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
Trusted GST Audit Defence · Perungudi

GST Audit Support for Perungudi (PIN 600096)

GST Audit Support delivery for it services and e-commerce firms across Perungudi — backed by a 15+ year track record

GST Audit Support for Perungudi firms under Chennai South (Mylapore Division) with WhatsApp document intake and same-day filed-acknowledgement delivery. Call 9566-068-468.

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Quick Answer

Who pays the cost of a Section 66 special audit in Perungudi, Chennai?

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.

Transparent Pricing

GST Audit Support in Perungudi — 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 Perungudi Clients Choose FilingPro

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

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.

Table 8 GSTR-9 Reconciliation

Table 8 of GSTR-9 — the reconciliation between GSTR-2A/2B and ITC availed in GSTR-3B — prepared in advance with documentary backup. Variances explained before audit team raises queries.

Section 17(5) Workings Pre-Disclosed

Motor vehicles for personal use, food and beverages, club memberships, works contract for immovable property and goods/services for personal use — all Section 17(5) blocked credits flagged and reversed in returns proactively.

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 Perungudi 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.

Key Benefits

What Perungudi Clients Get

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

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. Perungudi 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.
Multi-State GSTIN Audit Coordination
For Perungudi headquartered businesses with branches outside Tamil Nadu, GSTIN-wise records produced at the principal place of business — joint CGST + SGST audit handled under one engagement.
GSTR-9C Self-Certification Without Surprises
For Perungudi 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. Perungudi clients' audit data is never shared with third parties or used for cross-marketing.
Comparison

Section 65 (Departmental) vs Section 66 (Special)

Why this matters here — In Perungudi, the business activity radiating outward from Perungudi IT Park and nearby commercial pockets; with quick access via Perungudi Bus Stop and feeder routes connecting Perungudi to the rest of Chennai.

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

Documents for GST Audit Support

Share documents via WhatsApp to 9566-068-468. No office visit required for Perungudi 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 — In Perungudi, the cluster of it services, e-commerce, residential businesses that defines Perungudi's commercial fabric.

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.
Receipt of special audit report under Section 66(5)30 daysWritten representation and supporting documentsThe registered person should file a written representation on the report before the Commissioner initiates proceedings; opportunity of being heard under Section 66(6) must be granted before any material from the report is used against the registered person.
GSTR-9C self-certification mismatch with audit observationsOn due dateReconciliation note for recordMismatch flagged as audit observation under Rule 101(4); may escalate to Section 73 SCN if not reconciled
Aggregate turnover crosses five crore rupees during the financial year275 daysGSTR-9C reconciliation statementSelf-certified reconciliation statement must be filed along with annual return by 31 December of the year following the financial year

Deadline pressure points we see in Perungudi: On the ground in Perungudi, for Perungudi IT-services firms managing export-LUT cycles alongside payroll and TDS.

Forms Library

Forms used in this engagement

GST ADT-03Direction for special audit

Direction issued by the proper officer, with prior approval of the Commissioner, to the registered person to get his records examined and audited by a chartered accountant or cost accountant nominated by the Commissioner

Issued during scrutiny, inquiry, investigation or other proceedings at any stage Officer not below the rank of Assistant Commissioner with Commissioner approval
GST ADT-04Communication of findings of special audit

Communication by the proper officer to the registered person of the findings of the special audit conducted under Section 66; carries the nominee auditor's observations and the officer's view

After receipt of special audit report from nominee auditor Jurisdictional proper officer (officer-issued)
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)

GST Audit Support in Perungudi, Chennai 600096

Businesses registered in Perungudi share the Chennai South jurisdiction, and their statutory matters route through the same Mylapore Division each time. Perungudi is a key OMR IT-corridor locality with major IT campuses, BPOs, IT exporters and supporting hospitality. GST filings here often involve SEZ supplies, IT export refunds (Rule 89/96), and inter-state B2B services. For GST Audit Support at PIN 600096, understanding the Mylapore Division's documentation norms removes most of the friction from the process. Approvals, acknowledgements and queries for Perungudi businesses tie back to the Mylapore Division, so our GST Audit Support cadence accounts for how that office works.

