17

ASSESSMENT AND
AUDIT
The section numbers referred to in the Chapter pertain to CGST Act, unless
otherwise specified.

LEARNING OUTCOMES

After reading this chapter, you shall be equipped to:

 understand and explain the different types of assessment
which a registered person may be subjected to.
 describe the concept of self-assessment and provisional
assessment.
 identify and appreciate the different types of audit which may
be conducted against the registered person.
 gain knowledge pertaining to circumstances under which
special audit can be conducted.

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 17.2 GOODS AND SERVICES TAX

1. INTRODUCTION
What is the need for
assessment & audit ?

A supplier will come to know the extent of his tax liability which has to be
discharged on a continuous and regular basis only after assessment.
Assessment means determination of tax liability and includes self-assessment,
re-assessment, provisional assessment, summary assessment and best judgment
assessment.
GST is a trust based taxation regime wherein the assessee is required to self-
assess his returns and determine tax liability without any intervention by the tax
official. Therefore, a tax regime that relies on self-assessment has to put in place
a robust audit mechanism to measure and ensure compliance of the provisions
of law by the taxable person.
“Audit” has been defined in section 2(13) of the CGST Act, 2017 and it means
the examination of records, returns and other documents maintained or
furnished by the registered person under the GST Acts or the rules made there
under or under any other law for the time being in force to verify the correctness
of turnover declared, taxes paid, refund claimed and input tax credit availed,
and to assess his compliance with the provisions of the GST Acts or the rules
made thereunder.
Chapter XII – Assessment [Sections 59 to 64] and Chapter XIII-Audit [Section 65
& 66] of the CGST Act stipulates the provisions relating to assessment and audit
respectively. State GST laws also prescribe identical provisions in relation to
assessment and audit.
In GST, Section 59 is for self-assessment by assessee whereas section 60 stands
for provisional assessment with both assessee and departmental officer playing
their respective roles. Sections 61-64 give power to departmental officer for
assessment in different situations. Section 65 and section 66 pertains to audit
by tax authorities and by CA/CWA nominated by Commissioner respectively.
However, before going through the detailed study of Assessment and Audit
provisions, let us first go through few relevant definitions.

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 ASSESSMENT AND AUDIT 17.3

Provisions of assessment and audit under CGST Act have also been made
applicable to IGST Act vide section 20 of the IGST Act.

2. RELEVANT DEFINITIONS

 Assessment means determination of tax liability under this Act and includes
self-assessment, re-assessment, provisional assessment, summary assessment
and best judgment assessment. [Section 2(11)]

 Audit means the examination of records, returns and other documents

maintained or furnished by the registered person under this Act or the rules
made thereunder or under any other law for the time being in force to verify
the correctness of turnover declared, taxes paid, refund claimed and input tax
credit availed, and to assess his compliance with the provisions of this Act or
the rules made thereunder. [Section 2(13)]

 Chartered Accountant means a chartered accountant as defined in clause (b)

of sub-section (1) of section 2 of the Chartered Accountants Act, 1949; [Section
2(23)]

 Cost Accountant means a cost accountant as defined in clause (c) of sub-

section (1) of section 2 of the Cost and Works Accountants Act, 1959; [Section
2(35]

 Prescribed means prescribed by rules made under this Act on the

recommendations of the Council. [Section 2(87)]

 Proper Officer in relation to any function to be performed under this Act,

means the Commissioner or the officer of the central tax who is assigned that
function by the Commissioner in the Board; [Section 2(91)]

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 17.4 GOODS AND SERVICES TAX

3. SELF ASSESSMENT [SECTION 59]

Every person registered under the Act shall himself assess the tax payable by
him for a tax period and after such assessment he shall file the return required
under section 39.

4. PROVISIONAL ASSESSMENT [SECTION 60]

Situations demanding Provisional Assessment
Provisional assessment provides a method for determining the tax liability in
case the correct tax liability cannot be determined at the time of supply. The
major determinants of the tax liability are generally the applicable tax rate and
the value. There might be situations when these determinants might not be
readily ascertainable and may be subject to the outcome of a process that
requires deliberation and time.
Where the taxable person is unable to determine ─
(a) value of goods or services
or both to be supplied by
him; or
(b) the rate of tax applicable
to the goods or services
to be supplied by him,
he may furnish an application
in prescribed form stating
therein reasons for payment
of tax on a provisional basis
along with the documents in
support of his request,
electronically through the
common portal, either
directly or through a
Facilitation Centre notified by the Commissioner.
The proper officer may, on receipt of the application, issue a notice in prescribed
form requiring the registered person to furnish additional information or
documents in support of his request and the applicant shall file a reply to the
notice, and may appear in person before the said officer if he so desires.

