A usable export needs an explainable production history
CGST section 145 recognises the specified copied, computer-produced and electronically stored material as documents and evidence in proceedings under the Act and rules. Subsection (2) addresses a certificate identifying the statement-containing document, explaining its production and providing appropriate device particulars, on the stated knowledge-and-belief basis. Checked on 27 October 2026 against CBIC’s text and the April 2026 ICAI bare law, this guide focuses on building a traceable electronic evidence pack. CBIC CGST Act: section 145.
Identify the exact statement being tendered
Give each export a stable filename, date, period, GSTIN and scope description. Retain the original exported file alongside any working copy used for filtering or calculations. A screen photograph of an unexplained total is harder to test than a source export with its inclusion criteria. These are practical provenance controls; a particular filename, checksum algorithm or spreadsheet layout is not prescribed by section 145 itself. CBIC CGST Act: section 145.
Describe production and the relevant system
The certificate should connect the identified statement to how it was produced and the appropriate particulars of the device involved. Record the source system, report selection, extraction date and any conversion steps as facts known to the person providing the certificate. Avoid signing a broad assertion about systems or periods outside that person’s knowledge. The section does not prescribe a GST portal form number for this certificate. CBIC CGST Act: section 145.
Keep a transformation bridge with the evidence
If raw data was deduplicated, combined across branches or separated into financial years, retain the raw rows and show the transformation. Identify unique keys before removing apparent duplicates: invoice numbers can recur across suppliers or series. Explain exclusions, reversals and gross-versus-net differences. The certificate identifies provenance; the reconciliation explains what the figures demonstrate about the particular issue. CBIC CGST Act: section 145.
Separate admissibility from the merits of the claim
Section 145’s evidence treatment does not establish that every figure in an export is substantively correct, or that an underlying supply or tax-credit condition is met. Reconcile to source invoices, ledger postings, return records and the precise allegation. Do not use an admitted bank statement as the sole answer to an allegation about receipt of goods. Keep factual corrections explicit rather than silently replacing an earlier submission. CBIC CGST Act: section 145.
Use a controlled submission index
Prepare a document index linking each response paragraph to the source file, relevant rows and calculation. Preserve the submitted version and acknowledgement, and record later supplemental evidence separately. If the authority asks for a different extraction or clarification, document how it differs. This article does not assert that its suggested evidence-pack format replaces a specific notice requirement, a proceeding’s directions or other independently applicable evidence law. CBIC CGST Act: section 145.
Applicable primary references
CBIC CGST Act: section 145 ICAI April 2026 GST bare law: section 145
Six worked illustrations
All facts and amounts below are fictional. Assumptions describe the model, not additional statutory rules.
Illustrative example 1: Detect a duplicated export segment
An export contains 1,200 rows. A verified unique-key test identifies 35 repeated records from an accidentally appended segment. The working has 1,165 distinct records. Retain all 1,200 raw rows and the 35-row exclusion list; do not present 1,165 as an unexplained fresh source count.
Illustrative example 2: Reconcile gross invoices and reversals
Invoice postings total ₹25,00,000 and separately identified reversals total ₹1,80,000. The net ledger movement is ₹23,20,000. Submit both components if the notice compares gross invoices; netting without explanation leaves an apparent ₹1,80,000 difference.
Illustrative example 3: Retain a complete page index
Three source files contain 42, 28 and 35 pages. The combined evidence pack has 105 pages. If the second file starts at page 43, it ends at page 70, and the third begins at 71. The index should point to the submitted pagination rather than each source file’s internal first page.
Illustrative example 4: Explain the period filter
A raw extract has 520 entries: 32 relate to the preceding period and 18 to the next period. The selected period contains 470 entries. Preserve all 50 exclusions with dates and reasons so that the submitted 470-row statement can be reproduced.
Illustrative example 5: Bridge two accounting units
Unit A shows ₹18,40,000 and Unit B ₹12,60,000, totalling ₹31,00,000. A verified ₹2,00,000 internal transfer appears in both units’ combined gross movement but must be excluded once from the defined external-transaction measure. That measure is ₹29,00,000. Explain why this exclusion fits the issue; do not call every inter-unit entry a duplicate invoice.
Illustrative example 6: Locate a presentation difference
The source statement records ₹10,00,000 in rupees. A response working displays 10.00 in ₹ lakh. A second reviewer mistakenly reads it as ₹10. The unit conversion is 10 × 1,00,000 = ₹10,00,000; the erroneous interpretation differs by ₹9,99,990. Put units on every relevant schedule.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Identify the proceeding and issue | Notice and response scope |
| 2 | Fix the document population | GSTIN, period and report filters |
| 3 | Preserve the original export | Unedited source file |
| 4 | Identify the statement | Filename and submission index |
| 5 | Describe production | System, extraction and conversion facts |
| 6 | Record device particulars | Appropriate section 145(2) details |
| 7 | Reconcile transformations | Filters, duplicate keys and exclusions |
| 8 | Test the substantive linkage | Invoices, ledger and issue-specific support |
| 9 | Check presentation | Units, dates and page references |
| 10 | Retain the submitted version | Certificate, pack and acknowledgement |
Sixteen practitioner FAQs
1. Does section 145 cover electronically stored information?
Yes. Subsection (1) includes the specified electronically stored information and hard copies.
2. Is a computer printout automatically proof of a valid supply?
No. Evidence admissibility and the substantive supply conditions are different questions.
3. What document should the certificate identify?
The document containing the statement being given in evidence.
4. What should production details explain?
How the identified document was produced, including relevant extraction and conversion facts.
5. Are device particulars relevant?
Subsection (2) refers to appropriate particulars of a device involved in production.
6. Must I invent technical details I do not know?
No. Keep assertions within the stated knowledge-and-belief basis and obtain accurate system information.
7. Is there a certificate form number in section 145?
The section itself does not specify a GST form number.
8. Does the section prescribe a particular file hash?
No. A checksum can be a practical integrity control, rather than a stated statutory format.
9. Can I discard the original after making a spreadsheet?
Preserve the source and transformation history so the working can be checked.
10. How should duplicate records be removed?
Use a justified key and retain an exclusion log; invoice number alone may not be unique.
11. Can I submit only a net ledger balance?
Where gross activity is questioned, show invoices, reversals and the bridge to net movement.
12. Why retain records outside the selected period?
An exclusion schedule explains the filter and permits reproduction of the submitted statement.
13. Can one export combine different GSTINs without explanation?
Identify the population and segregate or reconcile registrations according to the issue.
14. Does page numbering affect the tax result?
It improves traceability; it is not itself a tax computation rule.
15. What if a submitted extract is corrected?
Identify the correction and preserve version history and the earlier submitted record.
16. Does this pack replace notice-specific directions?
No. Meet the actual notice and proceeding requirements in addition to preparing reliable evidence.
Conclusion
Prepare GST electronic evidence with an identifiable export, production history, device particulars and reconciliations that explain the numbers submitted.