Audit Report — Review Carefully

How to Reply to ADT-02 Audit Report Under Section 65 — AI Response Guide

ADT-02 is issued under Section 65(6), Rule 101(5). This guide explains the legal basis, common grounds, procedural steps, and how GST Notice AI drafts your reply in under 60 seconds with relevant citations and defences.

What is ADT-02?

Form GST ADT-02 is the Audit Report issued under Section 65(6) of the CGST Act read with Rule 101(5) within 30 days of completion of the departmental audit initiated via ADT-01. It documents the audit findings, observations, and any proposed demand. It is not itself a demand notice — but it usually precedes a DRC-01A (intimation) or DRC-01 (SCN).

Legal Section

Section 65(6), Rule 101(5)

Follow-Up Window

30 Days

Reply Deadline

30 Days to Respond to Findings

Risk Level

Medium — May Escalate to DRC-01

Likely Next Notice

DRC-01A / DRC-01

Issuing Authority

Audit Officer

Common Reasons for Receiving ADT-02

Completion of Departmental Audit

Routine issuance following conclusion of every Section 65 audit, regardless of whether discrepancies were found.

Findings of Wrong ITC / Short Tax

Audit team identifies ITC taken without Section 16 conditions, short payment of tax, or classification errors during the audit period.

Reverse Charge / Valuation Discrepancies

Observations on non-discharge of RCM liability, incorrect application of rule 28/29/30 valuation methods, or HSN misclassification.

Procedural Violations

Non-maintenance of records under Section 35, non-issuance of invoices in prescribed format, or e-way bill non-compliance during the audit period.

How to Respond to ADT-02

1

Obtain ADT-02 with all annexures listing each observation, the amount involved, and the section/rule invoked. Study each observation individually.

2

For each observation, classify as: (a) agreed — pay tax + interest via DRC-03 before DRC-01A is issued to avoid penalty, (b) disputed — prepare defence paper for the next stage, (c) factual error — write to the audit officer requesting correction.

3

Compute the full exposure: principal tax + interest under Section 50 + potential penalty at 10% (Section 73) or 100% (Section 74). Decide on voluntary payment strategy accordingly.

4

Draft a formal response to the audit report within 30 days (though the law does not prescribe a reply, a written response of agreement / disagreement strengthens subsequent defence).

5

Maintain the working papers submitted during audit, the ADT-02 with annexures, and your response — these will be the foundation of any reply to DRC-01A or DRC-01 that may follow.

6

If a DRC-01A is issued, the liability can be paid with just interest (no penalty) before the SCN stage — biggest cost saving available. If DRC-01 is issued, full adjudication under Section 73/74 begins.

How GST Notice AI Helps with ADT-02

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Observation Classification Matrix

Processes every ADT-02 observation and classifies by merit, quantum, and recommended action — agree-and-pay, contest, or seek clarification.

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Voluntary DRC-03 Wizard

For agreed observations, generates the DRC-03 challan with correct tax + interest breakdown and attaches the link to the underlying observation.

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DRC-01 Defence Precomputation

For disputed observations, pre-drafts the Section 73/74 defence so that when DRC-01A arrives, the reply is 80% ready.

Reply to ADT-02 with AI

Upload your ADT-02 notice. AI drafts the reply, computes deadlines, and cites every applicable section and rule.

No credit card required. Analyse your first 3 notices free.

Frequently Asked Questions — ADT-02

What is ADT-02 in GST?
ADT-02 is the Audit Report issued under Section 65(6) read with Rule 101(5), documenting the findings of a departmental audit initiated via ADT-01. It is issued within 30 days of completion of audit.
Is ADT-02 a demand notice?
No. ADT-02 records observations and proposed demand. The actual demand flows through DRC-01A (intimation) and DRC-01 (Show Cause Notice) under Section 73 or 74.
Can ADT-02 be challenged?
Directly challenging ADT-02 via appeal is not available because it is not an order. However, the taxpayer can respond to the observations in writing, and contest any demand that follows through DRC-01 adjudication and appeal.
What is the advantage of paying before DRC-01?
Voluntary payment before DRC-01A is issued (under Section 73(5) / 74(5)) closes proceedings with payment of only tax + interest (no penalty for Section 73, reduced 15% penalty for Section 74). This is the cheapest resolution.