✦ EXPERT GST ADVISORY
GST Consultant in Gurgaon for Registration, Return Filing & Compliance
Partner-led GST advisory that keeps your business compliant, your Input Tax Credit protected, and your notices answered, before they become penalties.
Gupta Varundeep & Co. (GVC Audit) is a Chartered Accountant firm in Gurgaon providing end-to-end GST services, registration, monthly GSTR-1 and GSTR-3B filing, GSTR-2B reconciliation, GST audits, and notice representation, for startups, MSMEs, manufacturers, exporters, and ecommerce brands across Gurgaon and Delhi NCR. Every engagement is reviewed by a qualified CA, not handed to a junior processor.
- ICAI-Registered Chartered Accountants
- 100% On-Time Return Filing Record
- Serving Startups to ₹100+ Crore Enterprises
- Partner-Reviewed Filings, Every Month
20+ Years
200+
Received Form ADT-01? The statutory clock starts when you hand over records — not when the notice arrives. Talk to us before you submit anything.
→ [PHONE]Which GST audit are you facing?
Three very different things get called a GST audit. They have different triggers, different forms and completely different risk. Start with the one that applies to you.
Annual Reconciliation
Mandatory above ₹2 crore (GSTR-9) and ₹5 crore (GSTR-9C), PAN-level. Self-certified — which means the liability for what it says is yours. Due 31 December 2026 for FY 2025-26.
Jump to: Annual reconciliation ↓Departmental Audit
Initiated by the department, selected by data analytics on your own returns. Any turnover. 15 working days' notice, 3+6 month statutory clock.
Jump to: ADT-01 defence ↓Special Audit
Ordered mid-investigation where value or credit looks wrong, and conducted by a CA the department nominates — not yours. Report in 90 days. Serious by definition.
Jump to: Special audit ↓GST audit limit for FY 2026-27 — check yourself in 10 seconds
Turnover counts PAN-level, all-India — exempt supplies, exports and stock transfers included. A Section 65 audit can reach you at any turnover.
GST audit services from [FIRM]
Four ways we take the audit off your desk — from the annual filing to the notice you hoped would never come.
GSTR-9 / GSTR-9C Annual Reconciliation
Full-year reconciliation of GSTR-1, 3B, 2B, IMS and books — including the FY 2025-26 two-rate-regime split at 22 September 2025. Shortfalls discharged via DRC-03 before filing, not discovered after.
Get your 9C reviewedSection 65 Departmental Audit Defence
ADT-01 response strategy, dated record-production trail, representation through to ADT-02 — and the pre-audit dry run that finds what the officer will find, first.
Defend your auditSection 66 Special Audit Support
Controlled liaison with the department-nominated CA/CMA, an independent parallel review, and representation at the ADT-04 hearing.
Get supportVoluntary GST Health Check
A departmental-grade internal audit before there is a notice: quantified risk register, remediation plan, and the control fixes that stop repeat findings.
Book a health checkFrom audit to defence, in six steps.
Six steps, in the order they actually happen. The sequence is the point — remediation comes before filing, never after.
GSTINs, turnover, sector, open notices. 30 minutes, no fee.
Returns, books, ledgers, e-invoice / e-way bill, IMS status.
Every difference quantified and categorised.
Discharge, reversal, or documented defence — decided deliberately.
GSTR-9C filed clean, or your position argued on the record.
So the same finding doesn't reappear next year.
FY 2025-26 GSTR-9 & GSTR-9C are due 31 December 2026 — and this year's return splits across two rate regimes. Start in October, not December.
Start nowCHECKLIST
The GST Audit Checklist we run on every engagement
The 10 reconciliations that decide your outcome — outward supply, ITC, RCM, place of supply, classification, credit notes, exports, job work, ledgers and documentation. Updated for FY 2025-26, including the 22 September rate split.
📋 Table of Contents
GST Audit Services Section 65 Departmental Audit, GSTR-9C Reconciliation & Audit Defence
The CA-certified GST audit under Section 35(5) was abolished with effect from 1 August 2021. What replaced it is harder, not easier: a self-certified GSTR-9C where the liability sits with you, and a departmental audit under Section 65 that the GST system now selects using data analytics with no turnover threshold at all. GVC Audit prepares Gurgaon and NCR businesses for both, and represents them when the ADT-01 lands. Received an ADT-01 notice? You have 15 working days before the audit begins. Call [PHONE] or request a same-day review.
What is a GST audit?
