Library / Goods and Services Tax: The Professional's Master Guide

Appendix J: Checklists

Adapt these lists to the business and keep the working on file.

Month-end closing

  • Sales register matched with e-invoices, e-way bills and GSTR-1; corrections through GSTR-1A.
  • Advances received for services taxed; receipt vouchers issued.
  • IMS actions completed; GSTR-2B matched with purchase register; differences followed up.
  • Reverse charge liabilities (legal, director, GTA, rent, imports) computed and self-invoices issued.
  • Blocked credits excluded; rule 42 and 43 reversals computed; rule 37 ageing checked.
  • Rule 86B cash payment checked; set-off order optimised.
  • GSTR-3B filed and tax paid by due date; ARN saved.

Year-end and GSTR-9

  • Turnover in books reconciled with GSTR-1, GSTR-3B and e-invoice data, State-wise.
  • ITC in books reconciled with GSTR-2B and GSTR-3B; pending invoices claimed before 30 November.
  • Credit notes of the year issued and declared before 30 November.
  • Rule 37A check of suppliers not filing; annual rule 42 true-up.
  • Unbilled revenue and advances reviewed at year-end.
  • GSTR-9 tables filled from reconciled data; additional liability paid through DRC-03.
  • GSTR-9C prepared where turnover exceeds Rs. 5 crore; LUT and composition options for next year filed.

New client onboarding

  • Registration certificates for all States; principal and additional places of business.
  • Last 12 months of returns, ledgers, notices and orders; pending refunds and appeals.
  • HSN and SAC codes and rates applied; exempt and reverse charge items.
  • E-invoicing and e-way bill status; QRMP or composition option.
  • Portal access, authorised signatory and a signed authorisation letter.

Due diligence for acquisitions

  • Filing status of all GSTINs; three-year bar exposure.
  • Open notices, audits, investigations and demands, with limitation dates under sections 73, 74 and 74A.
  • ITC quality: vendor compliance, section 16(2)(c) exposure, rule 37 and 37A, blocked credits.
  • Related party and cross-charge transactions, corporate guarantees, imports of services.
  • Refund claims and their risk; unjust enrichment position.
  • Transfer of ITC (ITC-02) and liability of transferee under section 85; indemnity in the agreement.

Export of services

  • Five conditions of section 2(6) of the IGST Act checked for each contract.
  • Place of supply confirmed under section 13 (default rule after 30 March 2026 for intermediaries).
  • LUT filed for the year; invoice marked "supply meant for export under LUT without payment of IGST".
  • Foreign exchange realisation tracked; FIRC or bank advice kept per invoice.
  • Refund of ITC filed within two years using rule 89(4).

ITC defence documents

  • Tax invoice, purchase order, contract and delivery challan or e-way bill.
  • Goods receipt note, transport documents, weighbridge slips where relevant.
  • Payment by banking channel; ledger of supplier; proof of GSTR-2B reflection.
  • Supplier GSTIN validity and filing status on invoice date.
  • Evidence of use in business: consumption records, photographs of assets, service reports.

Search or audit readiness

  • Nominated contact person; lawyer and consultant numbers available.
  • Statutory records at the registered place of business; backups of electronic records.
  • Staff briefed to cooperate, give true statements and ask for copies.
  • Check authorisation (INS-01) and identity of officers; note start and end time.
  • Inventory of documents and devices seized; copy of panchnama obtained.
  • No payment under pressure; any payment only after considered decision, with record that it is voluntary (Radhika Agarwal, Supreme Court, 2025).

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