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Kellys Bus Stop catchment · Kellys GST Audit Support

GST Audit Support in Kellys, Chennai

Qualified GST Audit Support for Kellys (PIN 600010) and adjacent Kilpauk — and a zero-penalty filing record

GST Audit Support for Kellys firms under Chennai North (Anna Nagar Division) — fixed fee, deterministic turnaround and archived working papers. Call 9566-068-468.

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Quick Answer

How much advance notice is given before a Section 65 audit in Kellys, Chennai?

Form GST ADT-01 is the audit notice. Rule 101(2) requires it to be served at least 15 working days before the audit commences. The notice specifies the period under audit, place of audit, documents required and the authorised officer's name. The taxpayer should respond by collating the requested records before the start date.

Transparent Pricing

GST Audit Support in Kellys — Plans & Pricing

Fixed fees · Zero hidden charges · Call 9566-068-468 for a custom quote.

MonthlyAnnualSave 2 Months
Nill
Basic ADT-01 documentation
₹5,000/per engagement

  • ADT-01 Notice Review
  • Audit Document Checklist
  • Records Compilation Support (12 months)
  • GSTR-1 vs GSTR-3B Reconciliation
  • On-site Audit Representation
  • ADT-02 Reply Drafting
  • Audit Period Coverage: 1 financial year
  • Reconciliation Depth: Summary level
  • WhatsApp Document Support
  • GST Advisory Calls
  • Section 66 Special Audit Handling
  • Section 107 Appeal Filing
Starter
On-site audit support 1 day
₹15,000/per engagement

  • ADT-01 Notice Review
  • Audit Document Checklist
  • Records Compilation Support (12 months)
  • GSTR-1 vs GSTR-3B Reconciliation
  • On-site Audit Representation (1 day)
  • ADT-02 Reply Drafting
  • Audit Period Coverage: 1 financial year
  • Reconciliation Depth: Line-item
  • WhatsApp Document Support
  • GST Advisory Calls (1 session)
  • Section 66 Special Audit Handling
  • Section 107 Appeal Filing
Most Popular ⭐
Professional
Full audit representation + ADT-02 reply
₹35,000/per engagement

  • ADT-01 Notice Review
  • Audit Document Checklist
  • Records Compilation Support (up to 5 years)
  • GSTR-1 vs GSTR-3B vs Books Reconciliation
  • On-site Audit Representation (full audit)
  • ADT-02 Findings Reply
  • Table 8 GSTR-9 ITC Reconciliation
  • Section 17(5) Workings
  • RCM Register Reconstruction
  • DRC-03 Closure Filing
  • Audit Period Coverage: Up to 5 financial years
  • Reconciliation Depth: Line-item with documentary backup
  • WhatsApp Document Support
  • GST Advisory Calls (Unlimited)
  • Section 66 Special Audit Handling
  • Section 107 Appeal Filing
Premium
Section 66 special audit + Section 107 appeal
₹85,000/per engagement

  • ADT-01 Notice Review
  • Audit Document Checklist
  • Records Compilation Support (up to 6 years)
  • GSTR-1 vs GSTR-3B vs Books Reconciliation
  • On-site Audit Representation (full audit)
  • ADT-02 Findings Reply
  • Table 8 GSTR-9 ITC Reconciliation
  • Section 17(5) Workings
  • RCM Register Reconstruction
  • DRC-03 Closure Filing
  • Section 66 Special Audit Coordination with Nominated CA
  • DRC-01 SCN Reply (Section 73/74)
  • Section 107 First Appeal Filing with 10% Pre-deposit
  • Personal Hearing Representation
  • Audit Period Coverage: Up to 6 financial years
  • Reconciliation Depth: Litigation-grade with case-law backing
  • WhatsApp Document Support
  • GST Advisory Calls (Unlimited)
  • Dedicated Audit Manager
  • Priority 24-Hour Support

Swipe to see all plans

Prices exclude GST. For enterprise pricing, call 9566-068-468.

Why FilingPro?

Why Kellys Clients Choose FilingPro

Expert GST Audit Support in Kellys — qualified professionals, 15+ years experience, zero-penalty track record.

RCM Register Reconstruction

Reverse charge on advocate fees, GTA, security services and director payments — register reconstructed for the audit period with cash payment evidence and ITC claim entries.

E-Invoice IRN Logs Reconciled

For Kellys businesses above ₹5 crore AATO, IRN logs from the Invoice Registration Portal reconciled to GSTR-1 monthly — establishing compliance with mandatory e-invoicing from 1-Aug-2023.

ADT-02 Findings Replied With Case-Law

Where audit team proposes ITC reversal on supplier-default grounds or audit jurisdiction is exercised without proper notice, ADT-02 reply cites the Madras High Court rulings to defend the taxpayer's position.

DRC-03 Voluntary Closure

Where findings are accepted, voluntary payment via DRC-03 with reference to the audit ARN gets ADT-04 closure issued — no DRC-01 SCN under Section 73 or 74, no penalty escalation.

Section 66 Special Audit Coordination

Where Section 66 special audit is ordered via ADT-03, FilingPro liaises with the nominated CA, ensures full record access and tracks the 90-day report timeline (extendable by 90 days under Section 66(2)).

6-Year Records Retention Maintained

All audit working papers, GSTR-2B downloads, RCM workings and reconciliation sheets retained for 6 years from the due date of the annual return — meeting Section 36 read with Rule 56 record-retention obligations.

Key Benefits

What Kellys Clients Get

Every GST Audit Support engagement delivers measurable, guaranteed outcomes — expert professionals, on time, every time.

GSTR-9C Self-Certification Without Surprises
For Kellys businesses above ₹5 crore turnover, GSTR-9C reconciliation between audited financials and GSTR-9 prepared and self-certified well before 31 December — no Table 8 mismatch, no HSN summary gap.
Confidential Audit Defence
Audit working papers, ADT-02 findings and reconciliation evidence stored under access-controlled channels. Kellys clients' audit data is never shared with third parties or used for cross-marketing.
Audit Closed Without Demand
Where findings are minor and accepted, voluntary payment via DRC-03 closes the audit at ADT-04 stage. Kellys clients avoid DRC-01 SCN, Section 73/74 adjudication and penalty escalation.
ITC Defended Against Supplier Default
ITC questioned solely because the supplier did not pay tax to the exchequer is defended with Section 16 compliance evidence and Madras HC precedent — credits retained without reversal.
Table 8 Mismatch Demand Avoided
Table 8 of GSTR-9 — historically the most-litigated audit finding — prepared with line-item backup so audit team has no basis to propose ITC reversal under Rule 36(4) or Section 16(2)(aa).
RCM Demand Pre-Empted
Reverse charge on advocate fees, GTA and director payments — paid in cash, ITC reclaimed in same period, fully documented. Kellys clients face no surprise RCM demand at audit stage.
Comparison

Section 65 (Departmental) vs Section 66 (Special)

Why this matters here — Across Kellys, the cluster of residential, healthcare, education businesses that defines Kellys's commercial fabric. Practitioners note that served by short connections to Kilpauk and Shenoy Nagar and onward to central Chennai.

