Section 145 at a Glance
Contents
1. Statutory Text of Section 145
(1) Notwithstanding anything contained in any other law for the time being in force,—
(a) a micro film of a document or the reproduction of the image or images embodied in such micro film (whether enlarged or not); or
(b) a facsimile copy of a document; or
(c) a statement contained in a document and included in a printed material produced by a computer, subject to such conditions as may be prescribed; or
(d) any information stored electronically in any device or media, including any hard copies made of such information,
shall be deemed to be a document for the purposes of this Act and the rules made thereunder and shall be admissible in any proceedings thereunder, without further proof or production of the original, as evidence of any contents of the original or of any fact stated therein of which direct evidence would be admissible.
(2) In any proceedings under this Act or the rules made thereunder, where it is desired to give a statement in evidence by virtue of this section, a certificate,—
(a) identifying the document containing the statement and describing the manner in which it was produced;
(b) giving such particulars of any device involved in the production of that document as may be appropriate for the purpose of showing that the document was produced by a computer,
shall be evidence of any matter stated in the certificate and for the purposes of this sub-section it shall be sufficient for a matter to be stated to the best of the knowledge and belief of the person stating it.
2. Section 145 Explained in Simple Language
GST compliance is now heavily digital. Businesses maintain accounting records in ERP systems, generate invoices electronically, receive emails, download portal reports, store spreadsheets and retain electronic documents on computers, servers and other devices.
Section 145 recognises several such forms of information as “documents” for the purposes of the CGST Act and rules. It also provides for their admissibility in GST proceedings without requiring production of the original in the situations covered by the section.
Why is this important?
- GST investigations frequently involve computer-generated records.
- ERP systems may contain millions of transaction entries.
- Paper originals may not exist for every electronic transaction.
- Tax authorities may rely on electronic data obtained from systems or devices.
- Businesses need a reliable method of explaining where a report came from and how it was generated.
3. Four Types of Records Covered by Section 145(1)
| Clause | Record type | Simple example |
|---|---|---|
| (a) | Microfilm or reproduction of images in a microfilm | Archived document image reproduced from microfilm. |
| (b) | Facsimile copy of a document | A faxed reproduction of a signed document. |
| (c) | Statement in a document included in computer-produced printed material, subject to prescribed conditions | Computer-generated accounting or transaction report printed from a system. |
| (d) | Information stored electronically in a device or media, including hard copies made from that information | ERP data, electronic files or information stored on a computer/device. |
4. Microfilms and Reproductions
Microfilm is an older document-storage technology, but Section 145 expressly recognises a microfilm of a document or reproduction of the images embodied in it, whether enlarged or not.
The provision is technologically broader than a simple paper-original approach: a properly covered reproduction can be treated as a document for GST purposes.
A company has archived historical accounting documents on microfilm. A relevant document is later required in a GST proceeding. The statutory provision can recognise the microfilm or its image reproduction as a document.
For practical modern businesses, this clause is less frequently encountered than electronic records, but it remains part of the statutory framework.
5. Facsimile Copies
A facsimile copy is expressly included in Section 145(1)(b). A fax reproduction therefore does not become irrelevant merely because it is a reproduction rather than the original paper document.
A vendor had sent a signed agreement by fax years earlier. The original is no longer readily available, but the fax copy remains in the company's records. Section 145 provides the statutory basis for treating the specified facsimile copy as a document for GST purposes.
6. Computer Printouts
Section 145(1)(c) addresses a statement contained in a document and included in printed material produced by a computer, subject to prescribed conditions.
This is important for accounting and tax teams because many GST workings are produced from ERP systems, accounting software and spreadsheets.
| Computer output | Examples | What to preserve |
|---|---|---|
| Ledger report | Supplier ledger, customer ledger, tax ledger | Source ledger, report period, filters and system source. |
| Invoice report | Sales/purchase invoice listing | Source transactions and report-generation parameters. |
| GST reconciliation | Purchase register vs GSTR-2B report | Original files, mapping logic and final report. |
| Tax computation | GST liability or ITC working | Underlying transaction data and formulas. |
7. Electronically Stored Information
Section 145(1)(d) covers any information stored electronically in any device or media, including hard copies made of that information.
This is particularly relevant to present-day GST records. Electronic information can exist on computers, servers, storage media and other electronic devices or media.
Examples of potentially relevant electronic information
- ERP transaction databases and exported reports.
- Accounting software data.
- Electronic invoices and related files.
- Spreadsheets and reconciliation workbooks.
- Emails and electronic correspondence.
- Digital copies of agreements and supporting documents.
- Data exports supplied during a GST investigation.
