GST Audit Services | N D Savla & Associates

GST Audit Services

GSTR Reconciliation, ITC Review, HSN Verification & Compliance Advisory — Fix GST Gaps Before the Department Does

GSTR-1 / 3B Reconciliation ITC Eligibility Review GSTR-9C Preparation RCM Compliance Section 65 Defence

Rs. 5 CrGSTR-9C Threshold

18%Interest per Annum

3–5 YrsDemand Look-back

0%Penalty on Voluntary Disclosure

100%Penalty Post-Adjudication

GST, launched 1 July 2017, has become India's most data-rich tax system. The CBIC now uses AI-driven analytics to flag ITC mismatches, turnover discrepancies, and phantom suppliers — making detection of non-compliance dramatically more likely. A proactive GST audit is no longer optional for any business with material GST transactions.

ℹ Voluntary Disclosure Advantage Under Section 73, self-correcting through voluntary payment (with interest) attracts zero penalty. Under Section 74 (fraud cases), voluntary disclosure before a show-cause notice: 25% penalty. After notice: 50%. After adjudication: 100%. Proactive audit is always the financially optimal course.

Who Needs a GST Audit?

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GSTR-9C Filers (Turnover > Rs. 5 Cr)

Self-certified GSTR-9C filers bear full personal responsibility for accuracy. An incorrect reconciliation creates significant enforcement risk. Our audit provides the analytical foundation for a defensible GSTR-9C filing.

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Large ITC Claim Businesses

Manufacturers, traders, and service providers with significant ITC — on blocked categories (Section 17(5)), 180-day reversal obligations, or GSTR-2B mismatches — face the highest enforcement risk.

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Multi-State Businesses

Multiple GSTINs, inter-GSTIN stock transfers, and complex cross-state supply chains require careful place of supply determination and ITC reconciliation across all registrations.

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Export-Oriented Units

LUT compliance, e-BRC receipt and linking, IGST refund claims, and correct treatment of input services for zero-rated supplies require specific audit attention.

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E-Commerce Sellers

TCS deducted by platforms (GSTR-8 reconciliation with GSTR-2B credits), returns and credit notes, and promotional discount treatment create complex GST compliance challenges.

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Businesses Under GST Notice

Businesses facing ASMT-10 scrutiny notices, Section 73/74 show-cause notices, or Section 65 departmental audits need immediate, comprehensive GST audit support and representation.

Our Comprehensive GST Audit Services

GSTR-1 & GSTR-3B Reconciliation

Monthly and annual reconciliation covering timing differences, GSTR-1A amendments, credit notes, and advance receipt treatment. Every month produces a detailed variance schedule with explanations.

Books-to-Returns Turnover Reconciliation

Reconciling audited financial statement turnover with aggregate GST return turnover — covering exempt supplies, advance receipts, credit notes, and inter-GSTIN stock transfers — as required for GSTR-9C.

ITC Eligibility & Documentation Review

Systematic review of every significant ITC head against Section 16(2) conditions, Section 17(5) blocked credits, Rules 42/43 proportionate reversal, 180-day reversal tracking, and GSTR-2B reconciliation.

HSN/SAC Classification & Rate Verification

Review of all major product and service categories against CGST/IGST Rate Notifications, with advance ruling analysis for genuinely unclear classifications.

Reverse Charge Mechanism (RCM) Review

Comprehensive RCM check across legal services, GTA payments, security guard services, import of services, director services, and all other notified categories — one of the most commonly missed compliance areas.

E-Invoice & E-Way Bill Compliance

Verification that all invoices above the applicable threshold are generated through the IRP with correct IRN embedding, and that e-way bills are generated, updated, and retained correctly.

GSTR-9 & GSTR-9C Preparation

Complete preparation of GSTR-9 (annual return) and GSTR-9C (self-certified reconciliation statement), coordinated with GST return filing and filed within the prescribed due date.

Place of Supply & Cross-Border Compliance

Careful review of place of supply for all significant transaction categories — especially services to immovable property, passenger transport, events, and OIDAR services from overseas suppliers.

