Published 13 October 2026
Under GST there is no annual assessment order that closes a year. A business files its returns, pays the tax it has worked out itself, and the year stays open. Later, the department may question the figures in any of several ways: a scrutiny notice, an audit, an inquiry, an order assessing a return that was never filed, or a show cause notice. Each route has its own section, its own forms, its own time limit and its own way out. A notice is much easier to read once it is clear which of these routes it belongs to.
This guide maps the routes. Each is covered step by step in a later guide in this set, linked below.
What “assessment” means in the Act
Section 2(11) defines assessment as “determination of tax liability under this Act” and says that it “includes self-assessment, re-assessment, provisional assessment, summary assessment and best judgment assessment”. Chapter XII of the CGST Act, sections 59 to 64, provides for five kinds of assessment and for scrutiny:
| Section | What it is | Who starts it | Form of the outcome |
|---|---|---|---|
| 59 | Self-assessment | The registered person | The return itself |
| 60 | Provisional assessment | The taxable person, on request | ASMT-04 (provisional order), ASMT-07 (final order) |
| 61 | Scrutiny of returns | The proper officer | ASMT-10 (notice), ASMT-12 (acceptance) |
| 62 | Assessment of non-filers of returns | The proper officer | ASMT-13 |
| 63 | Assessment of unregistered persons | The proper officer | ASMT-14 (notice), ASMT-15 (order) |
| 64 | Summary assessment in special cases | The proper officer, with prior permission | ASMT-16 (order); ASMT-17 and ASMT-18 for withdrawal |
The forms are prescribed by rules 98, 99 and 100 of the CGST Rules. The determination of tax “not paid or short paid or erroneously refunded”, and of credit “wrongly availed or utilised”, sits outside Chapter XII. It falls under section 73 or section 74 for years up to 2023-24, and section 74A from 2024-25. Most disputes end up there.
Self-assessment is the base
Section 59 is one sentence: “Every registered person shall self-assess the taxes payable under this Act and furnish a return for each tax period as specified under section 39.” The return is the assessment. Nobody approves it, and the department reviews it only if one of the other routes is used.
Two consequences follow. First, tax a person has declared but not paid needs no further assessment. Section 75(12) provides that where “self-assessed tax in accordance with a return furnished under section 39 remains unpaid”, it “shall be recovered under the provisions of section 79”. The Explanation extends this to tax on supplies shown in GSTR-1 but left out of GSTR-3B. Second, errors in a filed return are corrected by the person in a later return, within the limits of section 39(9). Correcting Mistakes in Returns explains those limits.
The other routes, one by one
Provisional assessment (section 60). This is the only route the taxpayer starts. Where a person “is unable to determine the value of goods or services or both or determine the rate of tax applicable”, he may ask the proper officer to let him pay tax on a provisional basis, against a bond and security. A final assessment follows. The procedure is in Provisional Assessment: Section 60.
Scrutiny (section 61). The officer compares the returns with “related particulars” and with other data, and informs the person of “the discrepancies noticed”. If the explanation is accepted, “no further action shall be taken in this regard”. If it is not, the officer may order an audit, special audit or inspection, or move to a demand. See Scrutiny of Returns: ASMT-10, ASMT-11 and ASMT-12.
Assessment of non-filers (section 62). A registered person who has not filed a return under section 39 or 45, even after a notice under section 46, may be assessed “to the best of his judgement” by the officer. The order is deemed withdrawn if a valid return is later filed in time. See Best Judgment Assessment of Non-Filers: Section 62.
Assessment of unregistered persons (section 63). This covers a person who “fails to obtain registration even though liable to do so”, and one whose registration was cancelled under section 29(2) but who was liable to pay tax. A hearing is required before the order. See Assessment of Unregistered Persons: Section 63.
Summary assessment (section 64). Where there is “evidence showing a tax liability” and the officer “has sufficient grounds to believe that any delay in doing so may adversely affect the interest of revenue”, he may assess at once, with the prior permission of an Additional or Joint Commissioner. See Summary Assessment: Section 64.
Who the proper officer is
Each of these sections acts through the proper officer, the officer to whom the function is assigned under section 2(91). For officers of Central tax, CBIC’s Circular No. 3/3/2017-GST of 5 July 2017 assigns:
| Function | Officer of Central tax |
|---|---|
| Section 60(1), (2) and (3); rule 98(2) to (5) and (7) | Deputy or Assistant Commissioner |
| Section 61(1) and (3) | Superintendent |
| Section 62(1) | Superintendent |
| Section 63; rule 100(2) | Deputy or Assistant Commissioner |
| Section 64(1) | Deputy or Assistant Commissioner |
Section 64(2), on withdrawal, names the Additional or Joint Commissioner in the section itself. For demands, Circular No. 31/05/2018-GST, as amended, divides sections 73 and 74 among Superintendents, Deputy or Assistant Commissioners and Additional or Joint Commissioners by the amount involved. Circular No. 254/11/2025-GST of 27 October 2025 does the same for section 74A. Taxpayers assigned to a State administration deal with State tax officers, under the assignment orders issued under the State GST Act. Either administration acts for both taxes, CGST and SGST, under section 6.
