The Commissioner of State Tax, Maharashtra, has issued Administrative Instructions No. CST/DC-OSD/Adm.Instr/GST-Audit/B-68 dated 09/07/2024 regarding the conduct of GST audits. These instructions follow up on previous circulars, notably Internal Circular 04A of 2024, which introduced a revised audit framework including guidelines for desk reviews, team formation, and the Audit Monitoring Committee under the Additional Commissioner of respective zones. This framework was implemented as part of a departmental restructuring aimed at improving audit efficiency.
The instructions clarify the transition period and procedures for GST audits. For audits pertaining to the financial year 2020-21, field officers will continue to follow the old guidelines, as the revised framework from Internal Circular 04A of 2024 does not apply retroactively. It emphasizes that GST audits for FY 2020-21 completed manually outside the BO system should now be uploaded onto the BO portal using new functionalities provided for this purpose.
Looking ahead, the instructions outline that comprehensive audits for FY 2021-22 will strictly follow the new guidelines set out in Internal Circular 04A of 2024. These audits will be conducted exclusively by the newly formed audit wing to ensure uniformity and adherence to updated procedures. Moreover, the limitations period for issuing Show Cause Notices under section 73 for FY 2020-21 ends on November 30, 2024, necessitating continued adherence to earlier guidelines for audits assigned to Nodal and LTU Divisions.
These administrative instructions are intended to streamline GST audit processes, maintain consistency across audits, and facilitate a smooth transition to the new framework as mandated by the recent circulars issued by the Commissioner of State Tax, Maharashtra. Officers are instructed to report any implementation challenges to ensure effective compliance across all divisions.
Office of the
Commissioner of State Tax,
Maharashtra. 8th floor, GST
Bhavan, Mazgaon, Mumbai-10
Administrative Instructions
No. CST/DC-OSD/Adm.Instr/GST-Audit/B-68 Mumbai. Date 09 /07/2024.
Sub. Guideline about conduct of GST Audit-reg.
Ref. 1. Internal. Circular 9A of 2023 dated 21/12 /2023.
2. Internal Circular 04A of 2024 dated 24/05/2024.
1. Background:
1.1 It may he noted that revised audit framework under internal Circular 04A of 2024 issued with guidelines related to desk review, team formation and Audit Monitoring Committee under Additional Commissioner of respective Zone. These guidelines were issued considering the formation of separate audit wing as per restructure of the Department. Some field officers have raised queries about applicability of these revised audit framework.
1.2 Initially online functionality for conduct of GST Audit was not available on BO portal, therefore GST audit was required to be done outside the BO system. Thereafter, online functionality has been made available on 130 portal as well as online distribution of cases is enabled. In line with this, vide circular No 09A of 2023, it has been mandated to conduct audit by use of 130 functionality from FY 2020-21 onwards. But, distribution of centrally selected cases was done earlier to these revised guidelines. Field formation has represented that in the intervening period GST audit in few cases has been done manually.
1.3 In order ensure uniformity in conduct of audit and smooth transition following administrative instructions are hereby issued.
2. Operative Instructions:
2.1 GST Audit of cases pertaining to FY 2020-21 shall be continued as per old guidelines. Revised audit framework as per Internal Circular 04A of 2024 shall not be applicable to FY 2020-21,
2.2 Limitation period to issue Show Cause Notices under section 73 for FY 2020-21 will be ending on 30th November, 2024, therefore audit proceedings of cases assigned to Nodal 86 LTU Divisions shall be continued by the officers of these Nodal / LTU Divisions as per earlier guidelines.
2.3 In order to avoid transfer of audit proceeding in between, it has been decided that Comprehensive Audit of cases for FY 2021-22, as per new guidelines under Internal Circular 04A of 2024, shall only be done by newly formed audit wing. Present jurisdictional officers shall not proceed for audit of FY 2021-22.
2.4 In few cases for FY 2020-21 GST audit is completed (GST-ADT-02 issued) outside BO system as per earlier guidelines. In this behalf, it has been decided that GST-ADT-02 shall be uploaded on BO portal at new functionality available for upload of physical ADT-02.
These guidelines shall be followed scrupulously by all field officers and difficulties, if any, in implementation of these instructions may be informed to this office.
(Aystieish Sharma)
Commissioner of State Tax
Maharashtra
Copy to,
1. Special Commissioner of State Tax, Maharashtra.
2. All Zonal Additional Commissioner of State Tax.
3. All Joint Commissioner of State Tax, LTU/Nodal Divisions/ VAT-Adm.
4. All Joint Commissioner of State Tax (HQ), Maharashtra.
5. All Joint Commissioner of State Tax (INV).
6. Staff Officer, Office of the Commissioner of State Tax, Maharashtra.
7. Commissioner of State Tax (01A), Mumbai.
