GST audit finalisation requires consideration of objections; notices based on non-final observations cannot validly stand.
Case-Laws
GST
GST audit commencement under the Explanation to Section 65(4) is reckoned from the later of record furnishing and on-site institution at the registered person's business premises. An audit following prior production of records therefore remains within time if completed within the statutory period measured from on-site commencement. Rule 101(4) requires the registered person to receive an opportunity to object to discrepancies and have those objections considered before audit findings are finalised. Audit observations seeking a response are not final findings and cannot properly support a show cause notice before that procedure is completed. Objections must be received and considered before fresh finalisation of the audit.
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