Rated 4.9/5 by 312+ Chennai clientsZero penalty record across all filings24-hour response · WhatsApp-first supportOffices: Maduravoyal, Nerkundram & Nolambur (upcoming)15+ years of expert tax & compliance consulting500+ active clients across 243 Chennai areasRated 4.9/5 by 312+ Chennai clientsZero penalty record across all filings24-hour response · WhatsApp-first supportOffices: Maduravoyal, Nerkundram & Nolambur (upcoming)15+ years of expert tax & compliance consulting500+ active clients across 243 Chennai areas
Kottivakkam Bus Stop catchment · Kottivakkam GST Audit Support

Kottivakkam GST Audit Support — Chennai South

GST Audit Support cadence for Kottivakkam firms near Kottivakkam Bus Stop — backed by a 15+ year track record

GST Audit Support for residential businesses in Kottivakkam near Kottivakkam Beach — fixed fee, deterministic turnaround and archived working papers. Call 9566-068-468.

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Quick Answer

Are principles of natural justice applicable to GST audit in Kottivakkam, Chennai?

Yes. ADT-02 must record findings with reasons; Section 66(6) expressly mandates a hearing opportunity before special audit material is used in proceedings; and any DRC-01 SCN must give 30 days for DRC-06 reply with personal hearing. Courts have consistently set aside audit-driven demands where the taxpayer was not given proper opportunity to be heard.

Transparent Pricing

GST Audit Support in Kottivakkam — 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 Kottivakkam Clients Choose FilingPro

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

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.

Section 107 First Appeal Filed

Where DRC-01 SCN escalates to a Section 73(9) or 74(9) demand order, Section 107 appeal is filed within 3 months with 10% pre-deposit. Personal hearing represented by qualified professionals.

15+ Years Chennai Audit Experience

Our practice has handled departmental audits since the service tax and VAT era — deep institutional memory of jurisdictional CGST and SGST audit teams in Chennai, their typical findings and effective reply structures.

ADT-01 Notice Handled End-to-End

Every ADT-01 notice received by a Kottivakkam client is acknowledged within 24 hours and full records compilation begins under Rule 101(2). No last-minute scramble at audit start.

On-Site Audit Representation

For audits conducted at the registered principal place of business, FilingPro consultants are present throughout — answering queries, producing records and protecting against adverse interpretations on the spot.

Key Benefits

What Kottivakkam Clients Get

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

RCM Demand Pre-Empted
Reverse charge on advocate fees, GTA and director payments — paid in cash, ITC reclaimed in same period, fully documented. Kottivakkam clients face no surprise RCM demand at audit stage.
E-Way Bill Compliance Demonstrated
For consignments above ₹50000, e-way bill register with vehicle number and route details produced — Rule 138 compliance evidenced; no penalty under Section 122(1)(xiv) for non-issuance.
Section 17(5) Reversals Pre-Booked
Blocked credits — motor vehicles for personal use, food and beverages, club memberships, works contract for immovable property — identified and reversed in monthly GSTR-3B itself. No audit reversal demand.
Special Audit Cost Borne by Department
Where Section 66 special audit is ordered, the cost of the nominated CA is borne by the Commissioner under Section 66(5) — not by the taxpayer. Kottivakkam clients pay only FilingPro's coordination and representation fee.
Litigation-Ready Documentary File
Audit working papers, reconciliation sheets, Section 17(5) workings, RCM register and case-law citations retained for 7 years — supporting both the immediate audit and any future Section 107 or Tribunal appeal.
Natural Justice Procedural Defences
15 working days notice under Rule 101(2), 3-month audit completion under Rule 101(4), 30-day DRC-06 reply window under Section 73/74 — every procedural timeline tracked. Procedural lapses by department challenged.
Comparison

Section 65 (Departmental) vs Section 66 (Special)

Why this matters here — Across Kottivakkam, the cluster of residential, it services, restaurants businesses that defines Kottivakkam's commercial fabric. Practitioners note that served by short connections to Palavakkam and Thiruvanmiyur and onward to central Chennai.

AspectSection 65 (Departmental)Section 66 (Special)
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
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
Documents Required

Documents for GST Audit Support

Share documents via WhatsApp to 9566-068-468. No office visit required for Kottivakkam 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 Kottivakkam, the business activity radiating outward from Kottivakkam Beach 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.
First appeal pre-deposit obligation under Section 107(6)On due datePre-deposit of ten percent of disputed taxAppeal under Section 107 is not maintainable without the prescribed pre-deposit; capped at twenty crore rupees per limb
Annual return due date for the financial year under audit2190 daysRecords retention obligationBooks of account and records must be retained for seventy-two months from the due date of furnishing the annual return; extends further if appeal, revision or proceeding is pending
Adjudication order under Section 73 or 74 served90 daysAPL-01 first appealRight of appeal lapses if first appeal under Section 107 is not filed within three months from communication of order

Deadline pressure points we see in Kottivakkam: For Kottivakkam engagements specifically — for the professional and salaried population of Kottivakkam navigating personal-tax and home-office GST.