- Electronic records of purchases, sales, inventory and payments.
8. Certificate Under Section 145(2)
Section 145(2) is important when a statement is sought to be given in evidence by virtue of Section 145. The certificate is intended to identify the document and explain how it was produced, including relevant particulars of the device involved in production.
The certificate identifies
- The document: what document contains the statement.
- Production method: how the document was produced.
- Device particulars: relevant information about the device involved in production, sufficient to show that the document was produced by a computer.
- Knowledge and belief: the statute provides that, for this subsection, it is sufficient for the matter to be stated to the best of the knowledge and belief of the person making the statement.
9. Is the Original Always Required?
Section 145 expressly provides that the specified records shall be admissible in proceedings under the Act and rules, without further proof or production of the original, as evidence of the contents or facts for which direct evidence would be admissible.
This is an important statutory facilitation for electronic and reproduced records. However, businesses should not interpret it as a licence to destroy originals or source data.
10. Detailed Practical Examples
A GST officer requests a supplier ledger. The company generates the ledger from its ERP for the relevant period. Section 145 is relevant to the statutory treatment of the computer-produced record.
A company prints its monthly sales register from accounting software. The report is accompanied by the underlying system data and report parameters.
A finance team produces a purchase register and reconciliation report generated from an internal system. Preserve the purchase data, source GSTR-2B files and reconciliation logic.
An invoice exists primarily in electronic form. The business maintains the electronic file and associated accounting entry instead of relying only on a printed copy.
An email exchange explains why an invoice was cancelled and reissued. The original email chain and attachment are preserved to maintain context.
A taxpayer disputes a report produced by an external system. The appropriate response is to examine the source, extraction method, filters, system records and supporting transaction documents.
A report is printed from electronically stored information. Section 145(1)(d) expressly includes hard copies made of electronically stored information.
A legacy business record is available as a microfilm reproduction. The statutory provision expressly recognises microfilm and image reproductions.
A signed document was transmitted by fax. The retained facsimile copy can fall within Section 145(1)(b).
A company migrated from one accounting system to another. During a later GST proceeding, it should preserve migration reports and legacy exports so that historical data can be explained.
A GST calculation is prepared in Excel using imported ERP data. The company should retain the source export, workbook version and relevant formulas or transformation steps.
A business uses a hosted accounting platform. It should maintain reliable exports and documentation explaining the source system and report-generation process.
11. ERP, Excel and GST Data: How Finance Teams Should Prepare
For a finance department, Section 145 has practical significance whenever a tax position depends on a report generated by software.
| Record | Recommended evidence pack |
|---|---|
| Purchase register | ERP export + source invoices + vendor master + period/filter details. |
| Sales register | ERP export + invoice series + credit/debit notes + GST return reconciliation. |
| GSTR-2B reconciliation | Original portal file + purchase register + matching logic + exception report. |
| GSTR-1 working | Sales data + amendment records + return filing acknowledgement. |
| GSTR-3B working | Tax liability/ITC workings + ledgers + return acknowledgement + payment details. |
| Trial balance | ERP export + period lock information + ledger mapping + financial statements. |
Recommended document naming
Use consistent names such as GSTIN_FY_Period_ReportType_ExtractionDate_Version. This makes later identification much easier when thousands of files are involved.
12. Evidence-Readiness Controls for a Company
- Maintain read-only archives of important GST reports after filing.
- Preserve the original source export before editing an Excel working file.
- Record report filters such as date range, GSTIN, branch and ledger selection.
- Use version control for reconciliation and tax workings.
- Restrict unauthorised editing of source accounting data.
- Maintain backups and test restoration periodically.
- Keep portal downloads with the period and GSTIN clearly identified.
- Retain return acknowledgements and payment challans with the underlying workings.
- When a dispute arises, preserve relevant records instead of overwriting them.
- Document major ERP migrations and data conversions.
13. Section 144 vs Section 145
| Point | Section 144 | Section 145 |
|---|---|---|
| Main subject | Presumption as to specified documents in certain cases. | Admissibility of specified reproduced and electronic records. |
| Core issue | What the court may presume about certain documents. | Whether specified reproductions/electronic information can be treated as documents and admitted as evidence. |
| Digital records | Not its central subject. | Expressly covers information stored electronically in any device or media. |
| Original | Deals with presumptions concerning specified documents. | Expressly permits covered records to be admitted without further proof or production of the original, subject to the section. |
| Certificate | No comparable certificate mechanism in Section 144. | Section 145(2) provides a certificate mechanism for statements sought to be given in evidence by virtue of the section. |
These sections work differently and should not be treated as interchangeable.
14. Common Mistakes
“A PDF is automatically correct because Section 145 covers electronic information.”
