Complete Guide to GST ADT-01 Notice Response & Audit Filing
By Legal & GST Advisory Team at LegalDev | Qualified Chartered Accountants and Tax Advocates
with 10+ years in GST litigation, audit proceedings and notice drafting.
Form GST ADT-01 is the notice a GST officer sends to tell you that an audit of your books under
Section 65 of the CGST Act has been decided on. It gives you the financial years under audit, the
date and place of the audit, and a direction to produce your records. By law you get at least
15 working days before the audit starts, and ignoring the notice can lead to a
tax demand under Section 73, 74 or 74A.
Audit Notice Under
Section 65, Rule 101(2)
Minimum Notice Period
15 Working Days
Audit Completion
3 Months from Start
Key takeaways
ADT-01 starts a departmental audit. It is not a demand and not, by itself, an allegation of evasion.
The notice period is at least 15 working days. The audit must normally finish within 3 months of commencement.
Reconcile GSTR-1, GSTR-3B, GSTR-2B and GSTR-9 before the audit date, not during it.
Silence is the worst reply. The form itself warns that non-compliance will be taken to mean you hold no books.
If tax is found short, the officer can proceed under Section 73, 74 or 74A.
What is Form GST ADT-01? (Section 65 Overview)
Form GST ADT-01 is the prescribed notice under Rule 101(2) of the CGST Rules, issued when an
officer authorised by the Commissioner decides to audit a registered person under Section 65. The
law lets the Commissioner or an authorised officer audit any registered person, at your premises
or at the department's office.
The form has a fixed shape. It names your GSTIN and the financial year or years to be audited,
and it states where and when the officer proposes to conduct the audit. It then asks you to do
two things: give the officer facilities to verify your books, and furnish whatever information is
asked for. You can attend in person or send an authorised representative. The closing paragraph
is blunt: if you do not comply, the department will presume you hold no books and may proceed as
it sees fit.
Three things are routinely confused with it:
| Form / term |
Provision |
What it is |
| GST ADT-01 |
Section 65(3), Rule 101(2) |
Notice that a departmental audit will take place |
| GST ADT-02 |
Section 65(6), Rule 101(5) |
Audit findings, sent within 30 days of the audit's conclusion |
| GSTR-9C |
Annual return process |
Reconciliation statement you file yourself; not a departmental audit |
ADT-01 is
also unrelated to anti-profiteering. A few third-party sites describe it that way, but ADT-01 is
the audit notice. If someone has told you otherwise, check the form header on your notice. It
says "Notice for conducting audit".
Reasons for Receiving an ADT-01 GST Audit Notice
The CGST Act does not list triggers. Section 65(1) only says the Commissioner or an authorised
officer may audit a registered person, by a general or specific order. So nobody outside the
department can tell you exactly why a particular GSTIN was picked. What follows is our reading of
how these files usually come about, not a published selection formula.
The patterns we see most often:
ITC that outruns the supplier data. Input tax credit claimed in GSTR-3B sits well above what GSTR-2B shows.
Turnover that tells three stories. Figures in GSTR-1, GSTR-3B and the annual return do not agree with each other or with the financial statements.
Refund claims. Exporters and businesses with inverted duty structures get closer scrutiny because money is leaving the exchequer.
Reverse charge gaps. Payments to unregistered suppliers, legal fees, freight and rent with no matching RCM liability.
Rate and classification disputes. Goods or services taxed at a rate the department does not accept.
Unfinished earlier business. A scrutiny notice, a mismatch intimation or a previous audit that was never closed cleanly.
An ADT-01 does not mean the officer has already found something. It means your file was selected.
Many audits end with findings that are explained, corrected or dropped, provided the paperwork is
ready.
