Rajasthan Revamps GST Return Scrutiny Framework: Comprehensive Guidelines Under Section 61 of RGST Act, 2017

The Commercial Taxes Department of Rajasthan has issued a fresh circular laying down overhauled guidelines for the scrutiny of GST returns filed by registered persons across the state. This circular, bearing reference Circular No. F.17(134)ACCT/GST/2017 PART-II-01613 dated 07/07/2026, issued by Chief Commissioner State Tax, Rajasthan, supersedes the earlier Circular No. F.17(151)ACCT/GST/2017/7602 dated 07.01.2022. The objective is to bring uniformity and standardisation to the return scrutiny process, both for ongoing proceedings and future cycles.

The revised framework draws its statutory authority from Section 61 of the Rajasthan Goods and Services Tax Act, 2017 (RGST Act, 2017), read with Rule 99 of the RGST Rules, 2017. Where scrutiny reveals unresolved discrepancies, appropriate action may follow under Section 73, Section 74, or Section 74A of the RGST Act, 2017, for the purpose of demand and recovery.

Section 61 of the RGST Act, 2017 empowers the proper officer to scrutinise returns and related particulars furnished by a registered person, with the primary aim of verifying the correctness of the returns so filed. Complementing this, Rule 99 of the RGST Rules, 2017 mandates that any discrepancies identified during such scrutiny must be formally communicated to the registered assessee, calling for their explanation.

The earlier circular from 2022 had established the initial framework for this process. The current circular replaces it entirely, introducing a more structured, data-driven, and technology-integrated approach aligned with contemporary GST administration requirements.

Role of the Business Intelligence Unit (BIU)

At the core of the revised mechanism lies the Business Intelligence Unit (BIU), which is tasked with periodically analysing data submitted by Registered Taxable Persons (RTPs) on the GSTN Portal. This analysis is conducted against a defined set of risk parameters to identify potential non-compliances and discrepancies warranting scrutiny.

Risk Parameters for Scrutiny Selection

The BIU will analyse GSTN data based on the following enumerated parameters:

  1. Excess outward tax liability declared in GSTR-1 as compared to GSTR-9 or GSTR-3B
  2. Lower turnover reported in GSTR-3B compared to figures reflected in GSTR-7 (TDS deductions)
  3. Lower turnover in GSTR-1 versus data available in GSTR-8 (TCS collections)
  4. Shortfall in RCM liability disclosed in GSTR-9 as against what has been declared by suppliers in their GSTR-1 filings
  5. Excess outward liability as indicated in e-way bills when compared against GSTR-3B
  6. Excess Input Tax Credit (ITC) claimed in GSTR-3B or GSTR-9 that is not corroborated by GSTR-2A, GSTR-2B, or GSTR-9
  7. Excess ISD ITC availed in GSTR-9 compared to what appears in GSTR-2A or GSTR-2B
  8. ITC claims from suppliers who have not filed GSTR-3B
  9. ITC availed from suppliers whose GST registration has since been cancelled
  10. ITC claims made beyond the deadline for availment as prescribed under Section 16(4) of the RGST Act, 2017
  11. Late filing of GSTR-3B, with interest either paid short or not paid at all

Mandatory vs. Weighted Parameters

The circular draws an important distinction between parameters that are mandatory for scrutiny selection and those that carry a weighted scoring for list preparation.

Specifically:

  • Serial numbers (i), (v), and (ix) — i.e., excess outward tax in GSTR-1 vs GSTR-9/GSTR-3B, excess liability in e-way bills vs GSTR-3B, and ITC claims from suppliers with cancelled registrations — are mandatorily referred for scrutiny.
  • For all remaining parameters, suitable weightage shall be assigned in preparing the scrutiny list.