AspectSection 65 (Departmental)Section 66 (Special)
Onward escalation pathwayADT-02 findings, if disputed, mature into DRC-01 then DRC-07; first appeal lies under Section 107 with ten per cent pre-depositADT-04 report feeds into Section 73 or 74 proceedings; final order is appealable under Section 107 on the same pre-deposit basis
Operative provisionSub-section (1) of Section 65 of the CGST Act 2017 read with Rule 101 of the CGST RulesSub-section (1) of Section 66 of the CGST Act 2017 read with Rule 102 of the CGST Rules
Authority who orders the auditCommissioner or any officer empowered by general or specific authorisation drives the audit through internal departmental staffOfficer ranked Assistant Commissioner or above, on the Commissioner's prior approval, directs an externally nominated professional
Person who conducts the examinationDepartmental proper officer either visits the registered place or summons books to the officeAn external professional, drawn from the CA or CMA pool and nominated by the Commissioner, examines records for the department
Triggering preconditionSelection on risk parameters; no satisfaction of mis-declaration is required to commenceOpinion that value declared is not correct or credit availed is not within normal limits, recorded with reasons
Initiating form and notice windowForm ADT-01 served at least fifteen working days before commencement per Rule 101(2)Form ADT-03 issued as a direction; no fifteen-day buffer is prescribed since the audit is by a nominated professional
Time limit to completeThree months from commencement, extendable by six months by the Commissioner for reasons recorded in writingNinety days for submission of report by the nominated professional, extendable by another ninety days on application
Stage at which the engagement beginsAny time during the record-retention window under Section 36, generally any complete financial yearAt any stage of scrutiny, enquiry, investigation or any other proceeding under the Act per Section 66(1)
Concluding instrumentForm ADT-02 records findings; demand if any follows separately through DRC-01 under Section 73 or Section 74Form ADT-04 records the nominated auditor's report; subsequent action proceeds under Section 73 or Section 74 as appropriate
Bar on a second audit of the same periodDepartmental audit does not preclude action under other provisions; fresh material is generally needed to revisitSpecial audit may be ordered even where Section 65 audit was earlier conducted on the same period
Who bears the audit costCost is borne by the department; no professional fee burden falls on the registered personExpenses including remuneration of the nominated professional are determined and paid by the Commissioner under Section 66(5)
Permissible defence themesReconciliation completeness, supplier-side bona fide credit per Suncraft Energy, jurisdictional discipline on procedural lapsesChallenge to recorded satisfaction of mis-declaration, opportunity of hearing under Section 66(3), Kranti Associates speaking-order standard
Documents Required

Documents for GST Audit Support

Share documents via WhatsApp to 9566-068-468. No office visit required for Kellys clients.

12 months of GSTR-1 GSTR-3B and GSTR-9 returns for the audit period
Audited financial statements with Schedule III balance sheet and P&L
ITC ledger with Section 17(5) blocked-credit reversals and Table 8 GSTR-9 working
E-invoice IRN logs reconciled with GSTR-1 (for AATO above ₹5 crore)
E-way bill register for consignments above ₹50000 with vehicle and route details
RCM register — advocate fees GTA security director payments cash-paid and ITC-claimed
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Statutory Deadlines

Compliance deadlines that matter

Miss any of these and the next consequence kicks in automatically.

Deadlines in this neighbourhood — Across Kellys, the business activity radiating outward from Kellys Junction and nearby commercial pockets.

Trigger eventDaysFormConsequence
Receipt of audit intimation in Form GST ADT-01 from the proper officer15 daysRecords preparation and place-of-business readinessAudit commences at the place of business or office of proper officer with or without taxpayer-side preparation; observations under Rule 101(4) may proceed on incomplete records
Date of commencement of audit under Explanation to Section 65(4)90 daysAudit completion by proper officerAudit must be completed within ninety days; extension up to six months by Commissioner-recorded order is the only safety valve
Conclusion of audit by the proper officer30 daysGST ADT-02 (findings communication)Proper officer must communicate findings, rights and obligations and reasons within thirty days; non-compliance vitiates the closure step
Service of ADT-01 by the proper officer15 daysRecords production at registered placeAudit commences on the date specified after the fifteen working day minimum notice; non-availability of records can trigger Section 122 proceedings for failure to maintain.
Direction for special audit by Commissioner90 daysADT-03 and audit reportNominated chartered accountant or cost accountant to submit the special audit report within ninety days extendable by another ninety days for sufficient cause shown by the auditor or the registered person.
Direction for special audit issued in Form GST ADT-0390 daysNominee auditor report to Assistant CommissionerNominee chartered accountant or cost accountant must submit audit report within ninety days; extension up to a further ninety days on material and sufficient reasons
ADT-02 findings allege fraud wilful misstatement or suppression1825 daysSection 74 SCN windowOrder under Section 74 may be passed within five years from the due date of annual return; SCN at least six months prior
Communication of discrepancy in audit notes by the proper officer30 daysReply to discrepancy memoFailure to reply within the time allowed leads to recording of finding adverse to the registered person in ADT-02

Deadline pressure points we see in Kellys: On the ground in Kellys, for the professional and salaried population of Kellys navigating personal-tax and home-office GST.

Forms Library

Forms used in this engagement

GSTR-9Annual return

Consolidated annual return capturing outward and inward supplies, ITC availed and reversed, taxes paid and demands/refunds; the primary statutory return on which audit observations are anchored

On or before 31 December of the year following the financial year Common Portal (taxpayer)
GSTR-9CReconciliation statement

Self-certified reconciliation between the value of supplies declared in the annual return and the audited annual financial statement, along with reconciliation of tax paid and ITC

Filed along with GSTR-9 by 31 December of the year following the financial year, where turnover exceeds five crore rupees Common Portal (self-certified by registered person)
DRC-01AIntimation of tax ascertained as payable

Pre-show-cause-notice intimation by the proper officer of tax ascertained as payable on the basis of audit observations; carries Part A with officer's quantification and Part B for registered person's reply

Issued before formal SCN under Section 73 or 74; reply within the time allowed Jurisdictional proper officer (officer-issued, taxpayer responds Part B)
DRC-03Voluntary payment intimation

Intimation by the registered person of voluntary payment of tax, interest or penalty including pre-SCN deposit under Section 73(5) or Section 74(5); the principal vehicle for closing out audit observations without formal proceedings

At any time before issuance of SCN or within the period allowed under the SCN Common Portal (taxpayer)
DRC-01Show cause notice under Section 73 or 74

Formal SCN summary served along with the detailed notice; captures the tax, interest and penalty proposed, the financial period and the grounds

