Text
The text below is the section as served by the CBIC tax information portal on 17 September 2026, with the portal's own amendment footnote markers (shown as small numerals before a bracket) and its footnotes.[1] The Act as published in the Gazette of India is the legal source.
Section 66, verbatim (show)
Section 66
* Section 66. Special audit.-
(1) If at any stage of scrutiny, inquiry, investigation or any other proceedings before him, any officer not below the rank of Assistant Commissioner, having regard to the nature and complexity of the case and the interest of revenue, is of the opinion that the value has not been correctly declared or the credit availed is not within the normal limits, he may, with the prior approval of the Commissioner, direct such registered person by a communication in writing to get his records including books of account examined and audited by a chartered accountant or a cost accountant as may be nominated by the Commissioner.
(2) The chartered accountant or cost accountant so nominated shall, within the period of ninety days, submit a report of such audit duly signed and certified by him to the said Assistant Commissioner mentioning therein such other particulars as may be specified:
Provided that the Assistant Commissioner may, on an application made to him in this behalf by the registered person or the chartered accountant or cost accountant or for any material and sufficient reason, extend the said period by a further period of ninety days.
(3) The provisions of sub-section (1) shall have effect notwithstanding that the accounts of the registered person have been audited under any other provisions of this Act or any other law for the time being in force.
(4) The registered person shall be given an opportunity of being heard in respect of any material gathered on the basis of special audit under sub-section (1) which is proposed to be used in any proceedings against him under this Act or the rules made thereunder.
(5) The expenses of the examination and audit of records under sub-section (1), including the remuneration of such chartered accountant or cost accountant, shall be determined and paid by the Commissioner and such determination shall be final.
(6) Where the special 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].
*Enforced w.e.f. 1st July, 2017.
1. Inserted by section 134 of The Finance Act (No. 2) Act, 2024 No. 15 of 2024 dated 16.08.2024.
Questions to answer on the file
Questions a reviewer answers from the engagement file, grouped by the part of the section they come from. They describe what the section asks; they do not decide it.
Scope the section as a whole
Questions to answer on the file1 question
The stage of the proceedings and the officer 66(1) opening words
Questions to answer on the file3 questions
The opinion on which the direction rests 66(1)
Questions to answer on the file4 questions
The prior approval and the written direction 66(1)
Questions to answer on the file3 questions
What is to be examined and audited, and by whom 66(1) closing words
Questions to answer on the file3 questions
The report and the ninety days 66(2)
Questions to answer on the file6 questions
The extension by a further ninety days the proviso to 66(2)
Questions to answer on the file3 questions
The special audit notwithstanding another audit 66(3)
Questions to answer on the file2 questions
The opportunity of being heard on the material gathered 66(4)
Questions to answer on the file3 questions
The expenses of the examination and audit 66(5)
Questions to answer on the file2 questions
The action that may follow a detection 66(6)
Questions to answer on the file3 questions
Amendment history
The CBIC text carries 2 footnotes. The table gives each in the source's own terms. Effective dates are as the footnotes state them.[1]
| Note | Change | Instrument | Effective from |
|---|---|---|---|
| Enforced the section. | — | 1st July, 2017 | |
| 1 | Inserted the words "or section 74A" in sub-section (6). | section 134 of The Finance Act (No. 2) Act, 2024, No. 15 of 2024, dated 16.08.2024[2] | the source's footnote gives no effective date for the insertion; the date shown is the date of the amending Act |
Relationship with other provisions
| Provision | Connection | Words that tie them |
|---|---|---|
| Section 3 | this provision requires Section 3 | 66(1) "any officer not below the rank of Assistant Commissioner... with the prior approval of the Commissioner", those being classes of officers section 3 appoints |
| Section 15 | this provision branches on Section 15 | 66(1) "is of the opinion that the value has not been correctly declared" |
| Section 16 | this provision branches on Section 16, S17 | 66(1) "or the credit availed is not within the normal limits" |
| Section 73 | 66(6) requires Section 73, S74, S74A | 66(6) "the proper officer may initiate action under section 73 or section 74 1[or section 74A]" |
| Rule 102 of the CGST Rules, 2017 | this provision prescribed by rule 102 of the CGST Rules 2017 | 66(1) "direct such registered person by a communication in writing"; rule 102(1) "shall issue a direction in FORM GST ADT-03" |
| Section 61 | Section 61 requires this provision | 61(3) "or section 66" |
Circulars and notifications
Circulars and notifications in the CBIC repository that cite this section, newest first, by number, date and subject. A listing here does not say what an instrument decides; read the instrument.
Circulars (1)
| Number | Date | Subject |
|---|---|---|
| Circular No. 3/03/2017-GST | 5 July 2017 | Proper officer relating to provisions other than Registration and Composition under the Central Goods and Services Tax Act, 2017-Reg. |
Notifications (1)
| Number | Date | Subject |
|---|---|---|
| Notification No. 10/2017-Central Tax | 28 June 2017 | Seeks to amend CGST Rules notification no 3/2017-Central Tax dt 19.06.2017 amended by a later instrument |
Unsettled questions
The words of section 66 do not answer these questions. Where one decides a matter on the file, the answer depends on the position taken on it.
- From what date does the reference to section 74A, inserted into sub-section (6) by section 134 of the Finance (No. 2) Act, 2024, apply? The source's footnote gives the amending Act and its date of 16.08.2024 and no commencement date. The same position already covers the identical insertions into sections 61 to 65 and is cited, not written again.
- What are "the normal limits" against which credit availed is measured for the opinion under sub-section (1)? Neither this section, nor the sections that govern credit, nor the rules fix a limit, a ratio or a comparison, and the direction rests on the officer's opinion that the credit is outside it.
- From which date does the period of ninety days in sub-section (2) run: the date of the direction, the date of the nomination, the date the direction reached the accountant, or the date the records were produced to him? The sub-section fixes the length of the period and never its beginning.
See also
- Rule 102 of the CGST Rules, 2017: special Audit
- Section 65 of the CGST Act, 2017: audit by tax authorities
- Section 74A of the CGST Act, 2017: determination of tax not paid or short paid or erroneously refunded or input tax credit wrongly availed or utilised for any reason pertaining to Financial Year 2024-25 onward
References
- Central Board of Indirect Taxes and Customs. "Section 66. Special audit". Central Goods and Services Tax Act, 2017, CBIC tax information portal, with amendment footnotes 1 to 2. Retrieved 17 September 2026.
- The Finance Act (No. 2) Act, 2024. Cited in CBIC footnote 1.
External links
- CGST Act, 2017, Section 66 on the CBIC tax information portal