Audit by tax authorities
Section 65, CGST Act
Straight from CBIC
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In one line
Section 65 lets the tax authorities conduct an AUDIT of a registered person’s records at their premises or the office, with 15 days’ notice, to be completed within three months (extendable), findings communicated in ADT-02.
What this means in practice
The parts that actually decide cases — the things a practitioner checks first.
Fifteen working days’ notice in ADT-01; audit to be completed within three months of commencement, extendable by six months by the Commissioner with reasons recorded.
‘Commencement’ means the date the records asked for are made available or the audit actually starts, whichever is later – the clock does not start with the notice.
Findings come in ADT-02 within thirty days of completion; any tax discovered is then demanded under section 73 or 74A, not under section 65 itself.
The department cannot audit a period already covered by a completed audit without fresh material – raise it early if a second notice covers the same year.
Questions people actually ask
Real questions we get on this provision, answered straight.
The audit has been running for eight months. Is that allowed?+
Three months from commencement, extendable by six by the Commissioner with reasons recorded in writing. Ask for the extension order; if none exists, the audit is beyond time and anything built on it is open to challenge.
How this provision is built
The skeleton, clause by clause — useful when a notice cites a specific sub-clause.
The exact words of the law
2,061 characters, uneditedReproduced from the CBIC text. We explain it above — but you should always be able to read it yourself.
Read the full provision+
(1) The Commissioner or any officer authorised by him, by way of a general or a specific order, may undertake audit of any registered person for such period, at such frequency and in such manner as may be prescribed.
(2) The officers referred to in sub-section
(1) may conduct audit at the place of business of the registered person or in their office.
(3) The registered person shall be informed by way of a notice not less than fifteen working days prior to the conduct of audit in such manner as may be prescribed .
(4) The audit under sub-section
(1) shall be completed within a period of three months from the date of commencement of the audit: Provided that where the Commissioner is satisfied that audit in respect of such registered person cannot be completed within three months, he may, for the reasons to be recorded in writing, extend the period by a further period not exceeding six months. Explanation .- For the purposes of this sub-section, the expression "commencement of audit" shall mean the date on which the records and other documents, called for by the tax authorities, are made available by the registered person or the actual institution of audit at the place of business, whichever is later.
(5) During the course of audit, the authorised officer may require the registered person, –
(i) to afford him the necessary facility to verify the books of account or other documents as he may require; (ii) to furnish such information as he may require and render assistance for timely completion of the audit.
(6) On conclusion of audit, the proper officer shall, within thirty days, inform the registered person, whose records are audited, about the findings, his rights and obligations and the reasons for such findings.
(7) Where the audit conducted under sub-section
(1) 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 1 [or section 74A] .
High Court cases on this section
Judgments in our index that cite this provision. Being listed does not make a case good law — it may have been appealed or distinguished since. Read it before relying on it.
M/S ICIRI ROOFING v. THE COMMERCIAL TAX OFFICER
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M/S V R SUNDARA MURTHY v. COMMERCIAL TAX OFFICER
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M/s.leela Enterprises v. Assistant Commissioner (ST)
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M/s.Vasudeva Reddy v. Assistant Commissioner (ST)
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M/s.Gee Kay Steel Corporation, v. The Assistant Commissioner (ST),
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M/s. Sita Devi Vundavalli v. Assistant Commissioner (ST)
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M/s.Srinivasa Automotives v. The Assistant Commissioner (ST)
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M/s. Golechha And Sons, v. The State Tax officer 2,
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64 more on record. Search all GST case law →
What changed, and when
The amendment trail, newest first — because the version that applies to your case depends on the period.
date not stated · Inserted
Inserted by section 133 of The Finance Act (No. 2) Act, 2024 No. 15 of 2024 dated 16.08.2024.
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Where this comes from
Text reproduced from the Central Board of Indirect Taxes and Customs, as available on 2026-09-05. The explanation and practice notes above are GSTZone’s own, written for this hub. If you spot anything out of date, tell us and we’ll fix it — this hub is checked daily against CBIC.
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