GST Scrutiny, Appeals & Litigation Services
The Goods and Services Tax (GST) law is highly data-driven, system-oriented, and enforcement-heavy. Over the last few years, businesses have increasingly faced GST scrutiny notices, audit objections, ASMT-10 communications, and Show Cause Notices (SCNs) often triggered by system-generated reports rather than actual tax evasion.
Many GST disputes arise not because of intentional non-compliance, but due to reporting mismatches, procedural lapses, or interpretation issues. However, once a notice is issued, interest, penalties, and prolonged litigation risks escalate quickly if the matter is not handled carefully.
At Karnani & Co., Chartered Accountants, we provide GST Scrutiny, Appeals & Litigation services covering the entire dispute lifecycle from initial notice stage to appellate proceedings with a strong focus on risk containment, factual clarity, and legal defensibility.
Understanding GST Disputes & Litigation
GST disputes commonly arise due to:
System-based scrutiny using GSTR-2B, GSTR-3B, and return analytics
Audit observations by CGST / SGST authorities
Alleged excess availment or mismatch of Input Tax Credit (ITC)
Classification, valuation, or rate interpretation issues
Procedural lapses treated as substantive violations
Delayed or retrospective issuance of notices
Once initiated, GST proceedings often move rapidly from scrutiny to SCN to adjudication, leaving businesses with limited time to respond and increasing exposure to tax, interest, and penalties.
GST Scrutiny, ASMT-10 Notices & Show Cause Notices (SCN)
For most businesses, the first point of stress in GST litigation is the receipt of a scrutiny notice or Form GST ASMT-10, often followed by a Show Cause Notice proposing tax demands and penalties.
These notices frequently create confusion and anxiety, especially when the allegations appear technical, vague, or disproportionate.
Common pain points faced by businesses at this stage include:
ASMT-10 notices alleging excess ITC, short payment, or reporting mismatches based purely on portal data
Differences between GSTR-2B, GSTR-3B, and books of accounts without proper contextual analysis
System-generated allegations without appreciation of business processes or commercial realities
SCNs proposing interest and penalties mechanically, even where tax is already paid or revenue-neutral
Notices issued years after the relevant period, often with incomplete details
Uncertainty on whether the issue is procedural or substantive
Pressure to make payment during proceedings without proper adjudication
In many cases, businesses either under-reply, over-reply, or make premature payments, which later weakens their position in adjudication and appeal.
Our Assistance in GST Scrutiny & Notice Proceedings
We assist clients in handling GST scrutiny, ASMT-10 notices, and SCNs through a structured, evidence-based, and legally sound approach.
Our services at this stage include:
Detailed analysis of GST scrutiny notices and ASMT-10 communications
Identification of actual issues vs system-assumed issues
Reconciliation of ITC, tax, and turnover differences with documentary support
Drafting comprehensive replies covering both factual and legal aspects
Assistance in responding to Show Cause Notices proposing tax, interest, and penalties
Advisory on whether the issue can be resolved at notice stage or contested further
Strategic handling to protect appellate rights and avoid unnecessary escalation
Our objective at this stage is risk containment o ensure that issues are properly explained, correctly recorded, and legally defended, preventing avoidable tax demands and long-drawn litigation.
Early professional handling often makes the difference between closure and years of dispute.
GST Adjudication, Appeals & Litigation Services
Where GST issues are not resolved at the scrutiny or notice stage, proceedings move into adjudication and appellate forums. We provide end-to-end assistance at all subsequent stages of GST litigation.
1️⃣ Adjudication-Stage Assistance
Representation during adjudication proceedings
Assistance in filing replies, rejoinders, and clarifications
Advisory on pre-deposit, payment strategy, and risk exposure
2️⃣ GST Appeal Filing & Documentation
Drafting Grounds of Appeal and Statement of Facts
Compilation of reconciliations, supporting documents, and evidence
Filing appeals before the GST Appellate Authority
3️⃣ Representation Before Appellate Authorities
Preparation of written submissions and legal arguments
Assistance in hearings and appellate proceedings
Strategic handling of disputes relating to ITC, classification, valuation, and penalties
4️⃣ Advanced GST Dispute Advisory
Advisory on complex GST interpretations and recurring issues
Assistance in legacy disputes and transitional credit matters
Preventive advisory to reduce future GST exposure
Our Approach to GST Litigation
Our GST litigation approach is:
Fact-driven – supported by reconciliations and documentary evidence
Law-focused – aligned with statutory provisions and judicial precedents
Process-conscious – addressing both procedural and substantive aspects
Partner-led – senior involvement at all critical stages
We do not merely contest demands we aim for sustainable dispute resolution and long-term risk reduction.
Who We Typically Assist
Our GST Scrutiny & Litigation services are suitable for:
Manufacturing and trading businesses
Service providers and contractors
MSMEs and growing enterprises
Entities facing audits, ITC reversals, or penalty exposure
We regularly assist clients in high-value and technically complex GST matters.
Why Choose Karnani & Co.
Strong experience in GST scrutiny and litigation matters
Practical understanding of departmental audits and processes
Focus on ITC, audit, and interpretation-based disputes
Partner-driven handling of assignments
Clear, documented, and defensible approach
Our focus is on ensuring fair treatment under GST law and controlled dispute outcomes.
Frequently Asked Questions (FAQs)
I have received a GST ASMT-10 notice. Is it serious?
An ASMT-10 notice is a scrutiny notice, usually triggered by system-based mismatches such as ITC differences or reporting inconsistencies. While it is not an immediate demand, improper or casual replies often lead to Show Cause Notices and tax demands. Timely and structured response is critical at this stage.
What happens if I ignore a GST scrutiny or ASMT-10 notice?
Ignoring or delaying a reply can result in the department assuming the allegations to be correct, leading to issuance of a Show Cause Notice proposing tax, interest, and penalties. This significantly weakens the taxpayer’s position in later stages.
Can GST issues be resolved at the notice or scrutiny stage itself?
Yes, many GST issues can be resolved at the scrutiny or notice stage, provided the reply is factually accurate, properly documented, and legally sound. Early professional handling often prevents escalation into adjudication and appeals.
How much time do I have to reply to a GST Show Cause Notice?
The time limit varies depending on the notice, but GST SCNs usually prescribe short response timelines. Missing deadlines or filing incomplete replies can result in ex-parte orders and higher exposure to penalties.
What happens if an adverse GST order is passed against me?
If an adverse order is passed, the taxpayer may file an appeal before the GST Appellate Authority, subject to prescribed time limits and pre-deposit requirements. Proper documentation at earlier stages significantly improves the chances of relief in appeal.
When should I approach a professional for GST disputes?
Ideally, as soon as a notice is received. Early professional intervention helps in issue framing, documentation, and risk control, and often avoids years of litigation.
How much do a Chartered Accountant charge for GST scrutiny, ASMT-10, and litigation matters?
Fees for GST scrutiny, ASMT-10 replies, Show Cause Notices, and litigation matters depend on the nature, complexity, and stage of the proceedings. Factors such as the issues involved, volume of documentation, value of demand, and level of representation required are considered. After an initial review of the notice and facts, we communicate the scope of work and fee structure transparently before proceeding.
Speak With a Chartered Accountant
If you have received a GST scrutiny notice, ASMT-10, SCN, or adjudication order, early professional support can significantly reduce exposure and long-term risk.
📞 Contact us for a confidential discussion regarding your GST matter.