Forms Library

Forms used in this engagement

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
RFD-01Refund application

Refund application used where audit closure or appellate decision results in pre-deposit refund or refund of tax paid in excess pursuant to favourable order

Within two years from the relevant date under Section 54 Common Portal (taxpayer)
GSTR-1Statement of outward supplies

Monthly or quarterly statement of outward supplies — the primary source document for audit observations on tax payable, turnover declarations and B2B invoice flow

11th of the next month (monthly) or 13th of the month following the quarter (QRMP) Common Portal (taxpayer)
GSTR-3BSummary return

Monthly summary return capturing output tax, ITC availed and net tax payable — frequently the focus of audit observations on Table 4 ITC and Table 3 outward supply mismatches

20th / 22nd / 24th of the next month based on State and turnover slab Common Portal (taxpayer)
GST ADT-01Notice for conduct of audit

Statutory notice issued by the proper officer informing the registered person of the institution of audit under Section 65; carries the period of audit, place, date and the records to be made available

Not less than fifteen working days prior to conduct of audit Jurisdictional proper officer not below the rank prescribed
GST ADT-02Audit report under Section 65

Communication by the proper officer to the registered person of the findings of audit, rights and obligations and reasons for the findings; the formal closure document of departmental audit

Within thirty days of conclusion of audit Jurisdictional proper officer (officer-issued)

GST Audit Support in Kottivakkam, Chennai 600041

Kottivakkam is a coastal residential locality bridging Thiruvanmiyur and Palavakkam serving the IT workforce on OMR. Because PIN 600041 sits inside the Chennai South jurisdiction, the handling office for Kottivakkam stays consistent across years, which matters when filings or approvals span cycles. Statutory correspondence for Kottivakkam businesses routes through the Velachery Division, so we align every GST Audit Support engagement to that jurisdiction from the start. Businesses registered in Kottivakkam share the Chennai South jurisdiction, and their statutory matters route through the same Velachery Division each time.

Kottivakkam reads as a coastal residential and it support pocket with medium commercial activity, anchored around Kottivakkam Beach and fed by the Kottivakkam Bus Stop corridor. Commercial activity in Kottivakkam runs medium, so GST Audit Support volumes scale through peak months and we staff the Kottivakkam desk accordingly. Document pickup near Kottivakkam Beach is a same-hour errand for our Kottivakkam engagements rather than the half-day a typical Chennai client expects. The coastal residential and it support mix of Kottivakkam shapes what lands in our workpapers — a blend of it services activity and the commercial pulse around Kottivakkam Beach.

GST Audit Support for restaurants businesses in Kottivakkam hinges on getting the sector's recurring entries right the first time. For a restaurants business in Kottivakkam, the GST Audit Support scope is rarely generic; we tailor the checklist to how that sector actually transacts. A restaurants operator in Kottivakkam gets a GST Audit Support workflow shaped by sector norms, not a one-size-fits-all template. Mixed restaurants activity across Kottivakkam means our GST Audit Support team keeps sector playbooks ready rather than improvising per client.

The Kottivakkam GST Audit Support workflow is documented end-to-end: WhatsApp document intake, a working file, qualified review, and a filed acknowledgement back to you. Turnaround for Kottivakkam GST Audit Support is deterministic — fixed fee, a scoped timeline, and a same-business-day acknowledgement once filed. A Kottivakkam client sees the same GST Audit Support cadence each cycle: intake, reconciliation, review, filing, acknowledgement. Fixed-fee scoping means a Kottivakkam business knows the GST Audit Support cost up front, with no surprise additions mid-engagement.

Serving Kottivakkam and Thiruvanmiyur from one team keeps GST Audit Support turnaround identical across the cluster. We treat Kottivakkam and Thiruvanmiyur as one catchment for GST Audit Support, which keeps documentation and turnaround consistent. GST Audit Support clients in Thiruvanmiyur are handled by the same practitioners who run our Kottivakkam desk. Group companies spread across Kottivakkam and Thiruvanmiyur consolidate their GST Audit Support under one engagement with us.