Most commerce in Perungudi — invoices, expenses, purchases and statutory records — eventually surfaces in the GST Audit Support working file we maintain for clients here. The it corridor residential mix of Perungudi shapes what lands in our workpapers — a blend of it services activity and the commercial pulse around Perungudi IT Park. Commercial activity in Perungudi runs high, so GST Audit Support volumes scale through peak months and we staff the Perungudi desk accordingly. Document pickup near Perungudi IT Park is a same-hour errand for our Perungudi engagements rather than the half-day a typical Chennai client expects.

We have closed enough GST Audit Support files for hospitality firms near Perungudi to know where the department usually probes. GST Audit Support for hospitality businesses in Perungudi hinges on getting the sector's recurring entries right the first time. For a hospitality business in Perungudi, the GST Audit Support scope is rarely generic; we tailor the checklist to how that sector actually transacts. Mixed hospitality activity across Perungudi means our GST Audit Support team keeps sector playbooks ready rather than improvising per client.

Our Perungudi GST Audit Support process is built to be predictable, documented, and on time, cycle after cycle. Turnaround for Perungudi GST Audit Support is deterministic — fixed fee, a scoped timeline, and a same-business-day acknowledgement once filed. Fixed-fee scoping means a Perungudi business knows the GST Audit Support cost up front, with no surprise additions mid-engagement. Working papers for Perungudi GST Audit Support engagements stay archived and retrievable, which makes any later notice or query straightforward to answer.

Proximity to Thoraipakkam means a Perungudi engagement can extend across the locality cluster with no change in cadence. Businesses straddling Perungudi and Thoraipakkam get a single GST Audit Support point of contact rather than two. From the same Perungudi team we also serve Thoraipakkam and other nearby localities without re-onboarding clients. We treat Perungudi and Thoraipakkam as one catchment for GST Audit Support, which keeps documentation and turnaround consistent.

Common patterns in the Mylapore Division give Perungudi businesses an early-warning map we use to pre-empt GST Audit Support issues. Because we work repeatedly across Perungudi, we can benchmark a new client's GST Audit Support position against the locality norm. Patterns we track for Perungudi include it services documentation gaps, timing mismatches, and the questions the Mylapore Division tends to raise. Over several cycles in Perungudi, the recurring GST Audit Support issues cluster around a predictable short list we screen for early.

Incorporating in Perungudi comes with jurisdiction, registration and GST Audit Support steps that we sequence so nothing stalls the launch. First-time GST Audit Support for a Perungudi business is where getting the basics right saves years of cleanup later. When a Kandanchavadi business expands into Perungudi, we extend its GST Audit Support setup to PIN 600096 without disruption. Shifting principal place of business to Perungudi means updating jurisdiction to the Chennai South, and we manage the paperwork end-to-end.

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Expert Guide

GST Audit Support in Perungudi — Complete Guide

For Perungudi businesses receiving an ADT-01 audit notice under Section 65 of the CGST Act, the 15 working days notice window prescribed by Rule 101(2) is used by FilingPro to compile all 12 months of GSTR-1, GSTR-3B and GSTR-9 returns, audited financials, ITC ledger with Section 17(5) workings and e-invoice IRN logs — so the audit team finds organised, reconciled records on day one.

GST Audit Support in Perungudi, Chennai

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

A dedicated GST audit consultant in Perungudi 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 Perungudi

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 Perungudi — Above ₹5 Crore Turnover

For Perungudi 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 Perungudi. 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 Perungudi
Section 65 departmental audit handled end-to-end for Perungudi 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 Perungudi 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 Perungudi
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 professional representation permitted during a GST audit?

Yes. Section 116 permits an authorised representative including a Chartered Accountant, Cost Accountant or advocate to represent the registered person. Representation is widely used in {{area_name}} for ADT-01 audits and Section 66 special-audit coordination to ensure procedural rigour.

What is the difference between Section 65 audit and Section 66 special audit?

Section 65 is a departmental audit conducted by the proper officer at the registered person's place. Section 66 is a special audit ordered by an Assistant Commissioner directing a Commissioner-nominated Chartered Accountant or Cost Accountant to conduct the examination on specified grounds.

How much advance time does ADT-01 give the taxpayer to prepare?

Rule 101(2) prescribes a minimum buffer of fifteen working days from service of ADT-01 to the date when audit work actually starts. The buffer is used to organise records, reconcile returns and brief the authorised representative.

