Authorisation does not transfer the taxpayer’s responsibility
Section 48(3) leaves responsibility for correctness of particulars with the registered person even where an approved GST practitioner files them. Rule 83(6) uses PCT-05 for authorisation or withdrawal and limits work to the indicated tasks during the authorisation period. This guide, checked on 26 October 2026, focuses on that operating control, not practitioner enrolment/examination eligibility or a promise about portal screen availability. ICAI statutory compilation: CGST Act section 48 and CGST Rules 83(6)–(10).
Define the mandate before preparing submissions
Identify the registered person, practitioner, tasks and period. Rule 83(8) permits the listed activities only if authorised; a fee engagement or access to books is not itself the specified portal authorisation. Preserve PCT-05 and its effective status, and review it when personnel or service scope changes. Withdrawal is available at any time in PCT-05; do not assume it retrospectively deletes a filing or changes its legal consequences.
Two confirmation rules must remain separate
Under Rule 83(7), confirmation of a practitioner-furnished statement is sought by email or SMS and the statement is made available on the portal. Failure to respond until its last furnishing date is deemed confirmation under the proviso. By contrast, the proviso to Rule 83(8) says the specified refund, registration-amendment/cancellation and composition intimations must not proceed further until the registered person consents. Silence under the statement rule should not be used to bypass that application control.
Review facts before confirming
Rule 83(9) requires the registered person using the practitioner route to consent in PCT-05 and ensure facts are true and correct before confirming submission. Reconcile turnover, adjustments, ledgers and the exact version presented. A message saying approved, without an identifiable document version or period, is weak operational evidence. Do not treat a practitioner’s acknowledgement as proof of the taxpayer’s separate consent.
Practitioner diligence and verification also matter
Rule 83(10) requires due diligence and the practitioner’s digital signature or electronic verification using their credentials. Maintain preparation and review trails without sharing personal authentication credentials as a substitute for the prescribed arrangement. An internal reviewer can help check the work, but the statutory roles should remain identifiable. This article does not invent a universal internal review deadline or automatic correction right after filing.
Build a confirmation register rather than relying on inbox memory
For each submission record GSTIN, form/statement type, period, practitioner authority, preparation version, confirmation request, relevant actual due date, taxpayer decision and final acknowledgement. Use the actual due date after applicable extensions; the illustrative dates below are assumed, not declared nationwide filing deadlines. Resolve rejected or unanswered applications and revoked mandates before the next submission. Review any error under its separately applicable correction procedure.
Applicable primary references
ICAI statutory compilation: CGST Act section 48 and CGST Rules 83(6)–(10)
Six worked illustrations
All facts and amounts below are fictional. Assumptions describe the model, not additional statutory rules.
Illustrative example 1: Limit work to authorised tasks
A service team lists five proposed tasks, but the valid mandate authorises only three. Three are within the assumed scope and two require an appropriate mandate change before being undertaken through this route. The number of services invoiced does not enlarge the authority.
Illustrative example 2: Statement review diary
Assume the actual last furnishing date for a statement is 20 November 2026 and its confirmation request arrives on 17 November. There are three elapsed calendar days to that date in this simple diary. Check the actual deadline and Rule 83(7) consequences; three days is not a prescribed universal response period.
Illustrative example 3: Applications awaiting consent
Six specified applications under the Rule 83(8) proviso are prepared. Four have the registered person’s actual consent and two do not. The two cannot be moved forward merely by applying the statement deemed-confirmation rule. Four consents also do not prove those four claims are substantively admissible.
Illustrative example 4: Correct the reviewed version
Draft outward-supply value is ₹12,50,000. Review establishes an omitted ₹50,000 item and a duplicated ₹20,000 item. The corrected value is ₹12,80,000. Obtain confirmation against that version; approval of the old ₹12,50,000 draft does not identify approval of the new figures.
Illustrative example 5: Reconcile cash-ledger deposits
The practitioner’s authorised deposit task produces valid credits of ₹40,000, ₹25,000 and ₹35,000, totalling ₹1,00,000. A preparer accidentally includes the ₹25,000 credit twice and reports ₹1,25,000. Remove ₹25,000 before the taxpayer reviews the reconciliation; a deposit is not by itself proof of tax discharge.
Illustrative example 6: Check authority at the next task
PCT-05 withdrawal is assumed effective on 10 December 2026. A proposed practitioner task is dated 12 December, two elapsed days later. It is outside that former authority on the stated facts; retain the withdrawal evidence and arrange a valid route rather than using an obsolete mandate.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Identify the registered person | Correct GSTIN and authorised taxpayer decision maker. |
| 2 | Verify practitioner status | Enrolment/status evidence relevant to the engagement. |
| 3 | Retrieve PCT-05 | Actual authorisation, tasks and effective period. |
| 4 | Classify the submission | Statement or specified consent-dependent application. |
| 5 | Reconcile the draft | Books, source documents, period and version. |
| 6 | Record the confirmation request | Email/SMS and portal availability trail. |
| 7 | Use the actual last furnishing date | Current deadline and applicable extension evidence. |
| 8 | Capture the taxpayer decision | Version-specific confirmation or required express consent. |
| 9 | Verify practitioner authentication | Signature or verification and filing acknowledgement. |
| 10 | Review withdrawals and unresolved errors | Current mandate, pending applications and correction route. |
Sixteen practitioner FAQs
1. Does using a practitioner remove taxpayer responsibility?
No. Section 48(3) retains responsibility for correctness with the registered person.
2. Which form governs the authorisation?
Rule 83(6) specifies GST PCT-05.
3. Can PCT-05 also withdraw authority?
Yes, at any time under that sub-rule.
4. Is authority unlimited once a practitioner is engaged?
No. It covers the indicated tasks during the authorised period.
5. Does a commercial engagement letter replace the portal authorisation?
Do not assume it fulfils the prescribed PCT-05 requirement.
6. How is statement confirmation sought?
Rule 83(7) specifies email or SMS and portal availability of the statement.
7. When does its deemed confirmation operate?
On failure to respond until the last date of furnishing that statement under the proviso.
8. Is that always a fixed number of days after the message?
No. The rule links it to the statement’s last furnishing date.
9. Can silence move a specified refund application forward?
The Rule 83(8) proviso requires the registered person’s consent before it proceeds further.
10. Which other submissions does that proviso specify?
Registration amendment/cancellation and the stated composition-scheme intimations, alongside refund applications.
11. Does consent establish substantive refund entitlement?
No. Eligibility and the claim’s merits remain separate.
12. What must the taxpayer check before confirmation?
Rule 83(9) requires ensuring that the return’s facts are true and correct.
13. What diligence duty applies to the practitioner?
Rule 83(10) requires preparation with due diligence.
14. How is the practitioner’s work authenticated?
By the stated digital signature or electronic verification using the practitioner’s credentials.
15. Does withdrawal automatically erase earlier filings?
Do not assume retrospective deletion or reversal; use the applicable legal correction route.
16. What is the essential closing record?
A submission-wise register connecting valid authority, exact draft, confirmation/consent and final acknowledgement.
Conclusion
Control the tasks and period authorised to a GST practitioner, distinguish deemed statement confirmation from application consent, and retain taxpayer review evidence.
Sources and primary references
Official CGST Rules compilation: Rule 83 authorisation and confirmation provisions; Notification 03/2019-Central Tax, clauses 12 and 23: Rule 83(8) and PCT-05 amendments, effective 1 February 2019.