The First Quarter Playbook: A 90-Day Compliance Roadmap for US Finance Leaders Taking Charge in India
Taking over the finance function of an Indian subsidiary is unlike any domestic transition a US executive will have experienced. The entity may be profitable, staffed, and audited — and still carry unresolved excise, GST, and customs exposure that no handover deck mentions. The difference between a clean first quarter and a costly surprise is rarely luck. It is sequence.
Week One: Pull the Paper Before You Form Opinions
Your first seven days should produce documents, not conclusions. Request the following before anything else:
- GST registrations (GSTIN certificates) for every state where the entity operates or warehouses goods
- The most recent twelve months of GSTR-1, GSTR-3B, and GSTR-9 annual returns
- Excise-era records if the entity manufactured goods before GST transition, including any pending CENVAT credit balances
- Customs bills of entry for imports over the past two fiscal years
- All correspondence from the Central Board of Indirect Taxes and Customs (CBIC), including notices marked as "intimation" rather than "demand"
US headquarters often assume these records live in a single system. In practice, Indian indirect tax records are frequently fragmented across state-level consultants, a legacy ERP, and email threads with former managers. Reconstructing them later is far more expensive than requesting them now.
Weeks Two Through Four: Verify Registrations Against Reality
Registration certificates are where dormant risk hides. Cross-check each GSTIN against the physical footprint: every warehouse, office, and factory location requires its own registration. A fulfillment center opened two years ago without a state registration is not a paperwork gap — it is an active non-compliance issue with interest running.
Confirm also that the entity's HSN classifications on filed returns match what operations actually ship. Mid-cycle product changes are a recurring source of retroactive duty exposure, and the finance team is often the last to know that engineering quietly reformulated a product line.
Weeks Five Through Eight: Read the Filings Like a Skeptic
Red flags in prior filings tend to follow familiar patterns:
- Consistent input credit reversals — often signals unclaimed or misallocated ITC on imports and inter-state transfers
- Late-filing interest entries — small amounts that indicate a process, not an accident, of missing deadlines
- Unreconciled GSTR-2B vs. GSTR-3B mismatches — supplier invoice data that never made it into your credit claims
- Round-number provisions — accruals created by a predecessor who knew something was wrong but couldn't quantify it
Bring your Indian tax advisor into this review early. A local practitioner can read tone into a notice or audit history that a US-based review cannot.
Weeks Nine Through Twelve: Set the Year-End Agenda
Close the quarter by converting findings into a calendar. Which refunds are claimable and approaching limitation deadlines? Which registrations need amendment? Which legacy excise matters require a voluntary disclosure strategy rather than silence?
The goal of the first 90 days is not to fix everything. It is to ensure that by day 91, nothing on your compliance ledger is unknown. Unknown liabilities compound; known ones can be managed, provisioned, or extinguished.
