GST Advisory & Litigation
for Manufacturers and Exporters
Prikriti Group provides technical GST advisory, refund claim assistance, notice handling, adjudication, first appellate work and litigation strategy for manufacturers, exporters and businesses with complex indirect tax issues.
Technical Advisory & Litigation Strategy
Framed Around the GST Acts
Our approach combines practical GST compliance experience with legal positioning under the CGST Act, 2017, the IGST Act, 2017 and applicable GST Rules. This positions Prikriti Group as a broader indirect tax advisory and litigation practice, supporting clients on GST matters where financial exposure, refund blockage, ITC disputes, departmental proceedings or appeal deadlines require technical review and structured representation.
"Manufacturers and exporters operate in a GST environment where input tax credit, export refund, e-way bill, invoicing, job work, reverse charge and place-of-supply positions directly affect cash flow and compliance risk. We provide GST advisory designed for businesses with high transaction volume, multiple locations, exports, imports, job work arrangements and regular departmental scrutiny."
GST Advisory for Manufacturers & Exporters
Relevant provisions considered include Section 16 of the Central GST Act for eligibility and conditions for input tax credit, Section 17 for apportionment and blocked credits, Section 19 for inputs and capital goods sent to job work, Section 31 for tax invoice requirements, Section 35 for accounts and records, Section 39 for returns, and Section 49 for payment and utilisation of tax, interest, penalty and other amounts.
Scope includes:- GST transaction advisory for manufacturers, exporters, merchant exporters, job workers and service providers.
- Input tax credit review under Sections 16 and 17 of the Central GST Act.
- Job work and manufacturing-chain review under Section 19 of the Central GST Act.
- Export supply and zero-rated supply advisory under Section 16 of the IGST Act.
- Review of tax invoice, debit note and credit note positions under Sections 31 and 34 of the Central GST Act.
- GST health checks for recurring risks in GSTR-1, GSTR-3B, e-invoicing, e-way bill and ITC reconciliation.
Refunds Optimization & Dispute Defense
GST refunds are a critical cash-flow area for exporters and businesses with accumulated input tax credit. We assist with refund eligibility review, documentation, computation, filing support, deficiency memo response, notice reply and refund order review. Framed around Section 54 of the Central GST Act, 2017, Section 56 for interest on delayed refunds, and Section 16 of the IGST Act.
Scope includes:- Refunds for zero-rated supply of goods or services.
- Refund of accumulated ITC due to exports under LUT or bond.
- Refunds linked to inverted duty structure, where applicable.
- Review of refund computation, turnover formula, eligible ITC and supporting documents.
- Response to deficiency memo, show cause notice or proposed refund rejection.
- Representation for refund sanction, partial rejection and post-audit issues.
Notices, Adjudication, Appeals & Litigation Strategy
Departmental actions may arise from return scrutiny under Section 61, audit under Section 65, special audit under Section 66, inspection, search and seizure under Section 67, summons under Section 70, and demand proceedings under Sections 73 and 74. General principles of adjudication, including natural justice, are governed by Section 75. Appeals before the Appellate Authority are undertaken under Section 107 of the Central GST Act read with Rule 108 through FORM GST APL-01. Where required, representation is also provided before the GST Appellate Tribunal under Section 112 of the Central GST Act.
Scope includes:- Analysis of GST notices, audit observations, summons and demand proposals.
- Preparation and filing of replies in scrutiny, audit, adjudication and refund-rejection matters.
- Representation in adjudication proceedings under Sections 73, 74 and 75 of the Central GST Act.
- Drafting and filing of appeals before the Appellate Authority under Section 107 of the Central GST Act read with Rule 108.
- Representation and appeal proceedings before the GST Appellate Tribunal under Section 112 of the Central GST Act.
- Grounds of appeal, statement of facts, legal submissions and hearing preparation.
- Litigation strategy for tax, interest, penalty, ITC denial, refund rejection and classification/rate disputes.
Departmental & Appellate Representation
Prikriti Group represents clients before GST authorities for advisory-led and dispute-related matters. Representation is structured to ensure that facts, documents, reconciliations, statutory provisions and legal arguments are presented clearly before the department or appellate forum.
Services Include:- Representation before jurisdictional GST officers in notice, refund, audit and adjudication matters.
- Representation before the Appellate Authority for first appeal proceedings under Section 107.
- Drafting and submission of written replies, appeal memoranda, additional submissions and hearing notes.
- Coordination of reconciliations, ledgers, invoices, shipping bills, LUT records and supporting documents.
- Assistance in managing statutory timelines, hearing dates, pre-deposit requirements and follow-up actions.
- Strategic review of adverse orders for appeal feasibility and next-step planning.
Discuss GST Matter
Primary CTAGet a comprehensive technical evaluation of your active GST notices, accumulated export refunds, input tax credit disputes, or pending appeal requirements before statutory limitation deadlines expire.
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