Step-by-Step Document Checklist for ADT-01 Audit
Rule 101(3) tells you what the auditor is looking at: whether turnover is correctly declared,
whether exemptions and deductions were rightly claimed, whether ITC was properly availed or
distributed, whether refunds were rightly obtained, and any other relevant issue. Build your
folder around those questions.
| Area |
What to keep ready |
Why the officer wants it |
| Registration |
Certificate, all additional places of business, authorisation letters |
To confirm which premises and which entity are in scope |
| Returns |
GSTR-1, GSTR-3B, GSTR-9, GSTR-9C (if filed), and amendments, for every audit year |
To compare declared figures year by year |
| Books of account |
Sales and purchase registers, general ledger, trial balance, audited financials |
To tie returns back to accounts |
| Sales evidence |
Tax invoices, credit and debit notes, e-invoice IRNs, e-way bills |
To test turnover and rate |
| Purchase and ITC |
Supplier invoices, GSTR-2B reconciliation, Rule 42/43 workings, Section 17(5) blocked-credit workings |
To test eligibility under Section 16 |
| RCM |
Self-invoices, payment vouchers, RCM ledger |
To check liability was discharged |
| Refunds |
Refund applications, orders, supporting statements |
To check entitlement |
| Cash and bank |
Bank statements, cash ledger, electronic credit and liability ledgers |
To trace payments |
| Contracts |
Key customer and vendor contracts, HSN/SAC basis for classification |
To justify rates and place of supply |
Three habits make this folder useful rather than just heavy.
Reconcile before you hand anything over. A clean three-way match of GSTR-1, GSTR-3B and books, plus a GSTR-2B to ITC reconciliation, answers most questions before they are asked. If you want help building these, our team handles GSTR-1, 3B and 2B reconciliation as a standalone job.
Index everything. A numbered index with page references lets a junior officer find a document in seconds, and officers who find things quickly ask fewer follow-up questions.
Keep originals and copies separate, and note what you hand over and when. If a dispute later turns on whether a document was produced, a dated acknowledgement settles it.
Time Limit and Procedure to Respond to ADT-01
You must receive the notice at least 15 working days before the audit is conducted (Section
65(3)). The audit must be completed within 3 months from commencement. The Commissioner can
extend that by up to 6 more months, but only for reasons recorded in writing. Commencement means
the date your records are made available or the audit actually begins at your premises,
whichever is later.
| Stage |
Form |
Time limit |
| Notice of audit |
ADT-01 |
At least 15 working days before the audit |
| Audit completion |
n/a |
3 months from commencement; extendable by up to 6 months |
| Findings communicated |
ADT-02 |
Within 30 days of conclusion of audit |
| Follow-up action if tax is short |
SCN / DRC-01 |
Under Section 73, 74 or 74A, with their own limitation periods |
The notice itself carries the date on which you must appear or produce records, and that date is
your working deadline. Here is the sequence we follow:
1
Read the notice line by line
Note the GSTIN, the financial years, the venue, the date and the officer's name and designation.
2
Count the working days
Check the notice date against the date it appeared on the portal. Courts have looked at exactly this. The Andhra Pradesh High Court set aside an audit where the notice reached the taxpayer without a full 15 working days. Verify the citation before relying on any decision in your own case.
3
Fix your team
Choose who will attend. An authorised representative can appear for you.
4
Ask for an adjournment if you need one
The GST portal has an adjournment request facility for ADT-01. It is discretionary, so give a concrete reason and ask early. Secondary sources describe a ceiling of one year from the notice date; check the current portal screen for the position that applies to you.
5
Reconcile and assemble the folder
Use the document checklist above.
6
Produce documents and answer queries
Answer in writing where possible, keeping a dated acknowledgement.
7
Reply to every audit observation
If you receive a draft observation or audit memo, answer it fully. In an Orissa High Court matter, the department issued draft and final reports on the same day and the court allowed the taxpayer to file a reply. Do not count on a court rescuing a missed reply.
8
Examine ADT-02
Check dates, quantification and whether your earlier submissions were considered.
Consequences of Non-Compliance or Delay in Reply
If you ignore an ADT-01, the officer can complete the audit on the material available and send
findings you never had a chance to explain. The form's own wording says it will be presumed you
hold no books. Everything after that is harder to unwind.
