Filing Mistakes, Notices and Sources
Hiring a CA or GST practitioner to file returns: fees, engagement scope and red flags
What CAs and GST practitioners do for small businesses, how their filing fees are structured, what the engagement letter should cover and how to authorise them safely on the portal.
A chartered accountant (CA) or an enrolled GST practitioner (GSTP) can prepare and file your GST returns, reconcile ITC and handle notices, but you remain legally responsible for what is filed. Choose one with a clear written scope, a monthly timeline, and a way of working that does not require handing over your portal password: a GST practitioner can be linked to your GSTIN on the portal, and returns can be filed with your OTP or DSC. Fees are commonly per return or per month and vary with invoice volume, so ask for a scope-based quote and compare on what is included, not the headline rate.
This guide belongs to the guide to common GST filing mistakes; if you are changing advisers and software together, also read switching accounting software. Fees shown are illustrative.
CA, GST practitioner, tax consultant: the differences
| Who | How they qualify | What they can do in GST |
|---|---|---|
| Chartered accountant | Member of ICAI; certificate of practice | File returns, reconciliation, GSTR-9C preparation, represent before authorities, audits under other laws |
| GST practitioner | Enrolled under section 48 of the CGST Act after meeting eligibility and passing the examination conducted by NACIN | Prepare and file returns, refunds, registration applications, appear before officers as authorised |
| Advocate | Enrolled with a Bar Council | Represent in litigation and appeals |
| Company secretary / cost accountant | Members of ICSI / ICMAI | Can be enrolled as GSTP and represent, within the rules |
| Unqualified "tax agent" | None | No standing to represent you; filing through your login only |
Verify a CA's membership with ICAI and a GSTP's enrolment through the GST portal's search facility.
Authorising a GST practitioner safely
The portal lets a taxpayer engage a GST practitioner by linking the GSTP's enrolment number to the GSTIN. The GSTP can then prepare returns in their own login, and the taxpayer confirms and files (or the system seeks the taxpayer's confirmation, as the rules provide). Benefits:
- you keep your own password and two-factor authentication;
- the record shows which practitioner prepared which return;
- you can disengage the GSTP on the portal at any time.
If your adviser insists on your username and password, ask why. Where it truly cannot be avoided, change the password after each filing period and ensure the registered mobile number and email remain yours, because these control OTPs and recovery.
Typical fee structures (illustrative)
| Scope | Illustrative fee | Notes |
|---|---|---|
| Nil returns only | ₹300–₹1,000 a month | Often bundled |
| QRMP: quarterly GSTR-1 and GSTR-3B | ₹1,500–₹4,500 a quarter | IFF may be extra |
| Monthly filing, up to ~100 invoices | ₹1,000–₹3,000 a month | |
| Monthly filing with full ITC reconciliation | ₹2,500–₹8,000+ a month | Depends on purchase volume |
| GSTR-9 (annual return) | ₹5,000–₹25,000 | Per GSTIN |
| GSTR-9C | ₹10,000–₹40,000+ | Per GSTIN |
| Notice reply (DRC-01B/01C) | ₹2,000–₹10,000 | ASMT-10 and SCNs higher |
| Registration, amendment, cancellation | ₹1,000–₹5,000 |
These are not market rates and vary greatly between cities and firms. GST at 18% applies to professional fees; a regular registered business can usually claim it as ITC. Compare with software costs in the annual compliance cost estimator.
What an engagement letter should say
- Scope: which returns, for which GSTINs, which periods; whether reconciliation, IMS actions, GSTR-9/9C, notices and e-way bill support are included.
- Your obligations: what data you send, in what format, by which date each month (for example, sales and purchase data by the 5th).
- Their timeline: draft returns to you by a fixed date before each due date, so you can review.
- Approval: who approves before filing and how (email confirmation, OTP).
- Fees: amount, billing frequency, extra charges, late-data surcharges.
- Records: who keeps working papers and how you get copies; return of data on termination.
- Confidentiality and data security.
- Termination: notice period and handover.
Worked example: comparing two quotes (illustrative)
A Kochi retailer receives two quotes for monthly filing:
| Item | Quote 1 | Quote 2 |
|---|---|---|
| Monthly GSTR-1 and GSTR-3B | ₹1,500 | ₹2,500 |
| ITC reconciliation | Extra: ₹1,000/month | Included |
| GSTR-9 | ₹10,000 | Included |
| Notice replies (DRC-01B/01C) | ₹3,000 each | Included up to 2 a year |
| Annual cost, assuming 1 notice a year | 12 × ₹2,500 + ₹10,000 + ₹3,000 = ₹43,000 | 12 × ₹2,500 = ₹30,000 |
The quote with the higher headline fee is cheaper once scope is compared.
Red flags
- Asks you to pay tax into a personal account or through anything other than a GST portal challan.
- Will not show you draft returns or copies of filed returns.
- Claims to get ITC on everything, or offers "adjustments" to reduce tax.
- Offers to arrange invoices from other businesses to increase credit. Fake invoicing is a serious offence.
- Files returns but never mentions GSTR-2B mismatches or notices.
- Keeps your registered mobile or email as their own.
Your own monthly checks
Even with a professional, spend ten minutes a month on the portal: confirm GSTR-1 and GSTR-3B show as filed, check the cash ledger matches what you paid, and look at the notices tab. The monthly GST filing checklist lists what to check. If you are weighing a professional against software, see the comparison of filing options, and for notices see GST notices and how to reply.
Frequently asked questions
Is the practitioner liable if they file a wrong return?
The taxpayer is responsible to the department. You may have a claim against the adviser under your engagement terms, and professionals are subject to their institute's discipline, but the tax demand is yours.
Can a GST practitioner file without my approval?
The portal requires taxpayer confirmation or authentication for returns prepared by a GSTP, as the rules provide. Do not share OTPs casually.
How do I change my practitioner?
Disengage the old GSTP on the portal, engage the new one, and obtain your working papers and data from the old adviser.
Should my CA also do my bookkeeping?
It can be efficient for a small business. Keep a copy of the books yourself and agree in writing who owns the data.
Sources
- GST portal — engaging and disengaging a GST practitioner, search GSTP
- CBIC GST — section 48 of the CGST Act and rules 83 and 83A on GST practitioners
- Institute of Chartered Accountants of India — membership verification