How assessment connects to audit, investigation and demand
Scrutiny, audit and investigation are ways of finding a shortfall. Sections 73, 74 and 74A are how a shortfall is turned into a demand. The connecting words are in the Act:
- Section 61(3): where the explanation is not satisfactory, the officer “may initiate appropriate action including those under section 65 or section 66 or section 67, or proceed to determine the tax and other dues under section 73 or section 74 or section 74A”.
- Section 65(7): where an 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 or section 74A”. Section 66(6) says the same of a special audit.
- Section 64(2): where the Additional or Joint Commissioner considers a summary order “erroneous”, he may withdraw it “and follow the procedure laid down in section 73 or section 74 or section 74A”.
Sections 62 and 63 work the other way. Each opens with “Notwithstanding anything to the contrary contained in section 73 or section 74 or section 74A”. The best-judgment order is an assessment in its own right and does not need a show cause notice under those sections. The words “or section 74A” were added to sections 61 to 66 by the Finance (No. 2) Act, 2024 with effect from 1 November 2024, under Notification No. 17/2024-Central Tax.
Whether a demand can be raised without first scrutinising the return is a contested question. The High Courts’ answers are set out in the guide on scrutiny.
The later guides in this set follow the same path. Audit is covered in Departmental Audit: Section 65 and Special Audit: Section 66. The investigation powers are covered in Inspection and Search: Section 67, Seizure and Provisional Release and Summons: Section 70. The demand itself is covered in three steps. Before a Notice: DRC-01A and Paying Voluntarily deals with the stage before a notice. Replying to a Show Cause Notice, and the Hearing deals with the reply. The Order, Rectification, and the Clock for Appeal deals with the order. The law of sections 73, 74 and 74A is explained in Notices and Demands.
Time limits side by side
| Route | Limit | Provision |
|---|---|---|
| Order on a request for provisional assessment | Within 90 days of the request | Section 60(1) |
| Final assessment after provisional | Six months from communication of the provisional order; extendable by six months (Joint or Additional Commissioner) and by up to four years more (Commissioner) | Section 60(3) |
| Reply to a scrutiny notice | 30 days, or a longer period the officer allows | Section 61(3), rule 99(1) |
| Best-judgment order, non-filer or unregistered person | Five years from the due date of the annual return for the year | Sections 62(1), 63 |
| Application to withdraw a summary order | 30 days from receipt of the order | Section 64(2) |
| Departmental audit | Three months from commencement; extendable by six months | Section 65(4) |
| Special audit report | 90 days; extendable by 90 days | Section 66(2) |
| Demand order, 2017-18 to 2023-24 | Three years (section 73) or five years (section 74) from the due date of the annual return | Sections 73(10), 74(10) |
| Demand, 2024-25 onwards | Notice within 42 months of the due date of the annual return; order within 12 months of the notice, extendable by six months | Section 74A(2), (7) |
One contrast in the table is worth noticing. For 2024-25 onwards, a show cause notice under section 74A must issue within 42 months. A best-judgment order under section 62 or 63 for the same year may issue up to five years from the same starting date.
Recovery and appeal
Orders under sections 62, 63 and 64, like demand orders, are summarised in FORM GST DRC-07. Section 60 orders and the scrutiny forms are not. Rule 142(5) requires a summary of orders under sections 62, 63, 64, 73, 74 and 74A, among others, to be uploaded in DRC-07. Rule 142(6) provides that the order “shall be treated as the Notice for recovery”. Recovery then follows sections 78 and 79, as described in Recovery, and Paying in Instalments.
Any person aggrieved by “any decision or order passed under this Act” may appeal under section 107 within three months of its communication, on payment of the pre-deposit. Section 121 bars appeals only against four kinds of order. None of them is an assessment order. The appeal procedure is in Appeals and Pre-Deposit.
Rights and duties that run through every route
- To be told the basis. Rule 99(1) requires the scrutiny notice to inform the person of “such discrepancy”. Section 63’s proviso bars an order “without giving the person an opportunity of being heard”. Section 75(4) requires a hearing in demand proceedings where it is requested in writing or “where any adverse decision is contemplated”.
- To reply in the prescribed form. ASMT-03 in provisional assessment, ASMT-11 in scrutiny, a reply to ASMT-14 under section 63, and DRC-06 in demand proceedings.
- To produce records. In audit, the authorised officer may require the person “to afford him the necessary facility to verify the books of account” and “to furnish such information as he may require” (section 65(5)). The records to keep are listed in Keeping the Records an Audit Will Ask For.
- To file and pay. A section 62 order is deemed withdrawn when a valid return is filed in time. By section 2(117), a valid return means one “on which self-assessed tax has been paid in full”.
The routes in order
- Self-assessment in the return, under section 59. Unpaid self-assessed tax is recovered directly under section 75(12).
- A request for provisional assessment under section 60, where value or rate cannot be determined.
- Scrutiny under section 61: ASMT-10, a reply in ASMT-11, and ASMT-12 or further action.
- Best-judgment assessment under section 62, after a GSTR-3A notice, in ASMT-13.
- Assessment of an unregistered person under section 63: ASMT-14, a reply, then ASMT-15.
- Summary assessment under section 64 in ASMT-16, with withdrawal on an application in ASMT-17.
- Audit under section 65 or special audit under section 66, ending in findings.
- A demand under section 73, 74 or 74A, the summary in DRC-07, and then recovery or an appeal under section 107.
The next guide covers the one route the taxpayer starts: provisional assessment under section 60.