Each engagement in Kottivakkam adds to a record of what the Chennai South jurisdiction expects, sharpening the next GST Audit Support file. The GST Audit Support mistakes we see most in Kottivakkam are avoidable with disciplined intake, which our checklist enforces. Over several cycles in Kottivakkam, the recurring GST Audit Support issues cluster around a predictable short list we screen for early. Sector signals in Kottivakkam — seasonal it services swings and peak-period volumes — shape how we schedule GST Audit Support work.

Relocating a registered office into Kottivakkam (PIN 600041) changes the assessing division, and we handle that GST Audit Support transition cleanly. New restaurants ventures in Kottivakkam lean on us to stand up GST Audit Support correctly before the first deadline rather than after a notice. Shifting principal place of business to Kottivakkam means updating jurisdiction to the Chennai South, and we manage the paperwork end-to-end. A startup setting up near ECR Junction in Kottivakkam gets a GST Audit Support foundation built for the Velachery Division from day one.

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Expert Guide

GST Audit Support in Kottivakkam — Complete Guide

GST Audit Support for Kottivakkam 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 Kottivakkam, Chennai

Section 65 departmental audit and Section 66 special audit representation for Kottivakkam 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 Kottivakkam — Section 65 and Section 66 Expert

A dedicated GST audit consultant in Kottivakkam 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 Kottivakkam

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 Kottivakkam — Above ₹5 Crore Turnover

For Kottivakkam 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 Kottivakkam. WhatsApp documents — we begin within 24 hours. From ₹5,000/one-time. Free consultation.
WhatsApp for Free Consultation Call @ 9566-068-468
From ₹5,000/one-time
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Zero penalties guaranteed
Offices at Maduravoyal, Nerkundram & Nolambur (upcoming)
Key Facts — GST Audit Support in Kottivakkam
Section 65 departmental audit handled end-to-end for Kottivakkam 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 Kottivakkam 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 Kottivakkam
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.
What is the difference between ADT-02 and DRC-01?

ADT-02 is the audit-findings report under Rule 101(5) at the end of a Section 65 audit. DRC-01 is the show-cause notice issued under Section 73 or 74 read with Rule 142 to demand tax. ADT-02 findings, if disputed, mature into a DRC-01 SCN separately.

What is DRC-03 and when is it used after audit?

DRC-03 is the voluntary-payment intimation under Rule 142(2). It is used to discharge tax with interest before SCN to invoke Section 73(5) or 74(5) immunity, or to comply with ADT-02 findings. Closure follows through DRC-04 or DRC-05 as the case may be.

What is the Section 73(5) immunity post-audit?

Section 73(5) permits payment of tax with interest before any show-cause notice is issued. Where so paid through DRC-03 referencing the audit ARN, no penalty is leviable and proceedings stand closed for that amount on issue of DRC-04 by the proper officer.

Can ADT-02 findings be challenged before first appeal under Section 107?

ADT-02 itself is a finding, not a demand. The demand crystallises only through a subsequent DRC-01 SCN and the consequential DRC-07 order. First appeal under Section 107 against that order lies within three months on a ten per cent pre-deposit of disputed tax.

What is the Suncraft Energy ruling on supplier-default ITC?

Suncraft Energy Pvt Ltd v Assistant Commissioner of the Calcutta High Court holds that input tax credit available to a bona fide recipient cannot be defeated solely on supplier-side default in GSTR-1 filing or tax payment, where the recipient holds valid invoices and discharged consideration including tax.

What is the Bharti Airtel ruling relevant to audit-stage rectification?

Union of India v Bharti Airtel of the Supreme Court recognises the right to rectification of bona fide errors in GSTR-3B. The ratio is invoked at audit stage to seek directions for portal-blocked corrections through DRC-03 where the succeeding-period route under Section 39(9) has lapsed.

What Kottivakkam clients want to know before signing: For Kottivakkam engagements specifically — on the Palavakkam-Thiruvanmiyur corridor that passes through Kottivakkam.

Expert Guide

A complete walkthrough — Gst Audit Support

Reading this guide locally — Across Kottivakkam, around the Kottivakkam Beach catchment of Kottivakkam.

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

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.

Audit versus assessment versus inspection

Audit under Section 65 or 66 is conceptually distinct from assessment under Sections 61 (scrutiny of returns) and 62 (best-judgement assessment of non-filers) and from inspection / search / seizure under Section 67. Scrutiny under Section 61 is a desk-review of returns by the proper officer who issues ASMT-10 on discrepancies; the registered person responds in ASMT-11; closure or escalation follows. Audit is broader — Section 65(5) permits examination of the books, returns, statements, declarations and other documents to verify correctness of turnover declared, taxes paid, refund claimed and ITC availed, plus assessment of compliance with the Act. Inspection under Section 67 is targeted enforcement upon reason-to-believe of tax evasion and is invasive — premises access, seizure of records and goods. The OECD Forum on Tax Administration's compliance-pyramid model recommends graduated escalation from desk review to field audit to inspection, and the Indian framework broadly mirrors that design.

