Whether departmental audit report can be challenged if audit is not completed within the prescribed timelimit ?
TRT-2026-610

Issue Favourable to Tax Payer ?:- yes

Held - In view of the Explanation to Section 65 (4) of the OGST Act, the 3-month period within which the audit had to be completed commenced, in the present case, on 22nd March, 2022. In other words, the entire audit exercised had to be completed with the submission of final audit report in terms of Section 65 (6) of the OGST Act on or before 22nd June, 2022.

On a plain reading of Section 65 (4) together with Section 65 (6) of the OGST A.....