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 ASSESSMENT AND AUDIT 17.5

The proper officer shall issue an order, allowing payment of tax on a provisional
basis indicating -
(a) the value or the rate or both on the basis of which the assessment is to be
allowed on a provisional basis, and
(b) the amount for which the bond is to be executed and security to be
furnished not exceeding 25% of the amount covered under the bond.
Furnish of Security
The payment of tax on provisional basis may be allowed, if the taxable person
executes a bond in the prescribed form along with a security in the form of a
bank guarantee for an amount as the proper officer may deem fit, binding the
taxable person for payment of the difference between the amount of tax as may
be finally assessed and the amount of tax provisionally assessed.
A bond furnished to the proper officer under the Central/State Goods and
Services Tax Act/Integrated Goods and Services Tax Act shall be deemed to be
a bond furnished under the provisions of this Act and the rules made
thereunder.
The term “amount” shall include the amount of integrated tax, central tax, State
tax or Union territory tax and cess payable in respect of such transaction.
Finalization of Provisional Assessment
The final assessment order has to be passed by the proper officer within 6
months from the date of the communication of the order of provisional
assessment. However, on sufficient cause being shown and for reasons to be
recorded in writing, the above period of 6 months may be extended:
(a) by the Joint/Additional Commissioner for a further period not exceeding
6 months, and
(b) by the Commissioner for such further period as he may deem fit not
exceeding 4 years
Thus, a provisional assessment can remain provisional for a maximum of 5
years.
For finalization of assessment, proper officer shall issue a notice in prescribed
form, calling for such information and records, as may be required and shall
issue a final assessment order specifying the amount payable by the registered
person or the amount refundable, if any.

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 17.6 GOODS AND SERVICES TAX

Where the tax liability as per the final assessment is higher than in
provisional assessment i.e. tax becomes due consequent to order of
final assessment, the registered person shall be liable to pay interest on
tax due but not paid, at the rate specified under section 50(1) from the
date the tax was due to be paid originally till the date of actual payment.
In simple words, in case any tax amount becomes payable subsequent to
finalization of the provisional assessment, then interest at the specified
rate will also be payable by the supplier from the first day after the due
date of payment of the tax till the date of actual payment, whether such
amount is paid before or after the issuance of order for final assessment.

Where the tax liability as per the final assessment is less than in
provisional assessment i.e. tax becomes refundable consequent to the
order of final assessment, the registered person shall be paid interest at
the rate specified under section 56 from the date immediately after the
expiry of 60 days from the date of receipt of application in accordance with
the provisions of Section 54(1) till the date of refund of such tax.
In simple words, in case any tax amount becomes refundable subsequent
to finalization of the provisional assessment, then interest (subject to the
eligibility of refund and absence of unjust enrichment) at the specified
rate will be payable to the supplier.
Release of Security
The applicant may file an application for release of security furnished after issue
of final assessment order.
The proper officer shall release the security after ensuring that applicant has
paid the amount specified in final assessment order and issue an order within
a period of 7 working days from the date of receipt of the application.

5. SCRUTINY OF RETURNS [SECTION 61]

Verifying the correctness of return
The return furnished by a registered person may be selected for scrutiny by
proper officer to verify its correctness. Where any return furnished by a
registered person is selected for scrutiny, the proper officer shall scrutinize the
same with reference to the information available with him.

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 ASSESSMENT AND AUDIT 17.7

Issue of notice
In case any discrepancy is found during scrutiny of return, proper officer shall
issue a notice to the said person informing him of such discrepancy and
seeking his explanation thereto within such time, not exceeding 30 days from
the date of service of the notice, or such further period as may be permitted
by him and also, where possible, quantifying the amount of tax, interest and
any other amount payable in relation to such discrepancy.
Reply to notice
The registered person to whom notice is issued may –

 accept the discrepancy as mentioned in the notice and pay the tax, interest
and any other amount arising from such discrepancy and inform the same
or furnish an explanation for the discrepancy to the proper officer or
 submit his explanation regarding non-acceptance of discrepancy within
a period of 30 days of being informed by the proper officer or such
further period as may be permitted by him.