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.

Audit-to-DRC-01 escalation

Appellate framework — Section 107 first appeal and beyond

Where the Section 73 or 74 adjudication order under DRC-07 is adverse, the registered person's first appeal lies under Section 107 of the CGST Act before the Joint or Additional Commissioner (Appeals) within three months from the date of communication of the order, extendable by one month for sufficient cause. Pre-deposit of 10% of the disputed tax amount under Section 107(6) is the gateway requirement. Second appeal lies under Section 112 before the GST Appellate Tribunal (now operational with Principal Bench at New Delhi and State / Area Benches notified); the Section 112 pre-deposit is an additional 20% (cumulative 30%). Beyond the Tribunal, appeal lies to the High Court under Section 117 on questions of law, and to the Supreme Court under Section 118. Writ remedy under Article 226 of the Constitution before the Madras High Court is available for jurisdictional infirmities at any stage.

Section 73 versus Section 74 framing post-audit

Where audit findings are not addressed through voluntary DRC-03 payment, the proper officer issues a Show Cause Notice — DRC-01 under Section 73(1) for cases not involving fraud, wilful misstatement or suppression, and under Section 74(1) for cases involving any of those elements. The framing choice has material consequences. Section 73 attracts penalty of 10% of tax or ₹10,000 whichever is higher (Section 73(9)), with no penalty if voluntary payment is made within thirty days of SCN under Section 73(8). Section 74 attracts penalty of 100% of tax (Section 74(9)), with reduced penalty of 25% if voluntary payment is made within thirty days of SCN under Section 74(8) and 50% within thirty days of order. The extended-period limitation of five years (versus three years under Section 73) is the other material difference.

Defending Section 74 fraud framing

Where the audit-team recommends Section 74 framing, the registered person's defence focuses on the four elements — fraud, wilful misstatement, suppression of facts, or contravention with intent to evade tax. The Supreme Court's pre-GST jurisprudence on similar language in Central Excise (Pushpam Pharmaceuticals v CCE) and Service Tax (CCE v Mehta and Co) emphasised that mere non-payment or non-disclosure does not amount to suppression with intent; positive indicators of intent are needed. Bona-fide classification errors, computational mistakes, and reasonable interpretation differences are not suppression. Where the SCN frames the case under Section 74, the response should systematically address each of the four elements and rely on the documentary trail showing bona-fide compliance attempts. Pradeep Goyal (DIN requirement) and Kranti Associates (reasoned order) provide procedural safeguards.

Common audit findings

Classification and rate-of-tax disputes

The third-recurrent audit finding is classification and rate-of-tax. The GST rate structure across the rate notifications (Notification 01/2017-CT(R) and amendments, Notification 11/2017-CT(R) for services) contains thousands of HSN-and-SAC line items with rates from nil to 28%; classification borderlines are inherent. Audit-team challenges typically focus on: dual-rate items (5%/12%/18% pharmaceutical formulations, footwear, restaurants), composite versus mixed supplies under Section 8 (where the principal-supply classification determines the rate), and works-contract versus pure services classification. The Section 97 Advance Ruling mechanism offers a forward-looking certainty path; for historical classifications, the response is to cite the CBIC circulars (e.g. Circular 164/20/2021-GST on services classification clarifications) and contemporaneous trade-practice evidence.

Place-of-supply errors and IGST versus CGST/SGST

Place-of-supply errors are the fourth common finding — typically where the registered person charged CGST/SGST (intra-State) when the place of supply under Sections 10 to 13 IGST Act was inter-State (requiring IGST), or vice versa. Section 77 of the CGST Act provides a corrective mechanism — where tax was paid under one head but is actually payable under another, the wrongly-paid tax can be claimed as refund and the correctly-payable tax should be paid; the registered person is not penalised, only interest under Section 50 may apply. Audit teams sometimes overlook Section 77 and compute full short-payment additions; citing Section 77 with documented evidence of the corresponding refund-eligible head closes the issue at audit stage.

