Section 61 Scrutiny: ASMT-10 and the Thirty-Day Reply

Section 61 Scrutiny 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.

Scrutiny is the lightest of the department's examination powers, and the one most often mishandled — because it looks informal and is not.

Section 61(1): the proper officer may scrutinise the return and related particulars to verify their correctness, and inform the registered person of the discrepancies noticed, if any, and seek his explanation. Rule 99(1): the discrepancy is communicated in FORM GST ASMT-10, informing the person of the discrepancy and seeking his explanation within such time, not exceeding thirty days from being informed, or such further period as may be permitted, and quantifying the amount of tax, interest and any other amount payable in relation to the discrepancy, where possible.

The three outcomes

Explanation accepted — s.61(2). Where the explanation is found acceptable, the registered person shall be informed accordingly and no further action shall be taken in that regard. Rule 99(3): the acceptance is communicated in FORM GST ASMT-12.

No explanation, or explanation not accepted — s.61(3). Where no satisfactory explanation is furnished within thirty days of being informed, or such further period as permitted, or where the person fails to take corrective measures in his return for the month in which the discrepancy is accepted, the proper officer may initiate appropriate action including under s.65 (audit), s.66 (special audit), s.67 (inspection, search and seizure), or proceed to determine the tax under s.73 or s.74 — and now s.74A for FY 2024-25 onwards.

Corrective action taken. Rule 99(2): where the person accepts the discrepancy and pays the tax, interest and any other amount arising from it, and informs the officer, or furnishes an explanation, he does so in FORM GST ASMT-11.

What scrutiny is not

Not an audit. Section 65 audit requires ADT-01 notice, fifteen working days, and a defined period. Scrutiny is a desk exercise on the returns.

Not an assessment. No liability is determined. Section 61 produces information, not an order.

Not appealable. An ASMT-10 is not an order under s.107. There is nothing to appeal — and nothing to comply with beyond replying.

Not a demand. The quantification in ASMT-10 is indicative. Any actual demand requires s.73, s.74 or s.74A with its own notice.

That last point matters for the reply. An ASMT-11 is not a defence to a demand; it is an explanation intended to prevent one.

What the system typically flags

Scrutiny is largely automated, driven by return-to-return comparison:

• GSTR-1 versus GSTR-3B liability — though Rule 88C now catches this earlier through DRC-01B; Rule 88C and DRC-01B →
• GSTR-3B credit versus GSTR-2B — likewise Rule 88D and DRC-01C; Rule 88D and DRC-01C →
• GSTR-3B versus GSTR-9 and GSTR-9C;
• e-way bill data versus reported outward supplies;
• reverse charge liability declared versus inward supplies from notified categories;
• ITC reversal under Rules 42 and 43 against declared exempt turnover;
• credit availed on invoices from suppliers who did not file GSTR-3B — Rule 37A;
• TDS and TCS credit in the cash ledger versus turnover reported;
• import data from ICEGATE versus credit claimed;
• refund claimed versus turnover and credit declared.

Writing the reply

Answer each discrepancy separately, in the order raised.

Give the reconciliation, not the conclusion. "The difference is on account of reverse charge outward supplies" is a conclusion. A schedule listing the invoices, the RCM notification entry and the recipient GSTINs is a reconciliation.

Attach the working papers. ASMT-11 permits attachments.

Where the discrepancy is correct, pay and say so. Rule 99(2) contemplates exactly this — accept, pay the tax and interest through DRC-03, and inform the officer. That closes the item and avoids the penalty exposure that a s.73 or s.74A proceeding would carry.

Ask for time where needed. The rule allows "such further period as may be permitted by him", so an extension can be sought — but it must be sought, not assumed.

Do not ignore it. Non-reply is an express trigger under s.61(3) for audit, special audit, inspection or a demand.

Key takeaways

• s.61: scrutiny of returns, discrepancy communicated in ASMT-10 with up to thirty days to explain.
• Reply or acceptance-with-payment in ASMT-11; acceptance of the explanation in ASMT-12.
• s.61(3): no reply or an unsatisfactory one triggers s.65, s.66, s.67, or s.73/74/74A.
• Scrutiny is not an audit, not an assessment, not appealable and not a demand.
• Most flags come from return-to-return and third-party data comparison.
• Where the discrepancy is right, pay through DRC-03 and inform the officer — that closes it.

Read next

• Scrutiny of Returns: ASMT-10 Notice and Response
• Reply to ASMT-10: Sample Draft
• Rule 88C and DRC-01B: GSTR-1 versus GSTR-3B
• Sections 46 and 62: What Happens When You Do Not File

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).