Defense Studio

Act 2 · Defend — scrutiny-notice inbox · decisions made in Act 1 become defenses here

₹36L of ₹40L defended (90%)
ASMT-10ZD290726000123X· 2025-Q3 · questioning ₹40,00,000 ITC across 6 invoices
4 defensible1 caveat1 concede

One scrutiny notice is open. It questions 6 specific invoices — each defended item-wise below, then assembled into a single formal ASMT-11 reply (how a real reply is filed: one letter, item-by-item). Additional notices would appear here as they arrive.

Notice text (parsed items highlighted)
FORM GST ASMT-10
[See rule 99(1)]
Reference No: ZD290726000123X                         Date: 12/07/2026

To,
Bharat AutoComp Ltd
GSTIN: (Karnataka)
Notice for intimating discrepancies in the return after scrutiny

Sub: Scrutiny of returns for the tax period Oct 2025 – Dec 2025 (FY 2025-26, Q3) — reg.

This is to inform that during scrutiny of the returns filed by you for the tax
period referenced above, the following discrepancies have been noticed. Input Tax
Credit aggregating Rs. 40,00,000/- appears to have been availed in
contravention of the provisions of the CGST Act, 2017. You are hereby directed to
explain the discrepancies tabulated below, along with supporting documentary evidence,
within thirty days of receipt of this notice, failing which proceedings under Section 73/74
may be initiated.

Sl | Invoice No | Supplier | Amount (Rs.) | Discrepancy
1  | SF-2025-041 | Sharma Fabricators Pvt Ltd | 9,00,000 | ITC availed exceeds supplier-reported value in GSTR-2B
2  | KAV-2211 | Kaveri Auto Parts | 7,20,000 | Credit claimed on invoice not reflected in 2B for the period
3  | DEC-5590 | Deccan Rubber Works | 6,40,000 | Mismatch between GSTR-3B ITC and 2B auto-population
4  | SHK-3301 | Shakti Forgings | 5,60,000 | ITC availed on supplies where recipient GSTIN differs
5  | NAN-7742 | Nandi Plastics | 7,80,000 | Payment to supplier not evidenced within 180 days (Rule 37)
6  | GAN-1180 | Ganesh Enterprises | 4,00,000 | Goods receipt not evidenced; condition u/s 16(2)(b) unmet

                                                     (Proper Officer)
                                                     State Tax, Karnataka
SF-2025-041Sharma Fabricators Pvt Ltd
₹9,00,000Defensible

The credit of ₹9,00,000 on invoice SF-2025-041 from Sharma Fabricators Pvt Ltd is fully supported: the tax invoice, purchase order, goods receipt, the supplier's presence in GSTR-2B, and payment proof are all on record, together with the timestamped IMS decision. The discrepancy alleged does not survive the documentary chain.

Tax invoice Purchase order Goods receipt (GRN) Supplier 2B presence Payment proof IMS decision timestamp
· Sec 16(2) — all ITC conditions satisfied· Sec 16(2)(aa) — invoice reflected in 2B· Documentary evidence chain complete
KAV-2211Kaveri Auto Parts
₹7,20,000Defensible

The credit of ₹7,20,000 on invoice KAV-2211 from Kaveri Auto Parts is fully supported: the tax invoice, purchase order, goods receipt, the supplier's presence in GSTR-2B, and payment proof are all on record, together with the timestamped IMS decision. The discrepancy alleged does not survive the documentary chain.

Tax invoice Purchase order Goods receipt (GRN) Supplier 2B presence Payment proof IMS decision timestamp
· Sec 16(2) — all ITC conditions satisfied· Sec 16(2)(aa) — invoice reflected in 2B· Documentary evidence chain complete
DEC-5590Deccan Rubber Works
₹6,40,000Defensible

The credit of ₹6,40,000 on invoice DEC-5590 from Deccan Rubber Works is fully supported: the tax invoice, purchase order, goods receipt, the supplier's presence in GSTR-2B, and payment proof are all on record, together with the timestamped IMS decision. The discrepancy alleged does not survive the documentary chain.

Tax invoice Purchase order Goods receipt (GRN) Supplier 2B presence Payment proof IMS decision timestamp
· Sec 16(2) — all ITC conditions satisfied· Sec 16(2)(aa) — invoice reflected in 2B· Documentary evidence chain complete
SHK-3301Shakti Forgings
₹5,60,000Defensible

The credit of ₹5,60,000 on invoice SHK-3301 from Shakti Forgings is fully supported: the tax invoice, purchase order, goods receipt, the supplier's presence in GSTR-2B, and payment proof are all on record, together with the timestamped IMS decision. The discrepancy alleged does not survive the documentary chain.

Tax invoice Purchase order Goods receipt (GRN) Supplier 2B presence Payment proof IMS decision timestamp
· Sec 16(2) — all ITC conditions satisfied· Sec 16(2)(aa) — invoice reflected in 2B· Documentary evidence chain complete
NAN-7742Nandi Plastics
₹7,80,000Defensible (caveat)

The credit of ₹7,80,000 on invoice NAN-7742 is eligible: payment to Nandi Plastics was made on day 172 of the 180-day window under Rule 37, and proof is enclosed. The condition is met, though the timing was tight.

Tax invoice Purchase order Goods receipt (GRN) Supplier 2B presence Payment proof IMS decision timestamp
· Sec 16(2) conditions met· Rule 37 — payment made within 180 days (day 172)· Caveat: payment timing tight; proof enclosed
GAN-1180Ganesh Enterprises
₹4,00,000Concede

On invoice GAN-1180 from Ganesh Enterprises, the goods receipt is not evidenced (Sec 16(2)(b) unmet). We concede this credit of ₹4,00,000 and will reverse it with interest. ₹4,00,000 × 18% × 212/365 days = ₹41,819 interest; total payable ₹4,41,819.

Tax invoice Purchase order Goods receipt (GRN) Supplier 2B presence Payment proof IMS decision timestamp
Reversal + interest: ₹4,00,000 × 18% × 212/365 days = ₹41,819 interest; total payable ₹4,41,819 (212 days)
· Sec 16(2)(b) — goods receipt not evidenced· Credit reversed with interest under Sec 50