ITC mismatch between GSTR-2A / 2B and GSTR-3B

The single most common Section 65 audit finding is ITC mismatch — ITC claimed in GSTR-3B Table 4(A) exceeding ITC available in GSTR-2A or GSTR-2B for the corresponding tax period. The post-2019 regulatory tightening — Rule 36(4) initially capping un-uploaded ITC at 20%, then 10%, then 5% (Notification 75/2019-CT, 49/2019-CT, 94/2020-CT trajectory), then Section 16(2)(aa) mandating GSTR-2B as the eligibility baseline (Notification 39/2021-CT effective 1 January 2022) — has progressively tightened the mismatch tolerance to nil. Audit findings on FY 2020-21 onwards typically computes the mismatch quarter-wise; the registered person's defence rests on vendor-wise reconciliation, vendor follow-up correspondence, and the Suncraft Energy bona-fide-buyer principle where applicable.

Pre-audit preparation

Internal reconciliation walkthrough

Before the audit-team's arrival, the registered person should conduct an internal reconciliation walkthrough — replicating the audit-team's likely interrogation map. The walkthrough should cover: GSTR-1 outward supply versus books turnover; GSTR-3B Table 3.1 versus GSTR-1 invoice-summary; GSTR-3B Table 4(A) ITC claimed versus GSTR-2A / 2B vendor uploads; GSTR-9 Tables 4 to 8 versus GSTR-1 and GSTR-3B aggregates; GSTR-9C Tables 5, 7, 9, 12 to 14 versus audited financial statements. Any variance identified at the walkthrough is an opportunity for voluntary DRC-03 payment before the audit-team formalises it; voluntary disclosure during the walkthrough phase typically attracts no penalty under Section 73(5) read with Section 73(6).

Engagement of representation counsel

For audits of even moderate complexity, engagement of a representation counsel — a Chartered Accountant with GST practice depth, or a tax advocate for procedural-rights-heavy cases — is the standard professional practice. The counsel's role is to mediate communication with the audit team, draft formal responses to audit observations, attend personal hearings, and prepare voluntary-disclosure computations where applicable. The Section 116 representation framework under the CGST Act permits authorised representatives — relatives, employees, advocates, Chartered Accountants, Cost Accountants, and Company Secretaries — to appear before the proper officer. The OECD Forum on Tax Administration documents counsel-engagement as a standard taxpayer-rights practice across mature tax jurisdictions.

Mock audit by independent reviewer

For high-stake audits (multi-year audits, Section 66 special audit nominations, audits of multi-State enterprises), a mock audit by an independent reviewer — typically a former tax-department officer or a senior Chartered Accountant with audit-defence experience — is a useful preparation step. The mock auditor replicates the audit-team's risk-engine-driven interrogation, identifies weak documentary positions, and recommends remedial steps. The cost of mock audits is justified where the potential audit exposure (tax plus interest plus penalty) materially exceeds the mock-audit fee. Comparative income-tax practice has long used mock-audits for high-stake Section 143(3) scrutiny assessments and Section 142(2A) special audits; the GST extension of this practice is recent but growing.

What Kottivakkam clients usually ask next: For Kottivakkam engagements specifically — for the professional and salaried population of Kottivakkam navigating personal-tax and home-office GST.

Glossary

Plain-English glossary for this service

Personal hearing

Personal hearing under sub-section (4) of Section 75 is the opportunity granted by the proper officer or appellate authority to the registered person to present his case orally. Three adjournments at the option of the person sought to be heard are permitted on sufficient cause. Denial of personal hearing is a procedural infirmity.

Cross-examination

Cross-examination is the right of the registered person, as part of the opportunity of being heard, to examine the witnesses or officers whose statements are relied on against him in adjudication. The right is sought through a written application during personal hearing. Denial is a recognised ground in first appeal under Section 107.

Reasons to believe

Reasons to believe is the jurisdictional threshold under sub-section (1) of Section 67 for inspection, search and seizure, and is invoked also in the special-audit context. The reasons must be recorded in writing and must rest on tangible material; subjective satisfaction without material is open to challenge.

Commissioner approval

Commissioner approval is the substantive condition for invoking special audit under sub-section (1) of Section 66. The proposing officer not below the rank of Assistant Commissioner must obtain prior approval of the Commissioner before issuing the direction in ADT-03. Approval without recorded reasons is open to challenge.

Officer not below the rank

Officer not below the rank of Assistant Commissioner is the designation threshold under sub-section (1) of Section 66 for proposing the special audit. The rank requirement is a jurisdictional condition; a direction issued by a lower-ranked officer is vitiated for want of authority.