The realistic chain of events looks like this:
Adverse findings in ADT-02. The audit report records what the officer believes is short-paid tax or wrongly claimed credit, built on the officer's assumptions rather than your explanation.
Show cause notice. Where the audit detects tax not paid, short paid or erroneously refunded, or ITC wrongly availed or utilised, Section 65(7) allows action under Section 73, 74 or, for later periods, Section 74A. Our guide on how to reply to a DRC-01 show cause notice covers that stage.
Interest and penalty. Interest under Section 50 runs on the unpaid tax, and penalty depends on which section is invoked. Fraud-type allegations carry far heavier penalties than ordinary short payment. Check the current notified interest rate when you compute exposure.
Penalty for non-cooperation. Failing to furnish information or documents is itself a contravention, with a general penalty under Section 125 of up to ₹25,000.
Summons. The department can summon you under Section 70 to give evidence or produce documents.
Appeals at your cost. If you end up with an adverse order, your remedy is an appeal under Section 107, which generally requires a pre-deposit of part of the disputed tax. Details are in our note on GST appeal filing under Section 107.
Delay hurts for a quieter reason too. Time-bar arguments, the 15-day notice point and
extension-of-audit objections are strongest when raised promptly and on the record.
How LegalDev Assists in Handling GST Audit Notices
We are a team of Chartered Accountants and Tax Advocates, and between us we have handled GST
litigation, audit proceedings and notice drafting for more than eight years. That mix matters in
audits, because the numbers and the legal position have to line up in the same reply.
When an ADT-01 lands on your desk, here is what we do
Review the notice for validity: dates, period, signatory, service and the 15 working day requirement.
Triage your exposure. We run the reconciliations an auditor is likely to run and tell you where the soft spots are before the officer finds them.
Prepare the document set in an indexed, auditor-friendly form.
Represent you at the audit, in person or through an authorised representative, and keep the correspondence trail.
Draft replies to audit memos, observations and ADT-02 findings, with legal grounds and supporting workings.
Carry on if it escalates to a show cause notice, adjudication or appeal through our GST litigation and appeals practice, or through our broader GST notice reply services.
We do not promise outcomes, and no honest adviser can. What we can do is make sure the department
sees your case at its strongest. If you have a notice in hand, talk to our GST team with the
notice copy and the last two years of returns.
Authoritative references we rely on: the CBIC GST portal for notifications and circulars, the GST
common portal for notices and replies, and India Code for the bare Act text.
Frequently Asked Questions (FAQs)
It is the notice issued under Rule 101(2) when the department decides to audit a registered person under Section 65. It states the audit period, venue and date, and directs you to produce records.
No. ADT-01 is an audit notice. Anti-profiteering is a separate mechanism under Section 171 and uses different procedures.
No. A Section 65 audit is departmental and selective. Only registered persons chosen by the Commissioner or an authorised officer receive an ADT-01.
At least 15 working days under Section 65(3). If the notice reached you late, record the date of service and raise it in writing at the first opportunity.
Three months from commencement, extendable by up to six months by the Commissioner for reasons recorded in writing.
Yes, the GST portal provides an adjournment request for ADT-01. Approval is at the officer's discretion, so make the request early and with a specific reason.
Yes. The form allows you to attend in person or through an authorised representative. Give a written authorisation and confirm the representative's access to the portal.
No. GSTR-9C is a statement you file as part of the annual return process. An ADT-01 audit is carried out by the tax authority.
Contact the officer in writing right away, request a fresh date, and produce what you can. Do not wait for reminders. The portal can generate reminder notices, and the form warns that non-compliance can lead to proceedings without further correspondence.
Tax can be paid voluntarily using Form DRC-03, with applicable interest. Take advice first, since paying can affect how penalty is computed under later proceedings.
The officer may drop the matter or, where tax has been short paid or credit wrongly taken, initiate action under Section 73, 74 or 74A. Reply to every finding in ADT-02 as if a demand will follow.
Not on its own. It means your GSTIN has been selected for verification. Whether anything adverse is found depends on your records.