Dear Experts,

Dear Experts,

We received ADT-01 on 03-01-2024, intimating us about the conduct of a departmental audit for FY 2021–22, with a request to submit the relevant details by 23-01-2024. We submitted the required information on 23-01-2024.

Subsequently, we received the audit observations in Form ADT-02 on 25-07-2025.

In this context, would the issuance of ADT-02 be considered time-barred under Section 65 of the CGST Act read with Rule 101 of the CGST Rules? As per my understanding, the audit should be completed within 3 months from the date of commencement (extendable to 6 months with approval). In our case, the gap between submission and issuance of ADT-02 is over 18 months. 

Now how do i contest the ADT-02 and SCN if issued under 73/74, what should be my reply.

Regards,

S Ram