No. Admissibility and factual correctness are different questions. Preserve the source and supporting evidence.
“The original can always be destroyed.”
Section 145 may remove the need for production of the original in the covered evidentiary situation, but retaining originals/source data remains prudent.
“Every Excel file is automatically reliable.”
An Excel file may be edited, filtered or transformed. Keep the source export and document the processing.
“A computer printout needs no explanation.”
Section 145(2) specifically addresses certification where a statement is sought to be given in evidence by virtue of the section.
“Electronic records are only relevant to criminal cases.”
No. Section 145 applies to proceedings under the CGST Act and rules.
“Printing an ERP report changes its evidentiary status.”
The statutory framework expressly contemplates computer-produced printed material and hard copies of electronically stored information.
15. Questions People Commonly Search
- What is Section 145 of the CGST Act?
- What is Section 145 GST in simple language?
- Is electronic evidence admissible under GST?
- Can an ERP printout be used as GST evidence?
- Can computer printouts be evidence under the CGST Act?
- What is Section 145(2) certificate?
- Is the original document required under Section 145?
- Are electronic records recognised under the CGST Act?
- Can Excel reports be used in GST proceedings?
- What is the difference between Section 144 and Section 145?
- How should a company preserve GST electronic records?
- What documents are covered by Section 145 CGST Act?
16. Frequently Asked Questions
1. What is Section 145 of the CGST Act?
It provides for admissibility of specified microfilms, facsimile copies, computer-produced material and electronically stored information as documents and evidence in proceedings under the Act and rules.
2. Does Section 145 recognise electronic records?
Yes. Section 145(1)(d) expressly covers information stored electronically in any device or media, including hard copies made from that information.
3. Can a computer printout be used as evidence?
Yes, Section 145(1)(c) specifically addresses statements included in printed material produced by a computer, subject to prescribed conditions.
4. Does Section 145 apply to Excel reports?
An Excel report can fall within the broader electronic/computer-generated record framework depending on how it was produced and the applicable conditions. Preserve the source data and report-generation details.
5. Is the original document always required?
No. For records covered by Section 145, the provision states that they are admissible without further proof or production of the original, subject to the statutory framework.
6. What is Section 145(2)?
It provides a certificate mechanism identifying the document, describing how it was produced and giving appropriate particulars of the device involved in producing it.
7. Does Section 145 make every electronic file automatically genuine?
No. Admissibility is different from proving every factual assertion or calculation contained in a record.
8. Does Section 145 cover emails?
Electronic information can fall within the broad wording of Section 145(1)(d), depending on the circumstances and applicable evidentiary requirements. Preserve the original email and relevant metadata/context where available.
9. Does Section 145 cover ERP data?
Electronic information stored in an accounting or ERP environment can fall within Section 145(1)(d). The business should preserve reliable source data and explain the extraction process.
10. Does Section 145 apply only to tax authorities?
No. It is an evidentiary provision for proceedings under the CGST Act and rules; its practical relevance depends on the particular proceeding and record.
11. What should a company retain with an electronic GST report?
Retain the source export, report period, filters, GSTIN, system/source details, version history and supporting accounting documents.
12. What is a facsimile copy?
It is a reproduction of a document transmitted or reproduced through facsimile technology. Section 145(1)(b) expressly includes a facsimile copy.
13. What is a microfilm reproduction?
Section 145(1)(a) covers a microfilm of a document or reproduction of images embodied in the microfilm, whether enlarged or not.
14. Does Section 145 create a tax demand?
No. It concerns documentary status and admissibility, not the substantive computation of GST liability.
15. Is Section 145 still relevant in 2026?
Yes. Current consolidated materials continue to list Section 145 as an in-force provision of the CGST Act.
17. Quick Revision – Section 145
- Section 145 = admissibility of specified reproduced and electronic records.
- Microfilms and reproductions are covered.
- Facsimile copies are covered.
- Computer-produced printed material is covered subject to prescribed conditions.
- Electronically stored information in a device or media is covered.
- Hard copies made from electronic information are expressly included.
- Covered records can be admitted without further proof or production of the original, subject to the statutory framework.
- Section 145(2) provides a certificate mechanism identifying the document and production method/device particulars.
- Admissibility does not automatically establish factual correctness.
- Finance teams should preserve source data, report parameters, versions and supporting records.
18. Legal Disclaimer
This page is provided for general educational and compliance-workflow purposes. The evidentiary treatment of electronic and reproduced records can depend on the exact proceeding, applicable rules and other laws. Verify the law applicable to the relevant period and obtain professional advice where appropriate. This page is not a substitute for professional legal advice.