destroyed, written off or given away, and closing balance, including raw materials, finished goods, scrap and wastage.

What it tests: whether s.17(5)(h) reversals were made, and whether losses were normal or abnormal.

2. Monthly production accounts — Rule 56(12)

Quantitative inputs used and goods manufactured, including waste and by-products.

What it tests: the input-output ratio, and whether unaccounted output exists. Monthly production accounts →

3. The document register — Rule 56(4)

Tax payable including under s.9(3) and 9(4), tax collected and paid, input tax, credit claimed, and a register of tax invoices, credit notes, debit notes and delivery challans issued or received by tax period.

What it tests: completeness. Gaps in the invoice series, unrecorded credit notes, delivery challans without a corresponding return.

4. The advances account — Rule 56(3)

Advances received, paid and adjustments.

What it tests: whether service advances were taxed on receipt, and whether receipt and refund vouchers were issued. Receipt, payment and refund vouchers →

5. The storage address list — Rule 56(5)(c)

Every premises where goods are stored, including goods in transit, with the stock held at each.

What it tests: whether every location is declared. Undeclared storage engages Rule 56(6) — tax on the goods as if supplied. Rule 56(6) →

6. Contract-wise accounts — Rule 56(14)

For a works contractor, per contract: client, goods and services received, goods and services utilised, payments received, suppliers.

What it tests: site stock reconciliation and invoicing timeline compliance. Works contract accounts →

7. The ITC reversal working — Rules 42 and 43

The T, T1, T2, T3, C1, T4, C2, D1, D2, C3 computation, monthly and the annual true-up; the Tc, Tm, Tr, Te working for capital goods.

What it tests: whether blocked credit was removed as T3 before apportionment, whether exempt turnover included the s.17(3) additions, and whether the annual recomputation was done. Rule 42 worked →

8. The e-way bill register

Bills generated, cancelled and expired, reconciled to invoices and to delivery challans.

What it tests: movements without documents, and invoices without corresponding movement.

9. The edit log — Rule 56(8)

For electronic records, a log of every entry edited or deleted.

What it tests: whether records were altered, and whether entries were back-dated. Rule 56(8): audit trail →

10. The three-way reconciliation

Books to GSTR-1 to GSTR-3B to GSTR-9 to GSTR-9C, and to the audited financial statements.

What it tests: everything else. This is where a difference becomes a finding.

What "cannot produce" signals

An officer reads the absence of a register as information.

No stock account → losses and write-offs were not tracked, so s.17(5)(h) reversals were probably not made.

No production account → the input-output ratio cannot be defended, so process loss is exposed to s.35(6).

No storage list → undeclared locations are likely.

No edit log → records may have been altered, and the presumption is not favourable.

No annual Rule 42 true-up → a shortfall with interest from 1 April of the succeeding year.

The pattern matters more than any single gap. A business with all ten in place, even with errors in them, is treated differently from one with four.

Preparing before the notice

The fifteen working days notice under s.65(3) is not enough time to build these records. They have to exist already.

A realistic annual exercise:

• reconstruct each of the ten as at year end and confirm it can be produced;
• test extraction of the electronic records in a readable format, with the file details, passwords and code explanations Rule 57(3) requires;
• reconcile the storage address list to the physical footprint;
• complete the Rule 42 and 43 annual true-up before 30 November;
• document the judgment calls — normal loss norms, plant and machinery splits, capitalisation decisions, classification positions — contemporaneously, not on receipt of ADT-01;
• retain everything for the s.36 period — seventy-two months from the annual return due date, extended while any proceeding runs. Document retention →

Key takeaways

• The opening request tests whether the statutory registers exist, not the arithmetic.
• The stock account and production account carry the s.17(5)(h) and s.35(6) exposure.
• The storage address list is the answer to Rule 56(6).
• The edit log is the answer to an allegation of altered records.
• The Rule 42 and 43 annual true-up must be complete before 30 November.
• Fifteen working days notice is not enough time to build any of this.

Read next

• Rule 56: The Accounts Every Registered Person Must Keep
• GST Audit Checklist: What Officers Check
• Rule 42 Worked: The Monthly Formula and Annual True-Up
• Document Retention: Section 36 and Electronic Records

Disclaimer: Positions stated as on 5 September 2026, based on the CGST Act and Rules as amended to 31 March 2026 (ICAI Bare Law, 12th edition).