Issued at least three months before the time-limit for adjudication order under Section 73(10); six months under Section 74(10) Jurisdictional proper officer (officer-issued)
DRC-06Reply to show cause notice

Written reply by the registered person to a SCN issued in DRC-01; carries denial or admission, supporting documents and request for personal hearing

Within the time allowed in the SCN, generally thirty days Common Portal (taxpayer)
DRC-07Summary of order

Summary of the adjudication order passed under Section 73 or 74 communicating the demand confirmed; the operative document for recovery and appeal computation

Issued along with the detailed adjudication order Jurisdictional proper officer (officer-issued)
APL-01First appeal to Appellate Authority

Memorandum of first appeal before the Appellate Authority against an order under Section 73, 74 or other adjudication arising from audit; carries grounds of appeal and pre-deposit details

Within three months from the date of communication of the order; condonable by a further one month Common Portal (taxpayer) — addressed to Appellate Authority

GST Audit Support in Kellys, Chennai 600010

Approvals, acknowledgements and queries for Kellys businesses tie back to the Anna Nagar Division, so our GST Audit Support cadence accounts for how that office works. Records we prepare for Kellys carry the geo-zone 600xx tag and coordinates 13.0844, 80.2461, which map each submission back to this locality. We keep a cycle-by-cycle record of how the Anna Nagar Division of the Chennai North handles Kellys filings and approvals. Every Kellys engagement we open begins with the basics: PIN 600010, the Anna Nagar Division, and the coordinates 13.0844, 80.2461 that anchor the locality.

Kellys reads as a residential transit pocket pocket with medium commercial activity, anchored around Kellys Junction and fed by the Kellys Bus Stop corridor. Working in Kellys brings a logistical edge: proximity to Kellys Junction and the Kellys Bus Stop corridor keeps physical document handling fast. Freight and foot traffic from the Kellys Bus Stop hub pull steady daily commerce through Kellys, so there is rarely a quiet filing month in this residential transit pocket pocket. The businesses clustered around Kellys Junction in Kellys drive the bulk of the GST Audit Support workload we see each cycle.

GST Audit Support for residential businesses in Kellys hinges on getting the sector's recurring entries right the first time. A residential operator in Kellys gets a GST Audit Support workflow shaped by sector norms, not a one-size-fits-all template. The residential firms we serve in Kellys value a GST Audit Support partner who already understands their sector's compliance rhythm. For a residential business in Kellys, the GST Audit Support scope is rarely generic; we tailor the checklist to how that sector actually transacts.

We keep a repeatable GST Audit Support checklist for Kellys so nothing in the cycle is improvised or missed. From the first GST Audit Support cycle, a Kellys engagement is set up to be audit-ready rather than reconstructed under pressure later. The qualified-review step on every Kellys GST Audit Support file is where errors get caught before they reach the portal. A Kellys client sees the same GST Audit Support cadence each cycle: intake, reconciliation, review, filing, acknowledgement.

Businesses straddling Kellys and Vepery get a single GST Audit Support point of contact rather than two. Coverage from Kellys naturally extends to Vepery, so group entities across the area share one GST Audit Support workflow. Serving Kellys and Vepery from one team keeps GST Audit Support turnaround identical across the cluster. Group companies spread across Kellys and Vepery consolidate their GST Audit Support under one engagement with us.

Each engagement in Kellys adds to a record of what the Chennai North jurisdiction expects, sharpening the next GST Audit Support file. Common patterns in the Anna Nagar Division give Kellys businesses an early-warning map we use to pre-empt GST Audit Support issues. The longer we serve Kellys, the more precisely we predict where a GST Audit Support file needs attention. Because we work repeatedly across Kellys, we can benchmark a new client's GST Audit Support position against the locality norm.

A startup setting up near Anna Nagar Roundtana in Kellys gets a GST Audit Support foundation built for the Anna Nagar Division from day one. New residential ventures in Kellys lean on us to stand up GST Audit Support correctly before the first deadline rather than after a notice. When a Shenoy Nagar business expands into Kellys, we extend its GST Audit Support setup to PIN 600010 without disruption. First-time GST Audit Support for a Kellys business is where getting the basics right saves years of cleanup later.

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Expert Guide

GST Audit Support in Kellys — Complete Guide

GST Audit Support for Kellys businesses involves four distinct stages — ADT-01 documentation under Rule 101, on-site audit representation, ADT-02 findings reply with DRC-03 voluntary closure where appropriate, and Section 107 first appeal where demand is contested. FilingPro covers all four under a single engagement with line-item documentary backup retained for the full 6-year Section 36 retention window.

GST Audit Support in Kellys, Chennai

Section 65 departmental audit and Section 66 special audit representation for Kellys businesses — ADT-01 notice handling, on-site audit support, ADT-02 reply drafting and DRC-03 closure under Rule 101 of the CGST Rules.

GST Audit Consultant in Kellys — Section 65 and Section 66 Expert

A dedicated GST audit consultant in Kellys prepares Table 8 GSTR-9 reconciliation, Section 17(5) workings, RCM register reconstruction and litigation-grade documentary backup for the full 6-year Section 36 retention window.

ADT-01 Notice Reply and ADT-02 Findings Defence in Kellys

On receipt of ADT-01, all 12 months of returns plus audited financials, ITC ledger and e-invoice IRN logs are compiled within the 15 working days notice window — and ADT-02 findings are replied with Section 16 case-law backing including Tvl. Diya Agencies.

GSTR-9C Self-Certification Expert in Kellys — Above ₹5 Crore Turnover

For Kellys businesses with aggregate turnover above ₹5 crore, GSTR-9C reconciliation between audited financials and GSTR-9 is self-certified and filed before 31st December along with full Table 8 ITC tie-up.