What is Form ADT-01 in GST?

Form ADT-01 is the audit-commencement notice issued by the proper officer under Rule 101(2) read with Section 65(3) of the CGST Act 2017. It precedes the audit and triggers the fifteen-working-day record-preparation window for the registered person.

What does Form ADT-02 set out at the close of a departmental audit?

Issued under Rule 101(5), Form ADT-02 documents the proper officer's conclusions on alleged short paid tax, ineligible credit and consequential interest. The instrument is a finding only; any monetary demand thereafter is crystallised through DRC-01 under Section 73 or 74.

What is Form ADT-03 in GST?

Form ADT-03 is the order issued under Section 66(1) directing a Commissioner-nominated Chartered Accountant or Cost Accountant to conduct a special audit. It is an order, not a notice, and the nominated professional then conducts the audit on the department's behalf.

What Perungudi clients want to know before signing: On the ground in Perungudi, in the it corridor residential micro-market of Perungudi.

Expert Guide

A complete walkthrough — Gst Audit Support

Reading this guide locally — In Perungudi, in the it corridor residential micro-market of Perungudi.

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.

Section 67 inspection and its relation to audit

Audit-to-inspection escalation patterns

In practice, Section 65 audit findings escalate to Section 67 inspection where the audit team identifies indicators of deliberate evasion — fake invoicing patterns, circular trading rings, ITC claimed against suppliers whose registrations are cancelled or who have nil GSTR-3B filings (Suncraft Energy and downstream judicial line), classification mis-applications that appear deliberate. The escalation is not automatic; the proper officer must form a fresh reason-to-believe under Section 67(1) and record reasons. The Pradeep Goyal (Supreme Court on DIN — Document Identification Number for tax notices) framework requires the inspection authorisation to bear a valid DIN, failing which the action is voidable. The GKN Driveshafts (India) v ITO principle on opportunity-of-being-heard before invasive action is occasionally invoked but its application in the Section 67 context is restricted.

Procedural safeguards under Section 67(2) to 67(10)

Section 67(2) requires that search and seizure shall be carried out in the manner prescribed under Rule 139; provisions of the Code of Criminal Procedure 1973 relating to search and seizure apply mutatis mutandis (Section 67(10)). Section 67(7) provides that goods so seized shall be returned within six months extendable by six months for sufficient reasons. Section 67(8) preserves the registered person's right to make copies of the seized documents. The procedural safeguards exist; the OECD Forum on Tax Administration recommends similar safeguards as part of the taxpayer-rights framework. In practice, the Bharti Airtel v UoI and Suncraft Energy v Asst Commissioner lines of authority have shaped the procedural-fairness review of Section 67 actions in writ jurisdiction before the Madras High Court and other High Courts.

Comparative framework — pre-GST excise / service tax and current GST

Pre-GST, the Central Excise Act Section 14 provided summons power, Section 18 search power, and Section 12F seizure power. Service tax under the Finance Act 1994 had similar provisions under Sections 82 (search) and 73 (recovery). The GST framework consolidates these into Section 67 with unified procedural architecture. The Empowered Committee 2009 First Discussion Paper had envisaged a single-window enforcement architecture replacing the fragmented pre-GST regime; Section 67 substantively delivers that design. Comparative OECD International VAT/GST Guidelines emphasise that enforcement powers should be calibrated to the gravity of the suspected evasion, and the Indian framework's reason-to-believe-plus-Joint-Commissioner-rank gating mechanism aligns with that principle.

Audit-to-DRC-01 escalation

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.

Limitation analysis post audit

Section 73(10) provides that the order under Section 73 shall be issued within three years from the due date for furnishing of annual return for the financial year to which the tax not paid or short paid or input tax credit wrongly availed relates; the SCN must be issued at least three months before that date (Section 73(2)). Section 74(10) provides corresponding five-year limitation. For FY 2017-18 GSTR-9 (annual return due 31 December 2018, extended dates apply), the Section 73 limitation expired in late 2021-22 (extended through various Notifications including 9/2023-CT to 31 December 2023 and further), and Section 74 limitation extends to mid-2024 onwards. Audit findings escalated beyond limitation are barred; the registered person should systematically test limitation as part of the SCN defence.

Common audit findings

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.