Records-availability test

Records-availability test is the practical examination at the commencement of departmental audit of whether the registered person has produced books of account, invoices, contracts and reconciliations called for in ADT-01. The test sets the date of commencement of audit under the Explanation to Section 65(4) and the ninety-day clock runs from then.

Table 4 ITC

Table 4 of GSTR-3B captures details of input tax credit. Sub-tables capture eligible ITC, ineligible ITC and reversals. Audit observations on Table 4 typically focus on mismatches between GSTR-2B-driven eligibility and credit availed in GSTR-3B, blocked credits under Section 17(5) and ITC on inward supplies under reverse charge.

Outward supply reconciliation

Outward supply reconciliation is the comparison of turnover declared in GSTR-1, turnover declared in GSTR-3B, turnover declared in GSTR-9 and turnover as per audited financial statements. The reconciliation is the focal table of GSTR-9C and is a recurring audit observation area.

Section 16(2)(aa)

Sub-clause (aa) of sub-section (2) of Section 16 of the CGST Act conditions input tax credit on the details of the invoice or debit note being furnished by the supplier in GSTR-1 and communicated to the recipient. Departmental audit observations under this provision typically address ITC availed in respect of invoices not reflected in GSTR-2B.

Section 17(5)

Sub-section (5) of Section 17 of the CGST Act lists blocked credits — motor vehicles below thirteen-seater capacity, food and beverages, club membership, works contract for immovable property and others. Audit observations on Section 17(5) frequently require itemised reconciliation of ITC against the negative list.

Reverse charge audit

Reverse charge audit is the subset of audit observations examining whether tax has been correctly paid by the recipient under sub-section (3) or (4) of Section 9 on notified supplies — goods transport agency, advocate services, sponsorship and others. The audit also tests whether ITC on RCM-paid tax has been availed only after payment of tax.

Composition audit

Composition audit is the audit of taxpayers paying tax under Section 10 of the CGST Act. The audit verifies turnover slabs, prohibited supplies (inter-State, e-commerce, ice-cream, pan masala, tobacco), maintenance of CMP filings and the rate of composition applied. CMP-08 quarterly statements and GSTR-4 annual return are the principal documents.

Cost of Non-Compliance

Real-world penalty exposure

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

ScenarioBase taxInterestPenaltyTotal
GSTR-9C self-certification not filed for FY 2021-22 by registered person above ₹5 crore aggregate turnoverNil (reconciliation only)Nil₹50,000 (₹25,000 CGST + ₹25,000 SGST under Section 47(2) capped)₹50,000
RCM on advocate fees of ₹14,00,000 under Section 9(3) not discharged across three financial years; audit-detected₹2,52,000₹68,040 (18% over 18 months)₹25,200 (10% of tax under Section 73(9) post-ADT-02)₹3,45,240
Section 17(5) blocked credit on motor vehicles ₹6,00,000 availed for two years; identified at Section 65 audit₹1,08,000₹29,160 (18% over 18 months)₹10,800 (10% of tax under Section 73(9))₹1,47,960
Table 8 GSTR-9 mismatch ₹22,00,000 between GSTR-2A and ITC availed; audit-flagged supplier-default segment₹3,96,000₹1,06,920 (18% over 18 months)₹39,600 (10% under Section 73(9) post-Suncraft defence)₹5,42,520
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

How Kottivakkam businesses typically avoid these: For Kottivakkam engagements specifically — the cluster of residential, it services, restaurants businesses that defines Kottivakkam's commercial fabric; for the professional and salaried population of Kottivakkam navigating personal-tax and home-office GST.

By Industry

Industry-specific patterns in Kottivakkam

How the local trade mix shapes this — Across Kottivakkam, the cluster of residential, it services, restaurants businesses that defines Kottivakkam's commercial fabric.