A GST audit is the examination of a registered person’s records, returns and documents to verify that turnover declared, tax paid, refund claimed and input tax credit availed are correct, and that the GST law has been complied with. It is defined in Section 2(13) of the CGST Act. Since 2021 there are two statutory GST audits, both conducted by the department, plus one annual self-certified reconciliation that most people still loosely call “the GST audit”:
| Type | Provision | Who Conducts It | Trigger / Applicability |
|---|---|---|---|
| Departmental Audit | Section 65, Rule 101 | Commissioner or an authorised GST officer (Superintendent rank or above) | Conducted on a risk-based selection. No turnover threshold applies. A notice in Form GST ADT-01 must be issued at least 15 working days before the audit begins. |
| Special Audit | Section 66, Rule 102 | Chartered Accountant (CA) or Cost Accountant nominated by the Commissioner | Ordered by an Assistant Commissioner (with prior approval of the Commissioner) during scrutiny, inquiry, or investigation where taxable value appears incorrect or Input Tax Credit (ITC) is suspected to be wrongly claimed. Direction issued in Form GST ADT-03. |
| Annual Return & Reconciliation (GSTR-9 / GSTR-9C) | Section 44, Rule 80 | The taxpayer (Self-certified) | GSTR-9 is generally applicable where aggregate turnover exceeds ₹2 crore. GSTR-9C is required where aggregate turnover exceeds ₹5 crore. Since FY 2020-21, CA certification is not required; the reconciliation statement is self-certified by the taxpayer. |
| Statutory Audit under Section 35(5) | Withdrawn | Not Applicable | Removed by the Finance Act, 2021, notified through CGST Notification No. 29/2021 dated 30 July 2021, effective from 1 August 2021. Businesses are no longer legally required to obtain CA certification for GSTR-9C under the old Section 35(5). |
GST audit limit for FY 2026-27
This is the question that causes the most confusion, so here is the direct answer.
| Obligation | Aggregate Turnover Threshold (PAN-Level, All-India) | Due Date for FY 2026–27 |
|---|---|---|
| GSTR-9 (Annual Return) | Mandatory where aggregate turnover exceeds ₹2 crore. Optional for taxpayers with aggregate turnover of ₹2 crore or below. | 31 December 2027 (unless extended by CBIC). |
| GSTR-9C (Self-Certified Reconciliation Statement) | Mandatory where aggregate turnover exceeds ₹5 crore. Filed separately for each GSTIN, while the ₹5 crore threshold is calculated on a PAN basis. | 31 December 2027. Can be filed only after successful filing of GSTR-9, as the GST portal enables GSTR-9C thereafter. |
| Departmental Audit (Section 65) | No turnover threshold. Even a business with turnover of ₹40 lakh may be selected for audit based on the department's risk parameters. | Not applicable. Initiated by the GST department at its discretion. |
| Special Audit (Section 66) | No turnover threshold. Ordered on a case-by-case basis where the department considers it necessary. | Not applicable. Initiated by the GST authorities when required. |
Be careful with the phrase “GST audit limit for FY 2026-27”
- There is no separate CA-audit limit any more. The Rs. 2 crore and Rs. 5 crore figures are filing thresholds for GSTR-9 and GSTR-9C not thresholds for an audit.
- CBIC notifies the annual-return exemption year by year (for FY 2024-25 it was done through Notification 15/2025-Central Tax). The FY 2025-26 position Rs. 2 crore and Rs. 5 crore is the current position and is expected to carry into FY 2026-27, but the FY 2026-27 notification has not been issued yet. We will update this page the day it is.
- The turnover limit protects you from a filing obligation. It does not protect you from an audit. Section 65 has no floor.
GST audit checklist
This is the checklist our team works through first in a pre-audit health check, and again when we defend a client under an ADT-01. Work through it before the department does.
1. Records the officer will call for
- GSTR-1, GSTR-1A, GSTR-3B and GSTR-2B for every month of the audit period
- GSTR-9 and GSTR-9C for the years in scope, with the working papers behind them
- Sales register and purchase register, tied to the trial balance
- Audited financial statements, trial balance, and the GST ledgers (electronic cash, credit and liability)
- All outward tax invoices, credit notes and debit notes; inward invoices supporting every credit claimed
- E-invoice IRN log and e-way bill log for the period
- ITC register with the Rule 42 / Rule 43 apportionment workings, month by month
- RCM working under Sections 9(3) and 9(4), with proof of payment and the corresponding credit
- Stock records, job-work challans (Form ITC-04), and branch/stock-transfer documentation
- Every DRC-03 filed, with the reasoning note behind it
2. Reconciliations to complete before the audit
- GSTR-1 vs GSTR-3B outward liability. Every difference needs a written reason.