Reverse-charge under Sections 9(3) and 9(4) — self-invoice gaps

The second-most-common audit finding is missed reverse-charge — supplies where the recipient is liable to pay tax under Section 9(3) (notified categories — GTA without forward-charge election, legal services, sponsorship, services by directors, etc.) or Section 9(4) (supplies from unregistered to registered persons in notified categories for real-estate developers under Notification 07/2019-CT(R) read with 03/2019-CT(R)). Section 31(3)(f) requires the recipient to issue a self-invoice; many registered persons miss this step. The audit-team computes the missed output liability under reverse-charge, the corresponding ITC eligibility (subject to time-limit under Section 16(4)), and the interest under Section 50. Voluntary disclosure via DRC-03 is the standard close-out.

What Perungudi clients usually ask next: On the ground in Perungudi, for Perungudi IT-services firms managing export-LUT cycles alongside payroll and TDS.

Glossary

Plain-English glossary for this service

Aggregate turnover

Aggregate turnover is defined in clause (6) of Section 2 of the CGST Act and means the aggregate value of all taxable supplies, exempt supplies, exports of goods or services and inter-State supplies of persons having the same Permanent Account Number, computed on an all-India basis. The turnover threshold for GSTR-9C self-certification is computed on this basis.

GSTR-9

GSTR-9 is the consolidated annual return prescribed under Section 44 read with Rule 80(1). It captures outward and inward supplies, ITC availed and reversed, taxes paid and demands or refunds for the financial year. GSTR-9 is the primary statutory return on which audit observations are anchored.

GSTR-9C

GSTR-9C is the self-certified reconciliation statement prescribed under Rule 80(3) reconciling the value of supplies declared in the annual return with the audited annual financial statement. It also reconciles tax paid and input tax credit. The threshold for applicability is aggregate turnover exceeding five crore rupees during the financial year.

Table 8 reconciliation

Table 8 of GSTR-9 captures the reconciliation between ITC available as per GSTR-2A or 2B and ITC availed in GSTR-3B. The difference under Table 8D is a frequent audit observation track. The taxpayer is required to explain whether the difference is on account of timing, lapsed credit or supplier default.

Records availability for 6 years

Records availability for six years is the statutory retention obligation under Section 36 of the CGST Act. Every registered person required to maintain books of account under Section 35(1) must retain them until the expiry of seventy-two months from the due date of furnishing the annual return for the relevant year. Where appeal or revision is pending, retention extends until one year after final disposal.

Reconciliation gap on Table 8

Reconciliation gap on Table 8 is a frequent finding in GST audit. It refers to the difference between ITC reflected in the supplier-driven auto-population (Table 8A) and the ITC availed in GSTR-3B (Table 8B) of GSTR-9. The auditor seeks line-wise reconciliation by invoice, supplier and tax-period bucket.

Adverse audit finding

Adverse audit finding is an observation recorded by the proper officer in the audit notes under sub-rule (4) of Rule 101 or in the communication under ADT-02 that points to short payment of tax, erroneous refund, or wrongly availed input tax credit. It is the precursor to action under Section 73 or Section 74.

Section 65

Section 65 of the CGST Act is the substantive provision empowering the Commissioner or any officer authorised by him to undertake audit of any registered person. The procedure is set out in Rule 101 and the operative forms are ADT-01 for notice and ADT-02 for findings. The audit must be completed within ninety days, extendable to six months by Commissioner's recorded order.

Section 66

Section 66 of the CGST Act is the special audit provision. The officer not below the rank of Assistant Commissioner, with prior approval of the Commissioner, may direct the registered person to get his records audited by a chartered accountant or cost accountant nominated by the Commissioner. The procedure is set out in Rule 102.

Section 35

Section 35 of the CGST Act is the records-maintenance provision. Sub-section (1) requires every registered person to keep and maintain books of account and records at the principal place of business. Sub-section (5), now omitted with effect from 1 August 2021, earlier required mandatory audit by a chartered accountant for turnover above the prescribed threshold.

Section 36

Section 36 of the CGST Act is the records-retention provision. Every registered person required to maintain accounts under Section 35(1) must retain them until the expiry of seventy-two months from the due date of furnishing the annual return for the financial year pertaining to the records. Pending appeal or revision extends the retention period.