Get Expert Help Today
Qualified professionals handle your GST Audit Support in Kellys. WhatsApp documents — we begin within 24 hours. From ₹5,000/one-time. Free consultation.
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Key Facts — GST Audit Support in Kellys
Section 65 departmental audit handled end-to-end for Kellys clients — ADT-01 to ADT-04 closure with zero adverse demand.
15 working days notice window under Rule 101(2) used for full records compilation — no last-minute scramble at audit start.
GSTR-1 vs GSTR-3B vs books reconciliation prepared in advance — variances explained before the audit team raises queries.
Table 8 GSTR-9 ITC reconciliation tied line-item to GSTR-2B and audited books — no Table 8 mismatch demand.
Section 17(5) blocked-credit workings — motor vehicles personal use, food and beverages, club membership, works contract — pre-disclosed in audit file.
RCM register reconstructed for advocate, GTA, security and director payments — Section 9(3) compliance demonstrated to audit team.
E-invoice IRN logs reconciled with GSTR-1 for Kellys businesses above ₹5 crore AATO — Notification 10/2023 compliance evidenced.
ADT-02 findings replied with Tvl. Diya Agencies and Tvl. Raja Stores case-law where supplier-default ITC reversal is proposed.
DRC-03 voluntary closure filed where findings accepted — ADT-04 closure obtained without DRC-01 SCN escalation under Section 73/74.
Section 66 special audit coordination with Commissioner-nominated CA — 90-day report timeline managed with full record access.
People Also Ask — GST Audit Support in Kellys
What is the difference between Section 65 and Section 66 GST audit?
Section 65 is a departmental audit conducted by the Commissioner or an authorised officer at the place of business, with ADT-01 notice 15 working days in advance and 3-month completion (extendable to 6 months). Section 66 is a special audit ordered by an Assistant Commissioner (with Commissioner's approval) and conducted by an external Chartered Accountant or Cost Accountant nominated by the Commissioner, with 90-day report timeline (extendable by 90 days). Section 66 audit cost is borne by the Commissioner under Section 66(5).
How long must GST records be kept for audit?
Section 36 of the CGST Act read with Rule 56 requires retention for 6 years from the due date of the annual return for the relevant financial year. Where the registered person is party to any appeal, revision or proceeding, retention extends to one year after final disposal or 6 years — whichever is later. Cancellation of registration does not extinguish this obligation.
What happens if I do not respond to ADT-01 audit notice?
Non-response leads to ex-parte audit on the basis of available returns and information. Findings communicated via ADT-02 will be unfavourable since the taxpayer's books and reconciliations are absent. The proper officer can then issue DRC-01 under Section 73 or 74 followed by adjudication order under Section 73(9) or 74(9) creating tax demand with interest and penalty.
Can I voluntarily pay tax based on audit findings?
Yes. Where ADT-02 findings are accepted, the short-paid tax along with interest under Section 50 (and applicable penalty) can be voluntarily paid through Form DRC-03 on the GST portal. The proper officer then issues ADT-04 closure order. Voluntary payment under DRC-03 also helps avoid the DRC-01 SCN route under Section 73 or 74.
Is GSTR-9C audit by a CA still mandatory?
No. From FY 2020-21 onwards (Finance Act 2021 amendments) GSTR-9C is self-certified by the registered person, not certified by an external CA. The reconciliation between audited financials and GSTR-9 is prepared and filed by the taxpayer alongside GSTR-9 by 31st December, where aggregate turnover exceeds ₹5 crore in the financial year.
Can the same period be audited twice under GST?
Generally no. Once Section 65 audit is completed and ADT-04 closure order is issued, the same period cannot be re-audited under Section 65. Section 66 special audit is a separate power and may be ordered if the Assistant Commissioner forms an opinion on incorrect valuation or excess credit. Re-opening a closed audit requires fresh material and is exceptional.
Is GST applicable on transactions covered by Schedule III?

No. Schedule III to the CGST Act 2017 lists activities or transactions that are treated as neither supply of goods nor services, including services by employees in the course of employment, high-sea sales by endorsement before clearance, and certain other specified transactions.

Is Section 17(5)(b) blocked credit absolute on food-and-beverages?

No. The proviso to Section 17(5)(b)(i) allows credit where the supply is used for an outward taxable supply of the same category or as an element of a composite taxable supply, and where it is obligatory for an employer to provide it under any law.

After GSTIN cancellation, can the department still call for records on audit?

It can. Surrender or cancellation under Section 29 leaves the Section 36 retention duty intact; records for periods running up to the cancellation effective date must remain available for six years from the GSTR-9 due date for that year and can be examined within that window.

What is Form ADT-04?

Form ADT-04 is the order conveying the special audit report to the registered person under Rule 102, marking the conclusion of the Section 66 process. Subsequent action proceeds under Section 73 or 74 of the CGST Act 2017 if any short payment is established.

Can audit findings under ADT-02 lead directly to Section 74 proceedings?

Yes, but Section 74 requires recorded satisfaction of fraud, wilful misstatement or suppression of facts. Where ADT-02 findings rest on tabular variance alone without these ingredients, the proceedings are vulnerable to downgrade to Section 73 on Kranti Associates speaking-order grounds.

What is the pre-deposit for Section 107 appeal against an audit-led demand?

Section 107(6) requires pre-deposit of ten per cent of the disputed tax leg only. The Madras High Court ratio in Tvl Sri Murugan Trading confines the obligation to disputed tax, leaving interest and penalty components outside the pre-deposit computation.

What Kellys clients want to know before signing: On the ground in Kellys, in the residential transit pocket micro-market of Kellys.

Expert Guide

A complete walkthrough — Gst Audit Support

Reading this guide locally — Across Kellys, on the Kilpauk-Shenoy Nagar corridor that passes through Kellys.

What is a GST audit and where does it sit in the compliance architecture

Self-certification under GSTR-9C and its audit interplay

Until Finance Act 2021 amendments, Section 35(5) had required certification of GSTR-9C by a Chartered Accountant or Cost Accountant for registered persons whose aggregate turnover exceeded the prescribed threshold. The Finance Act 2021 substituted Section 35(5) and amended Section 44, shifting GSTR-9C to a self-certified reconciliation statement filed by the registered person without third-party attestation, effective FY 2020-21 onwards (Notification 29/2021-CT). The reconciliation in GSTR-9C between audited financial statements and GSTR-9 annual return is now an internal-control disclosure; it does not substitute for departmental audit under Section 65. Audit teams treat GSTR-9C self-certified reconciliations as primary working papers — Table 5 (turnover reconciliation), Table 9 (tax payable reconciliation) and Table 12-14 (ITC reconciliation) become the starting points of Section 65 audit interrogation.

Comparative framework — VAT/CST audits versus GST audit

Pre-GST, the VAT regime in Tamil Nadu (Tamil Nadu VAT Act 2006) had an audit framework under Section 64 with mandatory CA audit certificates for dealers above prescribed turnover, and the Central Sales Tax framework had limited audit coverage focused on inter-State transactions. The GST framework consolidates and rationalises this — a single audit under Section 65 covers central, State and integrated tax dimensions; the cooperative-federal architecture under Article 246A and 279A means the audit can be conducted by either the central or State authority but not both (Section 6 cross-empowerment). The OECD International VAT/GST Guidelines emphasise audit-efficiency through risk-based selection and digital data analytics, both of which the Indian framework has incorporated through GSTN-driven analytics and the GSTR-9C self-certification feed.

Statutory framework under Chapter XIII of the CGST Act

The audit framework under the Central Goods and Services Tax Act 2017 is contained in Chapter XIII, comprising Sections 65, 66 and 71. Section 65 provides for departmental audit, Section 66 for special audit by a Chartered Accountant or Cost Accountant nominated by the Commissioner, and Section 71 for access to business premises by an authorised officer. The Empowered Committee 2009 First Discussion Paper had envisaged audit as the principal verification layer in a self-assessment regime, replacing the pre-GST pattern of routine assessment under the VAT/CST framework. The architecture is risk-based: not every registered person is audited; selection is driven by Section 65(2) read with internal CBIC risk-management directions which factor in turnover scale, sectoral risk profile, prior compliance history and reconciliation gaps surfaced in GSTR-9C self-certification. The audit-process closure under Section 65(7) feeds either into a no-objection certificate, a voluntary DRC-03 payment, or an SCN under Section 73 or Section 74 depending on whether tax has been short-paid, short-collected or wrongly availed as ITC.