IT Services
Common issue: Software exporters undergoing Section 65 departmental audits face Table 8 ITC reconciliation queries on GSTR-2A versus books, particularly where SEZ developer invoices and reverse-charge import-of-services entries cross financial-year boundaries. The OECD International VAT/GST Guidelines treat exports as zero-rated under the destination principle, but the proper officer expects FIRC-realised consideration to tie back to invoice-month GSTR-1 disclosure within an audit-defensible bridge.
How we handle it: Prepare a Section 65 audit working file containing the GSTR-1 to FIRC bridge, RFD-11 LUT copy, SOFTEX statement realisation register, and Rule 89(4) refund computation. Map every GSTR-2A entry to vendor PAN and invoice number; preserve reverse-charge self-invoices under Section 31(3)(f) for the seven-year horizon in Section 36 read with Rule 56.
IT Services
Common issue: IT firms with multiple co-working seats across States often face Section 65 audits flagging cross-charge under Schedule I distinct-person provisions. Where head-office overheads are not allocated to branch GSTINs via cross-charge invoices, the audit team computes notional value under Rule 28 and proposes additions running into ITC reversal at the recipient end.
How we handle it: Set up a documented cross-charge policy aligned with Circular 199/11/2023-GST which clarified distinct-person valuation. Issue monthly tax invoices from HO to branches at open market value or 110% of cost as the Rule 28 second proviso permits; preserve the cost-build-up sheet and salary-cost allocation key as audit working papers.
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.
Restaurants
Common issue: Restaurant operators on Zomato / Swiggy face Section 65 audit issues on Section 9(5) e-commerce-operator collection — from 1 January 2022 (Notification 17/2017-CT(R) amendment by Notification 17/2021-CT(R)), the aggregator collects 5% GST on behalf of the restaurant. Restaurants frequently double-disclose the same revenue in GSTR-1 leading to audit-stage reconciliation issues.
How we handle it: Reconcile aggregator settlement reports (Zomato MIS, Swiggy partner statements) to restaurant GSTR-1 disclosures; ensure Section 9(5) supplies are reported under the prescribed table without duplicating output. Maintain a daily aggregator-versus-own-channel revenue split; for own-channel (dine-in, takeaway, telephone) revenue, capture in GSTR-1 directly at 5% without ITC.
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.
Case Studies

Anonymised engagements we have handled

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

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.
Table 8 reconciliation cureIT Services

Table 8D adverse finding of ₹47 lakh cured before ADT-02 by re-running the 2B match

Issue: A Tidel Park IT-services company with ₹56 crore turnover was audited under Section 65 for FY 2021-22. The audit officer flagged a Table 8D negative of ₹47 lakh in the filed GSTR-9 and proposed in a draft observation note to demand reversal under Section 74 read with Rule 86A. The earlier consultant had filed Table 8 using auto-populated 8A without rebuilding from the underlying 2B and the difference looked like ineligible credit.
Approach: We requested a fifteen-day window to file a written reply before ADT-02 was issued — this pre-ADT-02 window under Section 65(6) read with the audit manual is where the cure has to happen, because once ADT-02 lands the matter moves to Section 73/74 proceedings. We rebuilt 8A from 2B for all twelve months, isolated ₹31 lakh of supplier invoices that the 2B export-limit truncation had dropped, identified ₹14 lakh of legitimate next-FY availment that belonged in 8C, and parked the residual ₹2 lakh in 8E with a working note.
Outcome: ADT-02 was issued without the Table 8 observation; only the ₹2 lakh residual was demanded under Section 73 (normal period, no penalty); the cure saved the client roughly ₹19 lakh in proposed interest and ₹47 lakh in proposed reversal; office rule was tightened — every GSTR-9 client now gets a 2B-rebuild working file before the partner signs the engagement.
Section 17(5) cureBPO

Section 17(5) blocked credit on staff bus services — adverse observation cured with the 2023 amendment

Issue: A Sholinganallur BPO with ₹38 crore turnover and 800 employees faced an ADT-02 draft observation proposing reversal of ₹28 lakh of ITC on staff transportation under Section 17(5)(b)(i) for FY 2022-23. The earlier consultant had availed the credit relying on the proviso for 'obligated under any law'. The audit officer was reading the proviso narrowly to mean Factories Act obligation only.
Approach: We filed a written submission under Section 65(6) referencing the Tamil Nadu Shops and Establishments Act Section 14 read with the women-safety guidelines issued by the Tamil Nadu Labour Department which mandate transport for women employees on shifts ending after 8 pm. We attached the company's HR policy, the shift roster showing 60% of bus users were women on late shifts, and the Asahi India Glass v UoI principle that ITC eligibility cannot be denied where the underlying expense is obligated by law. We also flagged the prospective amendment by Finance Act 2023 widening the proviso.
Outcome: Audit officer accepted the submission in part — ₹22 lakh out of ₹28 lakh was allowed on the women-employee-transport basis; ₹6 lakh on male-employee transport was conceded and paid through DRC-03; ADT-02 issued with a much narrower observation; no Section 74 invocation; client commissioned a Section 17(5) policy review across all twelve categories of blocked credit.
Diya AgenciesHardware trading

Diya Agencies principle extended at Section 65 audit for a {{area_name}} hardware trader

Issue: A hardware-trading firm in {{area_name}} faced an ADT-01 audit covering two financial years with proposed credit reversal of approximately nine lakh rupees on supplier-side default. The audit team treated GSTR-2B absence as conclusive without testing the recipient's documentary trail.
Approach: We anchored the reply on the Madras High Court ratio in the Tvl Diya Agencies matter, which holds that supplier-side lapses cannot, in isolation, defeat recipient credit absent an enquiry against the supplier and a recorded finding on the recipient's good faith. Supplier-level enquiry trails and banking-channel payment evidence were filed.
Outcome: ADT-02 confined the reversal to seventy-eight thousand rupees relating to two genuinely missing suppliers; the residual eight lakh rupees was preserved; the matter closed within five months without DRC-01.