Action by Proper Officer

Where the explanation furnished by the registered person or the information
submitted is found to be acceptable, the proper officer shall inform him
accordingly and no further action shall be taken in this regard.
In case no satisfactory explanation is furnished by registered person or where
the registered person, after accepting the discrepancies, fails to take the
corrective measure in his return for the month in which the discrepancy is
accepted, the proper officer may take recourse to any of the following
provisions, namely:
(a) proceed to conduct audit under section 65 of the Act;
(b) direct the conduct of a special audit under section 66 which is to be
conducted by a Chartered Accountant or a Cost Accountant
nominated for this purpose by the Commissioner; or
(c) undertake procedures of inspection, search and seizure under section 67
of the Act; or
(d) initiate proceeding for determination of tax and other dues under Section
73 or 74 of the Act.

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 17.8 GOODS AND SERVICES TAX

6. ASSESSMENT OF NON-FILERS OF RETURNS

[SECTION 62]
Best Judgment Assessment
Notwithstanding anything to the contrary contained in section 73 or section
74, where a registered person−
 fails to furnish the return under section 39 (monthly/quarterly) or under
section 45 (final return), and
 a notice under section 46 has been issued by proper officer to the
defaulting taxable person requiring him to furnish the return within a
period of 15 days and taxable person fails to file return within the given
time;
the proper officer may proceed to assess the tax liability of said person (i.e.
Return Defaulter) to the best of his judgement taking into account all the
relevant material which is available or which he has gathered.
Time Limit for Assessment Order
The order of Best Judgment assessment shall be issued b y Proper Officer
in the prescribed form.
The Assessment Order shall be issued by Proper Officer within a period of 5 years
from the date specified under section 44 for furnishing of the annual return for
the financial year to which the tax not paid relates.
If a person defaults in filing of return for any tax period falling in F/Y
2017-18, period of 5 years shall be reckoned from the due date of filing
of Annual Return for F/Y 2017-18 i.e. 31.12.2018. Accordingly, Best
judgment Assessment can be made by Proper Officer on or before 31.12.2023.
Withdrawal of Assessment Order
Where the registered person furnishes a valid return for the default period (i.e.
files the return and pays the tax as assessed by him) within 30 days of the
service of the assessment order, the said assessment order shall be deemed to
have been withdrawn but the liability for payment of interest under sub-
section (1) of section 50 or for payment of late fee under section 47 shall continue.

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 ASSESSMENT AND AUDIT 17.9

7. ASSESSMENT OF UNREGISTERED PERSONS

[SECTION 63]
Best Judgment Assessment
Notwithstanding anything to the contrary contained in section 73 or section
74, where a taxable person−
 fails to obtain registration even though liable to do so; or
 whose registration has been cancelled under sub-section (2) of section
29, for any of the following reason, namely––
(a) a registered person has contravened such provisions of the Act or
the rules made thereunder as may be prescribed; or
(b) a person paying tax under composition levy under section 10 has
not furnished returns for three consecutive tax periods; or
(c) any registered person, other than a person specified in clause (b),
has not furnished returns for a continuous period of six months; or
(d) any person who has taken voluntary registration under sub-section
(3) of section 25 has not commenced business within six months
from the date of registration; or

(e) registration has been obtained by means of fraud, wilful

misstatement or suppression of facts:
but who was liable to pay tax, the proper officer may proceed to assess
the tax liability of said unregistered person to the best of his judgement
for the relevant tax periods.
Issue of Notice

Before making the assessment, proper officer shall issue a notice to a taxable
person containing the grounds on which the assessment is proposed to be
made on best judgment basis and shall be given 15 days’ time to furnish his
reply, if any.
However, no such assessment order shall be passed without giving the person an
opportunity of being heard.

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 17.10 GOODS AND SERVICES TAX

Time Limit for Assessment Order

The assessment order shall be issued by proper officer within a period of 5 years
from the due date for furnishing the annual return for the financial year to
which non-payment of tax relates.
If the liability of a person to take registration arises at any time in the
F/Y 2017-18 for the reason that his turnover crosses the prescribed
threshold limit, period of 5 years shall be reckoned from the due date
of filing of Annual Return for F/Y 2017-18 i.e. 31.12.2018. Accordingly, Best
judgment Assessment can be made by proper officer on or before 31.12.2023.

