What is an ASMT-10 Notice?

Form ASMT-10 is a scrutiny notice issued by a proper officer under Section 61 read with Rule 99 of the CGST Act, 2017. It is issued when the tax authorities identify discrepancies between the data available with the department — such as data from GSTR-2A, GSTR-2B, GSTR-3B, e-Way Bill portal, or data received from third parties — and the returns filed by the taxpayer. The notice points to specific line-item discrepancies and asks the taxpayer to provide clarification or to accept the discrepancy and pay the differential tax.

An ASMT-10 is not a demand notice — it is an opportunity to explain. If you provide a satisfactory explanation, the officer is required under Section 61(2) to drop the scrutiny proceedings by issuing Form ASMT-12. If the explanation is unsatisfactory or no reply is filed, the officer can proceed to initiate Best Judgment Assessment under Section 62 (Form ASMT-14) or a formal demand under Sections 73 or 74. Acting promptly and precisely within the 30-day window is therefore critical.

Common Triggers for ASMT-10

  • Mismatch between outward supplies reported in GSTR-1 and the tax paid in GSTR-3B for the same period
  • ITC claimed in GSTR-3B exceeding ITC available as per GSTR-2B (auto-populated from suppliers' GSTR-1)
  • Turnover reported in GSTR-3B not matching e-Way Bill data or Annual Return GSTR-9
  • ITC reversal obligations under Rule 42/43 not carried out or incorrectly computed
  • RCM liability identified on inward supplies from unregistered persons not reflected in GSTR-3B
  • Tax on advances received (liability under Section 12/13) not declared in returns
  • Difference between Table 8A and Table 8C of GSTR-9 indicating excess ITC claimed versus reconciled ITC
  • Supplies made to composition dealers or exempted parties where wrong tax rate was applied
  • Export turnover or zero-rated supply mismatch with GSTR-1 Table 6A vs. shipping bill data

The CBIC January 2026 Circular — New Reconciliation Format

CBIC Circular · January 2026

The CBIC issued a circular in January 2026 prescribing a standardised reconciliation format that must be submitted alongside Form ASMT-11 wherever the discrepancy relates to ITC mismatches or turnover differences exceeding ₹5 lakh. The new format requires taxpayers to provide a period-wise, head-wise reconciliation table mapping GSTR-1, GSTR-3B, GSTR-2B, and books-of-accounts figures side by side. Officers are now directed not to accept ASMT-11 replies that do not include this reconciliation table in cases where the discrepancy threshold is met. Taxpayers who had earlier been responding with narrative-only replies should note that bare explanatory replies without the structured table may now be treated as non-compliant responses, potentially triggering escalation to Section 73/74 proceedings.

In practice, this means that even for discrepancies below the ₹5 lakh threshold, filing the reconciliation table is strongly advisable as it demonstrates good-faith compliance and reduces the risk of the officer exercising discretion to escalate. Our ASMT-11 template below has been updated to include this reconciliation table in the prescribed format.

Response Deadline

Days to Respond You must respond using Form ASMT-11 on the GST portal within 30 days of receipt of the ASMT-10 notice. Extensions may be sought by submitting a written application to the jurisdictional officer, though no statutory right to extension exists — act as early as possible.

Reply Template — ASMT-11

Use the following template as your ASMT-11 submission on the GST portal. Substitute all bracketed placeholders with your actual details. Attach supporting documents — reconciliation statements, ledgers, purchase registers, e-Way Bills, bank statements — as referenced in the template.

Form ASMT-11 — Supporting Submission
FORM ASMT-11 SUPPORTING SUBMISSION

To,
The Proper Officer,
[Jurisdictional GST Office Name]
[Office Address]

Reference: Reply to Form ASMT-10 Notice
Notice Number: [ASMT-10 Reference Number as appearing on the portal]
Notice Date: [DD/MM/YYYY]
Taxpayer Name: [Legal name of registered person as per GSTIN]
GSTIN: [Your 15-digit GSTIN]
Tax Period(s) under Scrutiny: [e.g., April 2023 to March 2024 / FY 2023–24]
Reply Date: [DD/MM/YYYY]

Dear Sir/Madam,

1. RECEIPT OF NOTICE

We are in receipt of Form ASMT-10 bearing the above reference number issued
under Rule 99 read with Section 61 of the CGST Act, 2017, pointing out
discrepancies in our returns for the above-mentioned tax period(s). We submit
this reply within the prescribed time limit and request that the proceedings
be dropped on the basis of the clarifications and documentary evidence
furnished herein.