- GSTR-3B vs GSTR-2B input tax credit. This is the single most litigated number in GST.
- GSTR-9 vs the monthly returns; GSTR-9C vs the audited financials.
- GST turnover vs income-tax turnover (ITR and Form 26AS / AIS). The department triangulates these.
- E-way bill value vs invoice value vs GSTR-1.
- Books ITC vs ITC actually availed with reversals and re-claims tracked separately.
3. Risk areas the officer goes to first
- Blocked credit under Section 17(5) motor vehicles, works contract, CSR spend, employee benefits
- Rule 42 reversal never computed, then reconstructed the week before the audit. Auditors look for exactly this.
- RCM on import of services, legal fees, GTA, director’s remuneration and sponsorship
- Credit notes issued but the recipient never reversed the credit
- HSN/SAC codes still carrying pre-22-September-2025 rates
- Place of supply on inter-state services a classic Gurgaon problem for firms billing Delhi and Noida clients
- IMS invoices left on deemed acceptance credit taken on invoices nobody in your team ever looked at
How a departmental GST audit actually runs (Section 65 procedure)
- Selection. The department picks you on risk score, not at random GSTR-1/3B/2B mismatches, a low tax-to-turnover ratio, heavy ITC utilisation, large refund claims, an unanswered ASMT-10, or a sector-wide drive.
- ADT-01. Intimation is issued at least 15 working days before the audit begins, listing the period, the officers and the records required.
- Commencement. The audit is treated as commencing on the later of: the date you make the called-for records available, or the date the officers begin at your premises. Not the date on the ADT-01. This matters, because it starts the clock.
- Conduct. Three months from commencement, extendable by the Commissioner by up to six further months with written reasons a hard outer limit of nine months.
- ADT-02. Findings, reasons, and your rights and obligations are communicated within 30 days of conclusion.
- Consequences. Short-paid tax, wrong refund or wrongly availed ITC leads to proceedings under Section 73, 74 or 74A. Voluntary payment via DRC-03 after ADT-02 but before the show-cause notice materially reduces the penalty.
A special audit under Section 66 runs to a different clock: direction in ADT-03, report by the nominated CA/CMA within 90 days, extendable by another 90, findings in ADT-04, and the auditor’s fee is paid by the Commissioner not by you.
What changed in 2025-26 and why audit risk went up, not down
If your last GST review was before September 2025, your exposure has changed materially.
- GST 2.0. The 56th GST Council’s rate overhaul took effect on 22 September 2025. The 12% and 28% slabs are gone; the structure is 0 / 5 / 18 / 40. Any rate master that was not re-mapped is generating incorrect invoices every day and a stale rate master is one of the most common causes of the mismatches that trigger an audit. FY 2025-26 workpapers must be split around the 22 September boundary.
- Invoice Management System (IMS). Recipients accept, reject or hold each supplier invoice before GSTR-2B is generated. No action means deemed acceptance the invoice flows into your GSTR-2B and your credit anyway. Credit you never reviewed is still credit you certified.
- GSTR-3B hard locking. Outward liability in Tables 3.1 and 3.2 has been auto-populated and locked from the July 2025 period; corrections must go through GSTR-1A before GSTR-3B is filed. ITC-side locking is expected to follow. The return has moved from “enter and adjust” to “verify before filing”.
- Three-year time bar. Returns cannot be filed after three years from their due date. Old periods close permanently and once closed, an error in them can still be assessed against you but can no longer be self-corrected by revision.
- DRC-01C. Where GSTR-3B ITC exceeds GSTR-2B ITC beyond the prescribed limit, the portal issues an automated intimation. You reply in Part B within seven days or risk being blocked from filing your next GSTR-1.
Penalties and what a bad audit actually costs
| Situation | Consequence |
|---|---|
| Short-paid tax (Non-fraud) – Section 73 / Section 74A | Tax payable + 18% interest per annum + penalty of 10% of the tax amount or ₹10,000, whichever is higher. |
| Fraud, Wilful Misstatement or Suppression – Section 74 / Section 74A | Tax payable + applicable interest + penalty up to 100% of the tax amount. Prosecution may also be initiated in serious cases. |
| Late Filing of GSTR-9 | ₹200 per day (₹100 CGST + ₹100 SGST), subject to a maximum of 0.25% of turnover in the State under each Act. |
| Late Filing of GSTR-9C | ₹200 per day, subject to the prescribed turnover-based cap. The GST portal automatically computes the applicable late fee. |
| GSTR-9C Not Filed | No separate penalty is prescribed. The general penalty under Section 125 applies, up to ₹25,000 under CGST plus ₹25,000 under SGST. |
| Wrongly Availed and Utilised Input Tax Credit (ITC) | Reversal of ITC + applicable interest + penalty. The wrongly claimed credit is also removed from the taxpayer's working capital. |
How GVC Audit helps
Pre-audit GST health check
A full reconciliation of your GST position for the years still open to audit GSTR-1 vs 3B vs 2B vs books vs financials vs income-tax turnover. You get a quantified exposure figure, a list of the corrections to make voluntarily through DRC-03 before the department finds them, and the working papers that support each one. Voluntary correction is always cheaper than a Section 73 demand.