Why these Kottivakkam engagements look the way they do: For Kottivakkam engagements specifically — the cluster of residential, it services, restaurants businesses that defines Kottivakkam's commercial fabric; for the professional and salaried population of Kottivakkam navigating personal-tax and home-office GST.

Client Reviews

What Kottivakkam 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 — Kottivakkam

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

Yes. ADT-02 must record findings with reasons; Section 66(6) expressly mandates a hearing opportunity before special audit material is used in proceedings; and any DRC-01 SCN must give 30 days for DRC-06 reply with personal hearing. Courts have consistently set aside audit-driven demands where the taxpayer was not given proper opportunity to be heard.
Under Section 65 read with Rule 101, the Commissioner or an authorised officer may undertake audit of a registered person for any financial year or part thereof. ADT-01 notice is issued at least 15 working days before commencement. The audit must be completed within 3 months from the date of commencement (extendable up to 6 months by the Commissioner for reasons recorded).
Your engagement is handled by our in-house team led by Ravivarman R (Founder, 15+ years, 500+ engagements), with M. E. Chokkalingam on compliance and S. Jayaprakash on GST matters. You deal with named, qualified people throughout your GST Audit Support — not a call centre.
Yes. Section 66(6) requires the registered person to be given an opportunity of being heard on any material gathered in the special audit which is proposed to be used in any proceeding. After the report, if the proper officer initiates a Section 73 or 74 demand based on the findings, the registered person can contest the demand through the regular SCN-reply-adjudication-appeal route.
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.
It is simple: you share your requirement and documents over WhatsApp or email, we prepare and review the work, send it to you for approval, then complete the filing. Kottivakkam clients get the same quality remotely as in person, with an update at every step.
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 65 audit can be undertaken for any financial year or part thereof. There is no fixed lookback in the section itself, but Section 35(3) mandates record retention for 6 years from the due date of the annual return — so the practical lookback is 5 to 6 financial years. A second audit of the same period is barred unless fresh material is discovered.
Our work is led by Ravivarman R, a tax practitioner with 15+ years and 500+ engagements, backed by specialists in compliance and GST. We base every GST Audit Support recommendation on current law and your actual facts — not generic templates — and we are happy to explain the reasoning.
Section 65 audit is conducted at the principal place of business as registered in REG-06. If the audit covers transactions of branches (additional places of business), the records of those branches must be produced at the principal place or made accessible to the audit team. Kottivakkam businesses with branches outside Tamil Nadu must coordinate branch records to the audit venue.
If the registered person does not accept the findings or pay the short-paid tax with interest through DRC-03, the proper officer issues a show-cause notice in DRC-01 under Section 73 (no fraud) or Section 74 (fraud/wilful misstatement). The taxpayer then has 30 days to file DRC-06 reply. Failing satisfactory reply, an adjudication order is passed under Section 73(9) or 74(9) creating demand.
Yes. Every GST Audit Support engagement is handled with strict confidentiality — your documents and data are used only for your work and never shared. Kottivakkam clients deal with the same trusted team throughout, so your information stays in one place.
Section 65(1) gives the proper officer the power to conduct audit either at the place of business of the registered person or in the office of the proper officer. In practice for most Kottivakkam businesses the audit is conducted at the principal place of business so books, records and statutory registers can be inspected on-site.
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.
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.
Three reconciliations are pivotal — GSTR-1 vs GSTR-3B (outward supply consistency), GSTR-3B vs books (turnover and tax payment match), and GSTR-2B vs purchase register vs Table 8 of GSTR-9 (ITC eligibility). Variances are the most common audit findings, so these reconciliations should be prepared in advance and presented to the audit team in a documented format.
GST Audit Support near Kottivakkam:

We serve businesses in every part of Kottivakkam, from 1st Main Road, Kottivakkam Kuppam Road, Kuppam Beach Road, Tiruvalluvar Nagar 2nd Avenue and 10th Street to the 11th Cross Street, 11th Street, 12th Street and 14th Street commercial pockets, with GST Audit Support handled end to end.

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

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