2. DETAILS OF THE DISCREPANCY AS PER NOTICE

[Set out the discrepancy(ies) as described in the ASMT-10 notice, point by
point. For example:]

   Point A: Mismatch between outward supplies in GSTR-1 and GSTR-3B
   As per notice: Difference of ₹[amount] for the period [month/year]

   Point B: Excess ITC claimed in GSTR-3B over GSTR-2B
   As per notice: Excess ITC of ₹[amount] for the period [month/year]

3. OUR RESPONSE AND CLARIFICATION

Point A — Outward Supply Mismatch:
[Provide the specific reason. For example: "The difference of ₹[X] arises on
account of [credit notes issued / amended invoices in subsequent period /
rounding differences / B2CS adjustments / export invoices mis-classified].
We have enclosed a detailed statement (Annexure A) reconciling our GSTR-1
Table [X] and GSTR-3B Table [X] figures with our books."]

Point B — ITC Mismatch:
[Provide the specific reason. For example: "The excess ITC of ₹[X] represents
ITC that was available as per our purchase records but had not yet been
reflected in GSTR-2B because the supplier filed GSTR-1 after the cut-off
date for GSTR-2B generation for that period. The ITC has since appeared in
GSTR-2B for [subsequent month] and is fully eligible. Reconciliation is
provided in Annexure B."]

4. RECONCILIATION TABLE (As per CBIC January 2026 Circular Format)

+-----------+------------+------------+------------+------------+----------+
| Period    | GSTR-1     | GSTR-3B    | GSTR-2B    | Books of   | Variance |
|           | (Outward/  | (Tax Paid/ | (ITC Avail)| Accounts   | &        |
|           | ITC)       | ITC Claimed|            |            | Remarks  |
+-----------+------------+------------+------------+------------+----------+
| [Mon-YY]  | ₹          | ₹          | ₹          | ₹          |          |
| [Mon-YY]  | ₹          | ₹          | ₹          | ₹          |          |
| [Mon-YY]  | ₹          | ₹          | ₹          | ₹          |          |
| Total     | ₹          | ₹          | ₹          | ₹          |          |
+-----------+------------+------------+------------+------------+----------+

[Explain any residual variance in the Remarks column]

5. ACCEPTANCE OF DISCREPANCY (if any)

[If a portion of the discrepancy is accepted and tax is being paid:]
"We accept a liability of ₹[amount] in respect of [specific point] and have
paid the said amount along with applicable interest under Section 50 of the
CGST Act. Details of payment: Challan Reference No. [CRN], dated
[DD/MM/YYYY], for ₹[principal] + ₹[interest] = ₹[total]."

[If no discrepancy is accepted:]
"After thorough review of our records and the data reflected in the GSTN
portal, we respectfully submit that there is no actual tax liability arising
from the discrepancies pointed out and request that the scrutiny be dropped."

6. LIST OF DOCUMENTS ENCLOSED

Annexure A — [GSTR-1 vs. GSTR-3B reconciliation statement]
Annexure B — [GSTR-2B vs. GSTR-3B ITC reconciliation with supplier-wise
              details]
Annexure C — [Relevant invoices / credit notes / debit notes]
Annexure D — [Bank statements / payment evidence where applicable]
Annexure E — [Other supporting documents]

We request that the Proper Officer review the above submissions and the
enclosed documents in totality and drop the scrutiny proceedings by issuing
Form ASMT-12, in accordance with Section 61(2) of the CGST Act, 2017.

We remain available for any further clarification or personal hearing if
the officer deems necessary.

Yours faithfully,

[Authorised Signatory Name]
Designation: [Proprietor / Partner / Director / Authorised Representative]
On behalf of: [Legal Name of Business]
GSTIN: [GSTIN]
Date: [DD/MM/YYYY]
Contact: [Phone / Email]

[If signed by CA / Tax Professional]
[CA Name], FCA / ACA
Membership No.: [ICAI Membership Number]
Firm Name: [Firm Name]
Date: [DD/MM/YYYY]

Related GST Notices

If an ASMT-10 is not satisfactorily resolved, proceedings may escalate to the following notice types. Understanding each helps you assess the risk at every stage.