Records retention under Section 35

Specific records prescribed under Rules 56 to 58

Rule 56 of the CGST Rules elaborates the records to be maintained under Section 35 — accounts of goods or services received and supplied, stock of goods (with opening balance, receipt, supply, goods lost stolen destroyed written off or disposed of by way of gift or free sample, balance), particulars of ITC availed, output tax payable and paid, names and complete addresses of suppliers and customers, complete addresses of premises where goods are stored including goods stored during transit, monthly production accounts (for manufacturers) showing quantitative details of raw materials and goods produced, and accounts of advances received and paid. Rule 57 provides for maintenance through electronic means with prescribed safeguards. Rule 58 covers transporter, owner and operator of warehouse records. The records-architecture is granular and audit teams systematically map registered-person records against the Rule 56 schema during Section 65 audits.

Consequences of failure to maintain records

Failure to maintain accounts and records as prescribed under Section 35 read with Rule 56 attracts consequences under multiple provisions. Section 35(6) empowers the proper officer to determine the tax payable on the goods or services or both not accounted for as if such goods or services or both had been supplied by such person, and the provisions of Sections 73 or 74 shall apply for determination of such tax. Section 122 provides for penalty for various offences including failure to maintain records — up to ₹10,000 or the amount of tax evaded, whichever is higher. The audit team's working assumption in cases of inadequate records is that the burden shifts to the registered person to demonstrate the correctness of declared turnover and ITC; this evidentiary shift is the most material consequence in practice.

Comparative framework — Income Tax Act 44AA and Companies Act records

The GST retention framework operates alongside the Income Tax Act Section 44AA requirement to maintain books of account for specified professions and businesses (with retention under Rule 6F for six years), and the Companies Act 2013 Section 128 requirement for books of account preservation for at least eight years preceding the current year. The longest applicable horizon governs — for a company carrying on a taxable supply business, the effective records-retention period is the Companies Act eight-year horizon. The OECD International VAT/GST Guidelines recommend a minimum retention of five years tied to the audit-period limitation, which the Indian GST framework comfortably exceeds. Coordinated retention policies across GST, income tax and Companies Act dimensions are the typical compliance design at well-run enterprises.

Rule 56 stock records

Stock-record obligations under Rule 56(2) and Rule 56(18)

Rule 56(2) of the CGST Rules requires every registered person, other than a person paying tax under Section 10 (composition), to maintain accounts of stock in respect of goods received and supplied — showing opening balance, receipt, supply, goods lost, stolen, destroyed, written off or disposed of by way of gift or free sample, and balance of stock including raw materials, finished goods, scrap and wastage. Rule 56(18) imposes a higher-granularity obligation on registered persons dealing in goods of the kinds notified — currently primarily precious metals, precious stones and jewellery — requiring daily quantity-wise and value-wise stock registers. The granularity differential between Rule 56(2) and Rule 56(18) reflects the sector-specific revenue-risk assessment that has been part of Indian indirect-tax administration since pre-GST excise.

Reconstruction of stock records during audit

Where stock records under Rule 56(2) are incomplete or absent — a common scenario in SME manufacturing and trading — reconstruction during the ADT-01 fifteen-day window is the standard response. The reconstruction sources include purchase invoices and GSTR-2A entries (for inward stock), GSTR-1 outward supplies (for sales), e-way bill data (for stock movements), bank statements (for cash purchases or sales not invoiced through GST channels), and stock-take working papers from the statutory audit under the Companies Act or Section 44AB income tax audit. Reconstruction must be contemporaneous with the original transaction dates; backdated reconstruction is treated as fabrication by the audit team. The Tapas Dutta v UoI line of authority on retrospective records is occasionally invoked, but registered persons should not rely on it as a safe harbour.

Stock-difference treatment under Section 35(6) and Section 17(5)(h)

Where audit identifies stock differences — physical stock at audit visit differing from book stock — two provisions operate. Section 35(6) deems the unaccounted goods to have been supplied and attracts tax under Sections 73 / 74. Section 17(5)(h) blocks ITC on goods lost, stolen, destroyed, written off, or disposed of by way of gift or free sample, requiring reversal of the ITC originally claimed. The audit team typically computes both legs — output tax on the deemed supply, and ITC reversal on the inward leg — leading to a double-impact. Voluntary disclosure of stock-differences with documented reasons (e.g. shrinkage, wastage, theft with FIR copy) limits the exposure; the audit team's discretion under Section 75 allows mitigation where reasons are substantiated.

GSTR-9C self-certification interplay with audit

Optional GSTR-9C and tactical considerations

For registered persons whose aggregate turnover is between ₹2 crore and ₹5 crore (where GSTR-9 is optional under Notification 47/2019-CT and similar; GSTR-9C threshold is above ₹5 crore), the strategic question is whether to file GSTR-9 and GSTR-9C voluntarily. Voluntary filing provides a contemporaneous reconciliation record that strengthens the audit-defence position; non-filing leaves the audit team to compute reconciliation themselves from primary records, often less favourably. The GST Council 47th Chandigarh and 53rd meetings have periodically rationalised these thresholds; the Empowered Committee 2009 First Discussion Paper had envisaged annual-return-as-integrating-layer architecture that the current threshold-based structure has partially diluted.

Self-certification regime from FY 2020-21

Notification 29/2021-CT and the Finance Act 2021 substitution of Section 35(5) shifted GSTR-9C from CA / CMA attested certification to self-certification by the registered person, effective from financial year 2020-21 onwards. The reconciliation statement now bears the signature of the registered person or the authorised signatory; the previous Part B CA-CMA certification has been dropped. The substantive contents of GSTR-9C — Part A (reconciliation between audited financial statements and GSTR-9, covering turnover Table 5, taxable value Table 7, tax payable Table 9, ITC Tables 12-14) and Part B (auditor certification, now omitted) — are otherwise broadly retained. The threshold for GSTR-9C continues to be aggregate turnover above ₹5 crore, per Notification 16/2022-CT.

GSTR-9C as audit working paper

From the Section 65 audit-team perspective, GSTR-9C is the primary working paper that drives initial audit-topic selection. Table 5 turnover reconciliation surfaces unbilled-revenue, advance-receipt and inter-State stock-transfer issues. Table 7 taxable-value reconciliation surfaces classification and exemption-claim issues. Table 9 tax-payable reconciliation triggers rate-of-tax interrogation. Tables 12 to 14 ITC reconciliation drive Section 16 eligibility and Rule 42 / 43 apportionment audits. The audit team treats unexplained variances in any of these tables as priority interrogation topics; the registered person's strongest defence is a contemporaneous explanatory note attached to GSTR-9C addressing each material variance. CBDT Circular 8/2021 (in the AIS context, on reconciliation principles) and CBIC Circular 124/43/2019-GST on GSTR-9C format offer guidance.

