Haryana GST Mandates Strict Multi-Level Approval for Suo-Moto Audit & Scrutiny Cases

The Excise & Taxation Department, Haryana, has issued stringent instructions for initiating Suo-Moto cases for audit or scrutiny under the Haryana Goods and Services Tax (HGST) Act, 2017.

The new mandate, circulated vide Memo No. 217/GST-II dated November 29, 2025, introduces a mandatory, multi-level approval framework that compels field officers to provide clear justification before proceeding with any suo-moto audit or scrutiny against a taxpayer.

Key Highlights of the New Procedure

The instructions dictate a clear protocol for officers proposing to take up a suo-moto GST case:

1. Clear & Specific Justification Required: Any proposal for suo-moto audit/scrutiny must be submitted with "a clear, specific, and duly justified reasons".
2. Mandatory Quantification of Evasion: The proposal must also include the tentative quantum of tax evasion. This quantification must be based on verifiable data, such as departmental records, intelligence inputs, or data analysis.
3. Two-Tier Approval Process: The most significant change is the introduction of a mandatory two-step approval:

• Level 1: The proposal must first be examined and recommended by the Deputy Excise and Taxation Commissioner (DETC) concerned.
• Level 2 (Final Approval): After the DETC's recommendation, the case file must be forwarded to the Joint Excise and Taxation Commissioner (Range) for final approval.

Impact and the Department's Stance

The department's directive emphasizes strict compliance with these new procedures, cautioning that "Any initiation of suo-moto action without adherence to the above-mentioned procedure shall be viewed seriously".

This move is widely seen as an attempt to streamline the scrutiny process and reduce instances of unwarranted notices or audits that often lead to taxpayer harassment and block business capital. By mandating a justified estimate of tax evasion and requiring senior-level approvals (DETC and JETC), the government aims to ensure that suo-moto actions are targeted and based on concrete evidence, thereby focusing departmental efforts on genuine cases of non-compliance.

Tax professionals are advising businesses to maintain robust records, as the new focus on "verifiable source of information" and "data analysis" underscores the need for thorough GST compliance and accurate reconciliation of filed returns.

Official copy of the notification has been attached