8. SUMMARY ASSESSMENT IN CERTAIN

SPECIAL CASES [SECTION 64]
When Summary Assessment can be made
Summary Assessments can be initiated to protect the interest of revenue with the
previous permission of Additional Commissioner/Joint Commissioner when:
 the proper officer has evidence that a taxable person has incurred a liability
to pay tax under the Act, and
 the proper officer has sufficient grounds to believe that delay in passing
an assessment order may adversely affect the interest of revenue.
Withdrawal of Assessment Order
The Summary Assessment Order may be withdrawn by Additional
Commissioner/Joint Commissioner, –
(a) on an application filed by taxable person for withdrawal of the summary
assessment order within 30 days from the date of receipt of order; or
(b) on his own motion, where he finds such order to be erroneous and may
instead follow the procedures laid down in section 73 or section 74 to
determine the tax liability of such taxable person.
Deemed taxable person in case of supply of goods
Where the taxable person to whom the liability pertains is not ascertainable
and such liability pertains to supply of goods, the person in charge of such
goods shall be deemed to be the taxable person liable to be assessed and
liable to pay tax and any other amount due under this section.

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 ASSESSMENT AND AUDIT 17.11

When goods are under transportation or are stored in a warehouse,

and the taxable person in respect of such goods cannot be
ascertained, the person in charge of such goods shall be deemed to
be the taxable person and will be assessed to tax.

9. AUDIT BY TAX AUTHORITIES [SECTION 65]

Who may conduct the audit?
 The Commissioner; or
 Any officer authorised by him, by way of a general or a specific order,
may undertake audit of any registered person at the place of business of the
registered person or in their office for a financial year or multiples thereof.
Where it is decided to undertake the audit of a registered person, the proper
officer shall issue a notice not less than 15 working days prior to the conduct
of audit.
What is meant by commencement of audit?
The term ‘commencement of audit’ is important because audit has to be completed
within a given time frame in reference to this date of commencement.
Commencement of audit means the later of the following:
a) the date on which the records/accounts called for by the audit authorities are
made available to them, or
b) the actual institution of audit at the place of business of the taxpayer.
Time limit for completion of audit
The audit is required to be completed within 3 months from the date of
commencement of audit. The period is extendable for a further period of a
maximum of 6 months by the Commissioner.
How to conduct audit
The proper officer authorised to conduct audit of the records and books of
account of the registered person shall, with the assistance of the team of officers
and officials accompanying him, verify the documents on the basis of which the
books of account are maintained and the returns and statements furnished
under the Act and the rules made thereunder, the correctness of the turnover,
exemptions and deductions claimed, the rate of tax applied in respect of
supply of goods or services or both, the input tax credit availed and utilized,

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 17.12 GOODS AND SERVICES TAX

refund claimed, and other relevant issues and record the observations in his
audit notes.
During the course of audit, the authorised officer may require the registered
person,—
a) to facilitate the verification of accounts/records available or requisitioned
by the authorities,
b) to provide such information as the authorities may require for the conduct
of the audit, and
c) to render assistance for timely completion of the audit.
The proper officer may inform the registered person of the discrepancies
noticed, if any, as observations of the audit and the said person may file his
reply and the proper officer shall finalise the findings of the audit after due
consideration of the reply furnished.
Finalisation of Audit
The proper officer shall finalise the findings of the audit after due consideration
of the reply furnished by registered person to audit observation brought to his
notice during the course of audit.
On conclusion of audit, the proper officer shall within 30 days inform the
registered person whose records are audited, about the findings, his rights and
obligations and the reasons for such findings.
Where the audit results in detection of tax not paid or short paid or erroneously
refunded, or input tax credit wrongly availed or utilised, the proper officer may
initiate action under section 73 or section 74.