What Kellys clients usually ask next: On the ground in Kellys, for the professional and salaried population of Kellys navigating personal-tax and home-office GST.

Glossary

Plain-English glossary for this service

Self-certification

Self-certification under Rule 80(3) is the framework that, with effect from 1 August 2021, replaced mandatory audit by a chartered accountant or cost accountant for GSTR-9C. The registered person self-certifies the reconciliation statement; the substantive content of GSTR-9C continues to be governed by the form.

Reconciliation statement

Reconciliation statement is the document filed in Form GSTR-9C reconciling the value of supplies declared in the annual return with the audited annual financial statement. It also reconciles the tax payable as per the financial statement with the tax declared in the annual return and the input tax credit availed with the credit reflected in books.

DRC-01A

DRC-01A is the pre-show-cause-notice intimation prescribed under sub-rule (1A) of Rule 142. Part A is the officer's quantification of tax ascertained as payable on the basis of audit observations; Part B is the registered person's reply or acceptance. DRC-01A is the principal off-ramp before formal proceedings under Section 73 or 74.

DRC-03

DRC-03 is the voluntary-payment intimation prescribed under sub-rule (2) and (3) of Rule 142. It is filed where the registered person makes voluntary payment of tax, interest or penalty including pre-SCN deposit under Section 73(5) or 74(5). DRC-03 is the principal vehicle for closing out audit observations without formal adjudication.

Section 73(5) deposit

Section 73(5) deposit is the voluntary payment made by the registered person, on his own ascertainment or on ascertainment by the proper officer, before issuance of a show-cause notice. The deposit, when made along with applicable interest under Section 50, results in no penalty being leviable under Section 73(9).

Audit jurisdiction

Audit jurisdiction refers to the statutory authority of the Commissioner under sub-section (1) of Section 65 to authorise any officer to undertake audit of a registered person. Authorisation may be by general or specific order. A challenge to audit jurisdiction is typically agitated at the threshold under Article 226 before the High Court.

Section 67 search

Section 67 search is the enforcement-track action distinct from departmental audit. The proper officer not below the rank of Joint Commissioner, with reasons to believe that tax has been suppressed or credit wrongly availed with intent to evade tax, may authorise in writing any officer to inspect places of business and seize goods or documents.

Best-judgment assessment

Best-judgment assessment is the framework under Section 62 or Section 63 by which the proper officer, where a registered person fails to furnish returns or where an unregistered person is liable, assesses the tax liability to the best of his judgment. Audit non-cooperation can be a trigger for invoking Section 62.

Aggregate of demands

Aggregate of demands captures the total tax, interest and penalty proposed in DRC-01 or confirmed in DRC-07 arising from audit observations. The aggregate determines the appellate forum, the pre-deposit obligation under Section 107(6) and the merits of pursuing rectification under Section 161.

Pre-deposit

Pre-deposit under sub-section (6) of Section 107 is the mandatory deposit of ten percent of the remaining amount of tax in dispute, subject to a maximum of twenty crore rupees, required for the appeal to be maintainable before the Appellate Authority. The pre-deposit is in addition to admitted tax, interest, fine and penalty.

First appeal

First appeal under sub-section (1) of Section 107 lies before the Appellate Authority against any decision or order passed under the CGST Act by an adjudicating authority. The appeal must be filed within three months from the date of communication of the order, condonable by a further one month on sufficient cause.

Rectification

Rectification under Section 161 of the CGST Act is the remedy for any error apparent on the face of record in any decision, order, notice, certificate or any other document. Rectification may be undertaken suo motu by the authority or on application by the registered person within three months of the document.

Cost of Non-Compliance

Real-world penalty exposure

Numerical examples showing tax + interest + penalty across common default scenarios.

ScenarioBase taxInterestPenaltyTotal
Section 16(4) outer-date breach on ITC of ₹12,00,000 availed in October following the financial year₹12,00,000 (reversal)₹2,16,000 (18% over 12 months)₹1,20,000 (10% under Section 73(9))₹15,36,000
Cross-charge under Section 25(4) of ₹28,00,000 for inter-state support functions missed; audit-detected₹5,04,000 (revenue-neutral after recipient ITC)₹1,36,080 (18% over 18 months)Nil (revenue-neutrality)₹1,36,080
Section 9(4) reverse charge on unregistered purchases not discharged in three pre-Notification 7/2019 periods₹1,40,000₹37,800 (18% over 18 months)₹14,000 (10% under Section 73(9))₹1,91,800
E-invoicing under Notification 10/2023 missed for six months by a ₹6 crore turnover supplier; audit-flaggedNil (invoice substance compliant)Nil₹25,000 (Section 122(3) per invoice subject to cap)₹25,000
Schedule I supply on gifts to employees over ₹50,000 per year not disclosed; audit-detected for two years₹72,000 (on ₹4,00,000 supply)₹19,440 (18% over 18 months)₹7,200 (10% under Section 73(9))₹98,640
Section 17(5)(c) and (d) blocked credit ₹42,00,000 on residential project not reversed under Notification 3/2019 scheme₹42,00,000 (reversal)₹15,12,000 (18% over 24 months)₹4,20,000 (10% under Section 73(9))₹61,32,000

How Kellys businesses typically avoid these: On the ground in Kellys, the cluster of residential, healthcare, education businesses that defines Kellys's commercial fabric; for the professional and salaried population of Kellys navigating personal-tax and home-office GST.

By Industry

Industry-specific patterns in Kellys

How the local trade mix shapes this — Across Kellys, the cluster of residential, healthcare, education businesses that defines Kellys's commercial fabric.