Section 67

Section 67 of the CGST Act is the inspection, search and seizure provision. The proper officer not below the rank of Joint Commissioner, where he has reasons to believe that tax has been suppressed or credit has been wrongly availed with intent to evade tax, may authorise inspection of places of business. Section 67 is a distinct enforcement track and is not the same as the audit jurisdiction under Section 65.

Cost of Non-Compliance

Real-world penalty exposure

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

ScenarioBase taxInterestPenaltyTotal
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
Annual reconciliation under Rule 42(2) skipped; cumulative common-credit reversal of ₹13,00,000 short for hospital₹13,00,000 (reversal)₹2,80,800 (18% over 14 months)₹1,30,000 (10% under Section 73(9))₹17,10,800
Ocean-freight RCM ₹21,00,000 demanded at audit on CIF imports; Mohit Minerals defence sustainedNil (post-defence)NilNilNil
GTA forward-charge election challenged at audit; Annexure V missing for one transitional year₹3,00,000 (on ₹25,00,000 freight)₹81,000 (18% over 18 months)₹30,000 (10% under Section 73(9))₹4,11,000
Section 50(3) interest on ineligible ITC of ₹9,00,000 utilised before reversal; audit-detected₹9,00,000 (reversal)₹1,62,000 (18% on utilisation period)₹90,000 (10% under Section 73(9))₹11,52,000

How Perungudi businesses typically avoid these: On the ground in Perungudi, the business activity radiating outward from Perungudi IT Park and nearby commercial pockets; for Perungudi IT-services firms managing export-LUT cycles alongside payroll and TDS.

By Industry

Industry-specific patterns in Perungudi

How the local trade mix shapes this — In Perungudi, the business activity radiating outward from Perungudi IT Park and nearby commercial pockets.

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.
Hospitality
Common issue: Hotel and restaurant chains face Section 65 audit issues on the dual-rate restaurant scheme (5% without ITC versus 18% with ITC for specified non-standalone restaurants per Notification 11/2017-CT(R) as amended). Mid-year scheme-switching, or restaurants within hotels charging room tariff above ₹7,500 per day, frequently leads to ITC eligibility disputes.
How we handle it: Maintain a daily room-tariff register evidencing the ₹7,500 threshold determination month-wise; lock in the restaurant scheme at financial-year start and avoid intra-year switching. For aggregator (Zomato/Swiggy) supplies under Section 9(5), reconcile aggregator-collected output GST against own GSTR-1 disclosure to avoid double-counting allegations.
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.
Plastics
Common issue: Plastic manufacturers under audit face HSN classification disputes between Chapter 39 primary forms (typically 18%) and Chapter 39 secondary moulded products (varying rates). Wrong HSN at REG-01 cascades into wrong-rate audit findings; the audit team frequently invokes Section 74 (fraud) framing rather than Section 73 where classification was clearly deliberate.
How we handle it: Obtain a contemporaneous classification opinion from a tax practitioner or seek an Advance Ruling under Section 97 for borderline HSN cases. Where classification was bona-fide but incorrect, voluntarily pay differential under DRC-03 to mitigate the Section 74 fraud framing; this typically converts the case to Section 73 with reduced penalty exposure.
Case Studies

Anonymised engagements we have handled

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

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.
Section 65(4) timelineHospitality

Three-year audit period closed in 47 days against the Section 65(4) ceiling of 90 working days

Issue: A Chennai hotel group with two GSTINs and ₹26 crore turnover received ADT-01 covering three FYs — 2019-20, 2020-21, 2021-22. The audit was scheduled to commence on 1st February. Section 65(4) caps the audit at 3 months extendable to 6 months by the Commissioner, and from our experience an audit drifting past 90 working days starts attracting deeper questioning as the officer feels pressure to justify findings. We targeted closure in under 60 working days.
Approach: We prepared an audit-management calendar — week 1 records walkthrough, week 2-3 outward and inward supply reconciliation, week 4 ITC reconciliation, week 5 RCM and blocked credit, week 6 working note on observations, week 7 ADT-02 drafting input. We delivered every requested document within 24 hours, maintained a single email chain with the audit officer, and proposed weekly Friday closure meetings. We also flagged our own adverse-finding expectations upfront so the officer was not surprised.
Outcome: ADT-02 was issued on day 47; total observations of ₹4.2 lakh across both GSTINs (mostly room-tariff classification under Notification 14/2022 for the year of the rate change); all accepted and paid through DRC-03; no Section 74 invocation; the office now uses this engagement as a template for audit-calendar planning across all departmental-audit clients.
GSTR-9C defenceHospitality