10. SPECIAL AUDIT [SECTION 66]

When Special Audit may be directed and from whom?
If at any stage of scrutiny, inquiry, investigation
or any other proceedings before him, any officer
not below the rank of Assistant Commissioner,
having regard to the nature and complexity of
the case and the interest of revenue, is of the
opinion that –
 the value has not been correctly declared; or

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 ASSESSMENT AND AUDIT 17.13

 the credit availed is not within the normal limits,

he may, with the prior approval of the Commissioner, issue a direction to the
registered person to get his records including books of account examined and
audited by a chartered accountant or a cost accountant as may be nominated
by the Commissioner and specified in the said direction.
The provisions of special audit shall have effect even if the accounts of the
registered person have been audited under any other provisions of the GST
Act or any other law for the time being in force.
Time limit within which audit to be completed
The Chartered Accountant or cost accountant as nominated by Commissioner shall
submit a report of such audit duly signed and certified by him within the period
of 90 days to the said Assistant Commissioner mentioning therein such other
particulars as may be specified:
The Assistant Commissioner may extend the said period 90 days by a further
period of 90 days −
 on an application made to him in this behalf by the registered person or the
chartered accountant or cost accountant; or
 for any material and sufficient reason.
Who will bear the expenses of audit?
The expenses of the examination and audit of records including the remuneration of
such Chartered Accountant or Cost Accountant, shall be determined and paid by
the Commissioner and such determination shall be final.
How Special Audit Report to be dealt with?
The registered person shall be given an opportunity of being heard in respect of
any material gathered on the basis of special audit which is proposed to be used
in any proceedings against him under this Act or the rules made thereunder.
On conclusion of special audit, the registered person shall be informed of the
findings of special audit.
Where the special audit results in detection of tax not paid or short paid or
erroneously refunded, or input tax credit wrongly availed or utilised, the process
of demand and recovery will be initiated against the registered person under
section 73 or section 74.

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 17.14 GOODS AND SERVICES TAX

LET US RECAPITULATE
The provisions relating to assessment and audit have been summarised by way of
diagrams to help students remember and retain the provisions in a better and
effective manner:-
Different ways to assess the tax liability by a registered person

A registered person may assess his tax liability in two different ways
depending upon the circumstances warranting such an assessment.

Provisional Self-Assessment
Assessment

Where the taxable person is In all other

unable to determine – cases
value; or
rate of tax
applicable to the goods or
services or both to be supplied
by him

For this –
• Taxable person shall furnish an application along with the
documents in support of his request.
• The proper officer after calling for additional information and
documents, if required, issue an order indicating therein-
o value or the rate or both on the basis of which the
assessment is to be allowed on a provisional basis;
o amount for which the bond is to be executed and security to be
furnished

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 ASSESSMENT AND AUDIT 17.15

Different types of assessments which may be conducted by the

department against the taxable person

There are three different type of assessments, which may be conducted by

Tax Authorities

Scrutiny Assessment Best Judgment Summary

Assessment Assessment

To make the To make the To protect the interest of

assessment on assessment of - revenue when:
selective basis
(i) Non-Filers of  the proper officer has
of taxable
Return under evidence that a taxable
person, who
section 39 person has incurred a
have filed
(monthly/quarte liability to pay tax under
return under
rly) or under
section 39. the Act, and
section 45(final
return)  the proper officer has
sufficient grounds to
(ii) Unregistered
person liable to believe that delay in
pay tax passing an assessment
order may adversely
affect the interest of
revenue.

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 17.16 GOODS AND SERVICES TAX

Assessment

Self Provisional Scrutiny of Assessment

Assessment Scrutiny
Assessment Assessment Returns of Non-filers
of Assessment in
of Return Certain Special
Unregistere
d Persons Cases
In order to
Person verify
Every
registered unable to accuracy of
determine return, the If return is
person
value of Proper Officer not Proper officer
shall Proper
supply or may examine furnished may issue an
himself officer to
rate of tax. return and even after assessment
assess tax the best of
seek service of order
liability his
explanations. notice u/s imposing tax
and Payment of judgment,
46, liability on a
furnish a tax on may issue an
person based
return. provisional assessment
on any
basis on If order, within
evidence
execution of explanation Proper a period of 5
showing a tax
bond on a offered is officer shall years from
liability.
request adequate, no assess the the date
made. further liability of specified
action. tax within a under
period of 5 section 44 If person to
Final
years from for whom
Assessment
the date furnishing liability
Time: 6 months specified u/s of the pertains is
If no annual not
from date of 44 for
adequate return. ascertainabl
communication furnishing of
explanatio e, the person
of order annual
n offered in charge of
return.
or no goods shall
Extension: 6
corrective be assessed.
months by
measures.
Joint/Additiona
l Commissioner
If order is
4 years by
Proper erroneous,
Commissioner
Action u/s proper officer
65,66,67,73 may withdraw
or 74. such order and
follow the
If short procedure laid
paid, pay If excess paid, down in section
with refund with 73 or section 74.
interest interest u/s 56
u/s 50