GST Audit Methodology — 7 Steps

Pre-Audit Data Collection & Scope Confirmation
Collect all GST returns (GSTR-1, GSTR-3B, GSTR-2B, e-way bill summaries, e-invoice data), books of account, and prior year GSTR-9/9C. Review departmental notices. Confirm scope and specific risk areas.
Turnover Completeness Check & GSTR-1 Verification
Verify all outward supplies against sales register. Check B2B invoices (GSTIN, invoice details, tax breakup), B2C categorisation, GSTR-1A amendments, and credit notes issued to customers.
GSTR-3B Tax Payment Reconciliation
Reconcile CGST, SGST, IGST, and cess paid in GSTR-3B with tax computed from sales register. Identify short or excess payment months and compute interest implications.
GSTR-2B vs ITC Claimed Reconciliation
Identify: (a) ITC in GSTR-2B not claimed — potential unclaimed ITC; (b) ITC claimed not in GSTR-2B — potentially ineligible; (c) credits from suppliers who filed nil returns or cancelled registrations.
ITC Eligibility Detailed Review
For all significant ITC heads: Section 16(2) conditions, Section 17(5) blocked credits, Rules 42/43 reversal, 180-day tracking, and capital goods ITC. Prepare ITC eligibility matrix quantifying eligible and ineligible portions.
RCM, HSN/SAC & E-Invoice Compliance Review
RCM compliance check across all applicable procurement categories, HSN/SAC classification review for all major product/service lines, and e-invoice compliance verification for applicable threshold periods.
GST Audit Report, GSTR-9 & GSTR-9C Preparation
Comprehensive report with findings by risk level (high/medium/low), quantified financial exposure (tax + 18% interest + applicable penalty), and specific remediation recommendations. GSTR-9 and GSTR-9C prepared and filed.

Sector-Specific Considerations

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Manufacturing

Capital goods ITC (Rule 43, 60-month computation), job work under Section 143 (return timelines, deemed supply risk), and GST on manufacturing scrap — frequently under-declared.

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Real Estate

Project-level GST (5%/1%/12% rates post-April 2019), ITC reversal on proportionate unsold units (Rule 42), and pre-April 2019 rate transition compliance.

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Service Sector

Place of supply for all major service categories — B2B default rule, performance-based services, intermediary services — and OIDAR services from overseas suppliers under Section 14 IGST Act.

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Import of Services (RCM)

IGST under RCM on management fees, software licences, cloud computing, consulting, and royalties from overseas parent companies — one of the most commonly missed compliance areas.

Why Choose N D Savla & Associates?

Technical currency — every CGST Act amendment, CBIC circular, notification, and significant advance ruling tracked and applied
Quantified risk assessment — each finding states the tax + interest + penalty exposure by risk level
Integrated with income tax audit — consistent turnover across GST portal, IT portal, and financial statements
Notice response & representation — ASMT-10 replies, Section 73/74 responses, Section 65 support, and appeal services through GSTAT and High Court
Scalable capability — single-GSTIN traders to multi-state manufacturing groups with Rs. 1,000+ crore turnover

Frequently Asked Questions

Is a GST audit by a CA still mandatory after FY 2020-21?

The mandatory CA-certified GST audit under Section 35(5) was abolished from FY 2020-21. However, taxpayers above Rs. 5 crore must still file self-certified GSTR-9C — bearing full personal responsibility for accuracy. Departmental audits under Section 65 remain fully operative. Voluntary GST audit ensures your GSTR-9C is accurate and defensible.

What is the difference between GSTR-9 and GSTR-9C?

GSTR-9 is the annual return summarising all supplies, ITC, and taxes paid (required for taxpayers above Rs. 2 crore). GSTR-9C is the reconciliation statement comparing GSTR-9 with audited financials (required above Rs. 5 crore). Since FY 2020-21, GSTR-9C is self-certified — the taxpayer bears full responsibility for its accuracy.

What are the most common and significant GST compliance errors?

The six most financially significant errors: (1) ITC on blocked categories under Section 17(5); (2) 180-day ITC reversal failures; (3) GSTR-1 to GSTR-3B mismatches; (4) HSN/SAC misclassification at wrong rates; (5) RCM non-payment on notified services; (6) place of supply errors in multi-state or cross-border transactions.

How far back can the GST department demand tax?

Under Section 73 (non-fraud): 3 years from the annual return due date. Under Section 74 (fraud/suppression): 5 years. A Section 65 departmental audit can cover any year within the applicable limitation period. Proactive audit for all open years is strongly advisable.

What triggers a Section 65 departmental GST audit?

High ITC-to-turnover ratios, unexplained GSTR-1/3B differences, intelligence inputs, sector-specific audit campaigns, and risk management system selection. Once triggered, the officer can examine all books and records for the selected period.

We have not filed GSTR-9 for some years — is it too late?

Late GSTR-9 attracts Rs. 50/day late fee (up to 0.04% of turnover). CBIC periodically offers amnesty schemes waiving prior year late fees. Urgent filing is strongly recommended — continuing non-filing escalates risk far more than the late fee cost. We provide complete support for prior year catch-up filings.

Schedule Your GST Audit — Eliminate Risk Before the Department Finds It

The cost of a proactive GST audit is a fraction of responding to a departmental demand with 18% interest and penalties of up to 100% of tax.

Contact Our GST Team

📞 +91 9821 832 683 | +91 9765 000 966
✉ nainitsavla@savlagroup.in
🏢 Baner Business Bay, Pune | Mon–Sat 10AM–7PM