GSTR-9C reconciliation defended at audit for a {{area_name}} hospitality group

Issue: A hotel group in {{area_name}} above the five-crore aggregate turnover threshold filed GSTR-9C with a turnover reconciliation difference of approximately seven lakh rupees explained as unbilled revenue. The ADT-01 audit team proposed treating the entire difference as suppressed taxable turnover with tax of approximately one lakh twenty-six thousand rupees.
Approach: We anchored the reply on Section 13(2) time-of-supply and demonstrated that the unbilled revenue was an accounting accrual recognised under Ind AS 115 but not a supply within Section 7(1) at the cut-off. Audited financials, room-occupancy registers and the subsequent period invoices were tied line-by-line.
Outcome: ADT-02 accepted the reconciliation; no tax demand was raised on the unbilled revenue head; the matter closed without DRC-01 escalation; turnover reconciliation discipline was carried into the next year.

Why these Perungudi engagements look the way they do: On the ground in Perungudi, the business activity radiating outward from Perungudi IT Park and nearby commercial pockets; for Perungudi IT-services firms managing export-LUT cycles alongside payroll and TDS.

Client Reviews

What Perungudi 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 — Perungudi

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

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.
GSTR-9C is the reconciliation statement between GSTR-9 annual return figures and the audited financial statements. From FY 2020-21 onwards, registered persons with aggregate turnover above ₹5 crore in a financial year must self-certify and file GSTR-9C alongside GSTR-9 by 31st December of the following year. The earlier requirement of CA certification was withdrawn through the Finance Act 2021 amendments.
Our GST Audit Support fees are fixed and shared in writing before any work starts — no hourly billing and no surprises. Pricing depends on the complexity of your case, not your location, so Perungudi clients pay the same transparent rates as everyone else. See the pricing section above or call 9566-068-468 for an exact figure.
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).
Generally no. Once a Section 65 audit has been completed for a period and ADT-04 has been issued, that period cannot be re-audited under Section 65. Special audit under Section 66 is a distinct power and may be invoked separately if the Assistant Commissioner forms an opinion on incorrect valuation or excess credit. Re-opening a closed Section 65 audit requires fresh material and is exceptional.
Our Maduravoyal office on Alapakkam Main Road (opposite KVB Bank) is well connected — from Perungudi, the Perungudi Bus Stop is a handy reference point on the way. That said, GST Audit Support rarely needs a visit; most of it is done online.
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.
The Madras High Court in Tvl. Diya Agencies v. State Tax Officer (W.P. 16866/2023) and similar rulings have held that the recipient who has paid consideration with tax to the supplier and filed valid returns cannot be denied ITC merely because the supplier did not pay tax to the exchequer — provided Section 16 conditions are otherwise met. Audit teams cannot mechanically reverse ITC on this ground alone.
Yes — honest advice is the whole point. If GST Audit Support is not right for your Perungudi situation, or can safely wait, we will say so plainly rather than sell you something. That is why much of our work comes through referrals.
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.
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.
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. Perungudi clients get the same quality remotely as in person, with an update at every step.
Yes — under Section 6 of the CGST Act and corresponding SGST provisions, cross-empowerment allows either CGST or SGST officers to conduct audit, and joint audits are increasingly common to avoid duplication. Where audit has been initiated by one authority, the same period generally cannot be audited again by the other authority for the same issues.
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.
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.
Where the taxpayer accepts the findings in ADT-02, the short-paid tax along with interest under Section 50 (and any applicable penalty) is voluntarily paid through Form DRC-03 on the GST portal. Reference to the audit ARN is recorded in DRC-03. The proper officer then passes the closure order in ADT-04 noting that the matter has been settled.
GST Audit Support near Perungudi:

Our GST Audit Support clients in Perungudi are spread right across the locality — along 3rd Cross, Anna Nedunchalai, Anna Salai, Church Main street and Nagamani Adigalar Street, and through the Panchayat Main Road, School Road, Estate 1st Cross street and Estate 1st Main Road business stretches — so wherever your premises sit, expert help is close by.

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

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