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 ASSESSMENT AND AUDIT 17.17

Audit

Audit by Tax Special Audit

• Commissioner or any officer • At any stage of scrutiny, inquiry

authorized by him may undertake or investigation.
audit of any registered person. • Assistant Commissioner is of
• Audit may be conducted at the the opinion that the value has
place of business or in their not been correctly declared or
office. the credit availed is not within
the normal limits
• At least 15 days prior notice
should be given • may nominate a Chartered
Accountant or Cost Accountant
• Time Period : 3 months from the
date of conduct of audit. • Time period : 90 days
• Extension : not exceeding six • Extension : further 90 days
months. • Audit will be conducted even if
• On conclusion, registered person accounts have already been
shall be informed about findings, audited.
rights & obligations. • If results in demand of tax, shall
• If results in demand of tax, shall be recovered under section 73
be recovered under section 73 or or 74.
74.

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 17.18 GOODS AND SERVICES TAX

TEST YOUR KNOWLEDGE

1. Is summary assessment order to be necessarily passed against the taxable
person?
2. Whether principal of natural justice is must to be followed before passing
assessment order against the taxable person?
3. In what cases, assessment order passed by proper officer may be withdrawn?
4. What recourse may be taken by the officer in case proper explanation is not
furnished for the discrepancy detected in the return filed, while conducting
scrutiny under section 61 of CGST ACT?
5. Who can conduct audit of taxpayers?

ANSWERS/HINTS
1. No. In certain cases, like when goods are under transportation or are stored in
a warehouse, and the taxable person in respect of such goods cannot be
ascertained, the person in charge of such goods shall be deemed to be the
taxable person and will be assessed to tax.
2. Yes, principal of natural justice is must to be followed before passing
assessment order against the taxable person seeking to impose any financial
burden on him.
3. Assessment Order passed by proper officer may be withdrawn in the following
cases:-
(i) Assessment of Non-filers of return – The best judgment order passed by
the Proper Officer under section 62 of CGST Act shall automatically stand
withdrawn if the taxable person furnishes a valid return for the default
period (i.e. files the return and pays the tax as assessed by him), within
thirty days of the receipt of the best judgment assessment order
(ii) Summary Assessment – A taxable person against whom a summary
assessment order has been passed can apply for its withdrawal to the
jurisdictional Additional/Joint Commissioner within thirty days of the date
of receipt of the order. If the said officer finds the order erroneous, he can
withdraw it and direct the proper officer to carry out determination of tax
liability in terms of section 73 or 74 of CGST Act. The Additional/Joint

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 ASSESSMENT AND AUDIT 17.19

Commissioner can follow a similar course of action on his own motion if

he finds the summary assessment order to be erroneous.
4. If the taxable person does not provide a satisfactory explanation within 30 days
of being informed (extendable by the officer concerned) or after accepting
discrepancies, fails to take corrective action in the return for the month in which
the discrepancy is accepted, the Proper Officer may take recourse to any of the
following provisions:
(a) Proceed to conduct audit under section 65 of the Act;
(b) Direct the conduct of a special audit under section 66 which is to be
conducted by a Chartered Accountant or a Cost Accountant nominated for
this purpose by the Commissioner; or
(c) Undertake procedures of inspection, search and seizure under section 67
of the Act; or
(d) Initiate proceeding for determination of tax and other dues under Section
73 or 74 of the Act.
5. There are three types of audit prescribed in the GST Act(s) as explained below:
(a) Audit by Chartered Accountant or a Cost Accountant: Every registered
person whose turnover exceeds the prescribed limit, shall get his accounts
audited by a chartered accountant or a cost accountant. (Section 35(5) of
the CGST Act)
(b) Audit by Department: The Commissioner or any officer of CGST or SGST
or UTGST authorized by him by a general or specific order, may conduct
audit of any registered person. The frequency and manner of audit will be
prescribed in due course. (Section 65 of the CGST Act)
(c) Special Audit: If at any stage of scrutiny, inquiry, investigations or any
other proceedings, if department is of the opinion that the value has not
been correctly declared or credit availed is not with in the normal limits,
department may order special audit by chartered accountant or cost
accountant, nominated by department. (Section 66 of the CGST Act)

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