GSTR-9 and GSTR-9C preparation
Self-certification does not mean self-service. We build the reconciliation, document every unreconciled difference with a defensible reason, compute any additional liability, and hand you a workpaper file that answers the officer’s questions before they are asked.
Section 65 audit representation
From the day the ADT-01 arrives: scoping the notice, assembling and indexing records, managing the document log, appearing before the officer, drafting the para-wise reply to ADT-02, and negotiating closure. We do not volunteer information beyond what is asked that is audit protocol, not obstruction.
Section 66 special audit and litigation support
Where a special audit has been directed, or where the audit has escalated to DRC-01A, DRC-01 or an appeal before the GST Appellate Tribunal, we run the technical defence and the documentation.
Year-round reconciliation retainer
The businesses that survive audits are the ones that reconcile monthly, clear the IMS dashboard before the 14th, and keep a standing DRC-03 file. We run that cycle for you so the annual return is a formality rather than an event.
Frequently asked questions for GST Audit Services in Gurgaon
What is a GST audit?
A GST audit is the examination of a registered person’s records, returns and documents to verify that declared turnover, taxes paid, refunds claimed and input tax credit availed are correct. Since 1 August 2021 it is conducted by the GST department under Section 65 or Section 66 of the CGST Act, not by a CA under Section 35(5).
Is GST audit compulsory?
There is no compulsory CA-certified GST audit any more. What is compulsory is GSTR-9 above Rs. 2 crore turnover and a self-certified GSTR-9C above Rs. 5 crore. A departmental audit under Section 65 is not something you opt into the department selects you, and there is no turnover threshold.
What is the GST audit limit for FY 2026-27?
For FY 2026-27 the working position is the same as FY 2025-26: GSTR-9 is mandatory above Rs. 2 crore aggregate turnover and GSTR-9C above Rs. 5 crore, both due by 31 December 2027 unless CBIC extends. The FY 2026-27 exemption notification has not been issued yet. Departmental audit under Section 65 has no turnover limit at all.
Who conducts a GST audit?
A Section 65 departmental audit is conducted by the Commissioner or an officer authorised by him, of Superintendent rank or above. A Section 66 special audit is conducted by a Chartered Accountant or Cost Accountant nominated by the Commissioner, whose fee the Commissioner pays.
What documents are required for a GST audit?
GSTR-1, GSTR-3B, GSTR-2B, GSTR-9 and 9C for the period; sales and purchase registers; audited financials and trial balance; all tax invoices, credit and debit notes; the ITC register with Rule 42/43 workings; RCM workings; e-invoice and e-way bill logs; stock and job-work records; and every DRC-03 filed.
How much notice do I get before a GST audit?
Form GST ADT-01 must be issued at least 15 working days before the audit begins. The audit itself is treated as commencing on the later of the date you produce the called-for records or the date officers start at your premises.
How long can a GST audit take?
Three months from the date of commencement, extendable by the Commissioner by up to six further months with written reasons a maximum of nine months. Findings must be communicated in Form ADT-02 within 30 days of conclusion.
Which section covers GST audit?
Section 65 of the CGST Act covers audit by tax authorities, read with Rule 101. Section 66 covers special audit, read with Rule 102. Section 35(5), which required a CA-certified audit, was withdrawn with effect from 1 August 2021.
What happens if discrepancies are found?
The officer issues Form ADT-02 with the findings. Where tax is short-paid, refund wrongly claimed or ITC wrongly availed, proceedings follow under Section 73, 74 or 74A. Paying voluntarily through DRC-03 after ADT-02 but before the show-cause notice usually reduces the penalty significantly.
Does GSTR-9C still need CA certification?
No. GSTR-9C has been self-certified since FY 2020-21. Certification by a Chartered Accountant or Cost Accountant is no longer required by law. Many businesses still engage a CA to prepare it, because self-certification transfers the risk of an error from the auditor to the taxpayer.