How does the GST department get our RERA data?

It is published. Quarterly project updates — units booked, area sold, amounts received — are filed with the state authority and are available on its portal. No information exchange is needed and no request has to be made to you. A developer's own disclosures are the source of the comparison.

Our figures genuinely do not match. Does that mean we underpaid?

Usually not. The two filings measure different things on different dates, so a well-run project will still show differences. RERA reports bookings and collections; GST reports supply and the time-of-supply rules that determine it. Cancellations, timing, credit notes and the treatment of the landowner's share all produce legitimate gaps. The problem is that an unexplained gap looks identical to an underpayment until someone explains it.

What are the most common innocent causes of a difference?

Timing above all — a booking reported to RERA in one quarter can fall into a different GST period under the time-of-supply rules. Then cancellations and re-sales of the same unit, which RERA and GST reflect differently; the landowner's share, which appears in project data but is not a sale by the developer; and amounts collected that are not consideration for the supply, such as pass-through statutory charges.

Should we reply with a reconciliation or just the numbers?

A reconciliation. A reply that asserts the returns are correct without showing how the two data sets bridge invites the next notice. The useful reply takes the department's own figure, walks it to the declared turnover through numbered explained differences, and pays whatever is genuinely short rather than defending all of it.

Can we correct this before a notice arrives?

Yes, and it is materially better. Running the reconciliation yourself surfaces the same gaps the department will find, and anything genuinely short can be paid with interest voluntarily rather than under demand. The difference in exposure between a voluntary correction and a contested demand is usually larger than the tax itself.

RERA Filings vs GST Returns: Why the Notice Arrives

Short answer: you file booking and collection data with RERA. You file turnover with GST. Both are yours, one is public, and comparing them requires no investigation at all. Most gaps are innocent — but an unexplained gap and an underpayment look identical from the outside.

Why this comparison is easy to run

Real estate is unusual in producing two independent, self-reported data sets that describe the same commercial activity:

RERA quarterly project updates — units booked, area sold, amounts received, project progress. Filed with the state authority and published on its portal.
GST returns — outward supply and tax declared.

The department does not need to request anything, visit anything, or exchange information with another authority. The comparison runs off filings the developer has already made, one of which anyone can read.

That is why this has become a standing source of notices rather than an occasional one. It scales without effort.

The differences that are genuine

A correctly run project will still show gaps, because the two filings are not measuring the same thing.

Timing. RERA reports bookings and collections within a quarter. GST reports supply according to the time-of-supply rules. A booking in one RERA quarter can legitimately fall into a different GST period. Across a project life these mostly wash out; in any single period they do not.

Cancellations and re-sales. A unit booked, cancelled and rebooked appears differently in the two data sets, and the credit note that reverses the original supply has its own timing and its own conditions.

The landowner's share. Units allotted to the landowner under a joint development agreement form part of the project reported to RERA, but they are not sales by the developer to buyers. They carry a construction service to the landowner instead, which is taxed differently and at a different time.

Amounts that are not consideration. Statutory charges collected and passed through, refundable deposits, and maintenance corpus held on account are collections in the RERA sense without necessarily being consideration for the supply.

Exempt post-completion sales. Units sold after the completion certificate are outside GST but remain part of the project's reported sales.

The differences that are not

Set against those, the ones that usually indicate a real shortfall:

Bookings disclosed to RERA that were never invoiced at all.
Reverse-charge liabilities never computed — on development rights, or under the 80:20 procurement test. A project with substantial activity and no reverse charge ever declared is the single most visible pattern in this data.
The landowner's construction service never invoiced, on the assumption that no money changed hands so no supply occurred.
Credit notes issued outside the permitted window, reversing supply that can no longer be reversed.

How to answer a notice

The instinct is to assert that the returns are right. It rarely closes anything.

What works is a bridging reconciliation: start from the department's own figure, and walk it to declared turnover through numbered, individually evidenced differences.

Step	Amount
Collections per RERA filings	as per notice
Less — landowner's allotted units (not a sale by the developer)
Less — post-completion sales, outside GST
Less — pass-through statutory charges and refundable deposits
Less / add — timing differences between quarter and tax period
Less — cancellations, with credit note references
Declared turnover per returns	should agree

Two things make this reply work: every line is supported by a document, and anything genuinely short is paid with interest rather than argued. A reply that defends all of it, including the indefensible part, loses credibility on the part that was actually right.

Do it before the notice

The whole reconciliation can be run on your own data, and the department's version of it holds no information you do not already have.

Running it yourself surfaces the same gaps. Anything genuinely short can then be paid voluntarily with interest, rather than under a demand carrying penalty exposure and a defended position. On this fact pattern the difference between those two routes is routinely larger than the tax at stake.

Where a notice has already been issued, see tax notices and assessments for the procedural side, and GST notices from ASMT-10 to demand for how this escalates if the first reply does not land.

This is a working reference, not the statute. For anything you are relying on, confirm the provisions and the notice's own stated basis directly.

RERA filings vs GST returns: the comparison that generates the notice