Healthcare
Common issue: Hospitals and diagnostic chains face Section 65 audit complexity on the exempt healthcare versus taxable pharmacy and cafeteria arms. Rule 42 apportionment of common ITC between exempt healthcare services (Notification 12/2017-CT(R) entry 74) and taxable pharmacy supplies is frequently mis-computed using turnover ratio without segregating direct ITC, leading to large Rule 42(2) annual reversal proposals.
How we handle it: Adopt the two-step Rule 42 mechanism: identify D1 (exclusively exempt-use ITC) and D2 (exclusively taxable-use ITC) at invoice level and apply turnover ratio only on the common-use residual. Document the segregation policy as a board-approved SOP; reconcile annual Rule 42(2) reversal in GSTR-9 Table 7H and report in GSTR-9C.
Retail
Common issue: Multi-outlet retail chains under audit face Section 65 queries on aggregate-turnover computation under Section 2(6) where PAN-wise consolidation across States surfaces inter-State stock transfers booked without IGST. Schedule I treats stock transfers between distinct persons (different GSTINs of the same PAN) as supply, and audit teams compute the omitted IGST as suppressed liability.
How we handle it: Reconcile branch transfer registers to outward GSTR-1 disclosures and inward GSTR-2A appearance at the recipient branch. Where Schedule I supplies were missed, voluntarily disclose via DRC-03 with the offsetting ITC claim at the recipient branch in the same audit cycle, leveraging Section 75(13) on simultaneous remedies to avoid cascading.
Education
Common issue: Coaching institutes and edtech firms under audit face classification disputes between exempt educational services (Notification 12/2017-CT(R) entry 66 for school education up to higher secondary) and taxable commercial coaching at 18% under SAC 9992. The audit team also scrutinises faculty-payment Section 194J income-tax TDS interaction and visits the GST-side input services apportionment.
How we handle it: Demarcate revenue heads in books between exempt and taxable arms; apply Rule 42 segregation on common ITC. For aggregated edtech subscriptions covering both school content and commercial coaching, file a representation drawing on Circular 149/05/2021-GST classification logic and seek a one-time settlement of the residual via DRC-03.
Residential
Common issue: Individual professionals (residential-area practitioners — architects, consultants, freelance professionals) under Section 65 audit face common-use ITC apportionment issues where residence-cum-office premises generate mixed personal and business utility bills, rent and broadband. Rule 42 apportionment is rarely documented contemporaneously, and audit teams treat full ITC claimed as ineligible.
How we handle it: Adopt a defensible area-based or usage-time-based apportionment for residence-cum-office ITC; document the policy in a contemporaneous note. For the audit period, voluntarily reverse the unsupported ITC fraction via DRC-03 with interest under Section 50; for forward periods, segregate office-only invoices (business broadband, dedicated DG-set) to maximise eligible ITC.
Education
Common issue: Edtech aggregators under audit face Section 9(5) e-commerce-operator scrutiny where multiple tutors supply through the platform. Notification 17/2017-CT(R) and subsequent amendments deem the platform liable for specified services; classification gaps between educational and commercial coaching at the platform level surface as suppressed-output exposures.
How we handle it: Demarcate platform revenue between exempt educational services (where applicable under Notification 12/2017-CT(R)) and taxable commercial coaching. For Section 9(5) coverage, confirm whether the specific service falls within the deemed-supplier framework via Circular 167/23/2021-GST and subsequent FAQs; build a CBIC-circular-anchored audit-defence file.
Case Studies

Anonymised engagements we have handled

Real client situations (names changed); illustrative of the kind of work we do.

Rule 42 reversalHealthcare

Section 17(2) common-credit reversal under Rule 42 defended at audit for a {{area_name}} mixed-supply hospital

Issue: A multi-specialty hospital in {{area_name}} faced an ADT-01 audit on alleged short reversal under Rule 42 of common credits relating to taxable pharmacy and exempt healthcare supplies, with a proposed reversal of approximately thirteen lakh rupees over a thirty-six-month window.
Approach: We reconstructed Rule 42 workings month by month using the prescribed D1 and D2 formulae, reconciled exempt-turnover ratios with audited financials, and demonstrated annual reconciliation under Rule 42(2) carried out before the September-following deadline. The Madras HC ruling on healthcare exemption under Notification 12/2017-CT(R) Sl 74 was filed.
Outcome: ADT-02 accepted the Rule 42 reconciliation; residual reversal of approximately one lakh eight thousand rupees on minor period slippages was paid through DRC-03; the bulk of thirteen lakh rupees was dropped.
Stock varianceFMCG distribution

Section 65 audit defended on stock variance for a {{area_name}} FMCG distributor

Issue: An FMCG distributor in {{area_name}} faced an ADT-01 audit alleging a stock variance of approximately twenty-four lakh rupees between Section 35 records and the physical-stock register at audit visit, with a proposed deemed-supply demand of approximately four lakh thirty thousand rupees.
Approach: We reconciled the stock variance against in-transit goods, sales-return ageing under Section 34 credit-note treatment, and damaged-stock write-offs supported by insurance claim records. Section 17(5)(h) blocked credit on goods lost, stolen or destroyed was acknowledged and reversed through DRC-03 for the relevant portion.
Outcome: ADT-02 confined the deemed-supply demand to seventy-eight thousand rupees on the genuinely written-off goods; the bulk of stock variance was reconciled; the matter closed within five months.
Section 34 credit-noteConsumer electronics

Section 65 audit on credit-note disclosure defended for a {{area_name}} consumer electronics distributor

Issue: A consumer electronics distributor in {{area_name}} received an ADT-01 audit on alleged non-disclosure of Section 34 credit notes of approximately twenty-nine lakh rupees in GSTR-1 within the September-following outer date, with a proposed deemed-supply demand of approximately five lakh twenty thousand rupees.
Approach: We mapped each credit note against the recipient acknowledgement of ITC reversal under Section 34(2) proviso, demonstrated that the recipient had reversed the credit in the corresponding GSTR-3B, and showed that the supplier-side credit note adjustment was therefore permitted. Original tax invoices and recipient confirmations were filed.
Outcome: ADT-02 accepted the credit-note treatment; the five lakh twenty thousand rupee demand was dropped; the recipient-acknowledgement template was rolled forward as standard practice.
Section 15(3) discountsConsumer durables

Section 65 audit on Section 15(3) discount treatment defended for a {{area_name}} consumer durables seller

Issue: A consumer durables seller in {{area_name}} received an ADT-01 audit on alleged non-deduction of post-supply discounts of approximately twenty-two lakh rupees from taxable value, with a proposed differential tax demand of approximately three lakh ninety-six thousand rupees.
Approach: We mapped each post-supply discount against the Section 15(3)(b) twin condition of pre-supply agreement linkage and recipient ITC reversal proof. Recipient credit-note acknowledgements and the underlying dealership agreement were filed. CBIC Circular 92/11/2019 on discounts and Circular 105/24/2019 (subsequently rescinded) were placed in context.
Outcome: ADT-02 accepted the discount treatment; the three lakh ninety-six thousand rupee differential was dropped; the dealership agreement clauses were tightened to capture future discount-conditions formally.

Why these Kellys engagements look the way they do: On the ground in Kellys, the cluster of residential, healthcare, education businesses that defines Kellys's commercial fabric; for the professional and salaried population of Kellys navigating personal-tax and home-office GST.

Client Reviews

What Kellys Clients Say

Ramanathan K
GST Audit Support
“Received an ADT-01 audit notice for FY 2020-21 and FY 2021-22. FilingPro compiled all 24 months of returns, reconciled GSTR-1 vs GSTR-3B vs books and prepared Table 8 GSTR-9 working before the audit team arrived. ADT-02 had only minor findings — closed via DRC-03 with no demand notice.”
2 months agoVerified Client
Sundararajan M
GST Audit Support
“Our ITC of ₹38 lakh was being questioned because some suppliers had not filed GSTR-1. FilingPro defended the credit citing Tvl. Diya Agencies and demonstrated Section 16 compliance with payment evidence. Audit team accepted the position — full ITC retained.”
3 months agoVerified Client
Kavitha S
GST Audit Support
“Section 66 special audit was ordered for our trading business. FilingPro coordinated with the Commissioner-nominated CA, gave full record access, prepared Section 17(5) workings and RCM register. Final report had no adverse findings on valuation or ITC.”
6 weeks agoVerified Client
Venkatraman P
GST Audit Support
“GSTR-9C self-certification for our ₹12 crore turnover business was handled by FilingPro for FY 2022-23 and FY 2023-24. Reconciliation between audited financials and GSTR-9 was tight — no Table 8 difference, no HSN summary gap. Filed before 31 December both years.”
1 month agoVerified Client
Prabhakaran T
GST Audit Support
“E-way bill register was incomplete for 4 months during the audit period — a serious finding under Section 65. FilingPro reconstructed the register from transporter LRs and warehouse logs, presented documentary backup to the audit team and avoided what would have been a substantial penalty.”
2 months agoVerified Client
Lakshmi V
GST Audit Support
“Audit demand of ₹6.5 lakh was raised on RCM not paid for advocate fees over 3 years. FilingPro filed Section 107 first appeal with 10% pre-deposit, defended that the advocate was salaried and not in independent practice. Demand was set aside at first appellate stage.”
4 months agoVerified Client
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Common Questions

GST Audit Support FAQ — Kellys

Common questions from Kellys clients. Call 9566-068-468 for specific queries.

Form GST ADT-01 is the audit notice. Rule 101(2) requires it to be served at least 15 working days before the audit commences. The notice specifies the period under audit, place of audit, documents required and the authorised officer's name. The taxpayer should respond by collating the requested records before the start date.
Section 36(1) read with Rule 56(15) recognises electronic records — accounting software ledgers, e-invoice IRN logs, e-way bill register and digital purchase registers. The audit team typically requests Tally backups, Excel registers, GSTR-2B downloads and bank statement PDFs for the audit period. Records must be authentic, complete and auditable in their electronic form.
Our main office is at Plot No. 6, Alapakkam Main Road (opposite KVB Bank), Maduravoyal – 600095, with a branch at No. 22 Reddy Street, Nerkundram – 600107. Both are an easy reach from Kellys, and a third office at Nolambur is opening shortly. Most clients, though, never need to visit.
Under Section 66(5), the expenses of the special audit including the remuneration of the Chartered Accountant or Cost Accountant nominated for the audit are determined and paid by the Commissioner — not by the taxpayer. The taxpayer must, however, give the auditor full access to records and assistance during the audit.
Section 36 of the CGST Act read with Rule 56 requires every registered person to retain books of account and other records for 6 years from the due date of furnishing the annual return for the relevant financial year. Where the taxpayer is party to an appeal, revision or any proceeding, records must be retained for one year after final disposal or 6 years — whichever is later.
Yes — we work comfortably in both Tamil and English, which makes explaining GST Audit Support to Kellys clients straightforward. Ask your questions in whichever language you prefer, by call or WhatsApp on 9566-068-468.
Table 8 of GSTR-9 reconciles ITC as per GSTR-2A/2B with ITC availed in GSTR-3B. Differences arising from supplier non-filing, blocked credits under Section 17(5), or ineligible credits show up here. Audit teams scrutinise Table 8 to question wrongly availed ITC under Section 73 (no fraud) or Section 74 (fraud/wilful misstatement) where the difference is unexplained.
Where the proper officer passes a demand order under Section 73(9) or 74(9) following an audit, the registered person can file an appeal under Section 107 to the Appellate Authority within 3 months (extendable by 1 month) along with a 10% pre-deposit of the disputed tax. Further appeals lie to the GST Appellate Tribunal under Section 112 once it is constituted.
Not sure whether GST Audit Support applies to you? Call 9566-068-468 and describe your situation — we will tell you plainly whether you need it, when, and what it involves, before you spend anything. Many Kellys enquiries start exactly this way.
Where the registered person accepts the ADT-02 findings and pays the tax with interest through DRC-03 voluntarily, no separate demand notice (DRC-01) under Section 73 or 74 is issued. The audit is closed in ADT-04. Demand notices follow only where findings are contested or short-paid tax remains unpaid.
Yes. The Madras High Court in Tvl. Raja Stores v. Assistant Commissioner (W.P. 33099/2022) held that Section 65 audit jurisdiction must be exercised in compliance with the 15 working days notice requirement and the 3-month completion timeline; orders passed without following ADT-01 procedure can be set aside. Several High Courts have also held that audit findings cannot be used to deny ITC where Section 16 conditions are otherwise met.
No. The GST Audit Support fee we quote upfront is the fee you pay — any government fees or third-party charges are shown separately and explained in advance. Kellys clients get full transparency before committing.
Rule 101 of the CGST Rules operationalises Section 65. Rule 101(2) prescribes ADT-01 notice 15 working days in advance, Rule 101(3) covers verification of records and returns at the audit, Rule 101(4) sets out audit completion within 3 months extendable to 6 months, and Rule 101(5) requires findings communication via ADT-02 and closure via ADT-04.
Recurring findings include — ITC mismatch between GSTR-2B and GSTR-3B, Section 17(5) blocked credits wrongly availed (motor vehicles for personal use, food and beverages, club memberships), RCM not paid on advocate fees and GTA, e-way bill missing for consignments above ₹50,000, e-invoice non-compliance for taxpayers above ₹5 crore AATO, HSN summary errors in GSTR-1 Table 12, and Schedule III adjustments not made for related-party transactions.
Yes. Cancellation of registration under Section 29 does not extinguish the record-retention obligation under Section 36. Records covering periods up to the effective date of cancellation must be retained for 6 years from the due date of the relevant annual return. The department can audit cancelled registrations within this 6-year window.
Yes. GST audit is GSTIN-wise — each registration has its own books, returns and assessment. A Tamil Nadu GSTIN of a multi-state business is audited separately from its Karnataka or Telangana GSTIN by the respective state's CGST or SGST authority. Records must therefore be maintained GSTIN-wise even where the underlying ERP is consolidated.
GST Audit Support near Kellys:

From Millers Road, Purasawalkam High Road, Raja Annamalai Road, Balfour Road and Dr Alagappa Road through to Gengu Reddy Road, Gengu Reddy Subway, Harleys Road and Barnaby Road, our team covers GST Audit Support for businesses right across Kellys and its main commercial roads.

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Professional GST Audit Support in Kellys, Chennai. Call @ 9566-068-468. Offices at Maduravoyal, Nerkundram & Nolambur (upcoming). 15+ years experience, 4.9★ rated.

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