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ATO Objection Letter for a GST / BAS Assessment (Australia)
If the Australian Taxation Office has denied your input tax credits, reclassified a supply or assessed extra GST, you can object — but the four-year input tax credit window means timing is everything. Our Australian template produces a formal notice of objection to a GST or BAS assessment under Part IVC of the Taxation Administration Act 1953 (Cth), with issue-aware grounds, a tax-invoice schedule, the four-year window analysis under Division 93 of the GST Act, and a path to the Administrative Review Tribunal (ART) if the Commissioner of Taxation disallows it.
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Notice of Objection — GST / BAS Assessment
Objection Under Part IVC Of The Taxation Administration Act 1953 (Cth) · 8 June 2026
Cedar and Stone Cafe Pty Ltd
140 Marine Parade, Southport QLD 4215
0413 668 204
admin@cedarstonecafe.com.au
8 June 2026
The Commissioner of Taxation
Australian Taxation Office
GPO Box 9990
Brisbane QLD 4001
GPO Box 9990
Brisbane QLD 4001
NOTICE OF OBJECTION — GST / BAS ASSESSMENT
ABN: ABN 29 615 402 118 · Period: Quarter ending 30 September 2024
Dear Commissioner,
On behalf of Cedar and Stone Cafe Pty Ltd, I object to the GST / BAS assessment for the tax period Quarter ending 30 September 2024, notice of which is dated 20 April 2026. This objection is made under Part IVC of the Taxation Administration Act 1953 (Cth) and states the grounds fully and in detail. The net amount in dispute is approximately 11,800.00 AUD. This is a formal objection — not a BAS revision — so that the disputed amounts and the entity's review rights are preserved.
On behalf of Cedar and Stone Cafe Pty Ltd, I object to the GST / BAS assessment for the tax period Quarter ending 30 September 2024, notice of which is dated 20 April 2026. This objection is made under Part IVC of the Taxation Administration Act 1953 (Cth) and states the grounds fully and in detail. The net amount in dispute is approximately 11,800.00 AUD. This is a formal objection — not a BAS revision — so that the disputed amounts and the entity's review rights are preserved.
1.
BUSINESS DETAILS
Entity: Cedar and Stone Cafe Pty Ltd
ABN: ABN 29 615 402 118
GST status: Registered for GST
Address: 140 Marine Parade, Southport QLD 4215
Telephone: 0413 668 204
Email: admin@cedarstonecafe.com.au
ABN: ABN 29 615 402 118
GST status: Registered for GST
Address: 140 Marine Parade, Southport QLD 4215
Telephone: 0413 668 204
Email: admin@cedarstonecafe.com.au
2.
BAS / ASSESSMENT UNDER OBJECTION
Tax period: Quarter ending 30 September 2024
Date of notice / assessment: 20 April 2026
Assessment / reference: GST-ASMT-2026-330814
Net amount in dispute: 11,800.00 AUD
Date of notice / assessment: 20 April 2026
Assessment / reference: GST-ASMT-2026-330814
Net amount in dispute: 11,800.00 AUD
3.
OUTCOME SOUGHT
I respectfully ask the Commissioner to allow this objection and allow the input tax credits claimed. The Commissioner must decide this objection under section 14ZY of the Taxation Administration Act 1953 (Cth) and give written notice of the decision with reasons.
4.
GROUNDS OF OBJECTION
The assessment denied input tax credits on our fit-out and equipment purchases on the basis that the tax invoices were defective. We held valid tax invoices at the time we claimed, and the acquisitions were wholly for our taxable catering business. The credits should be allowed.
5.
DETAILED GROUNDS OF OBJECTION
The assessment denies input tax credits to which the entity is entitled. Under Division 11 of the A New Tax System (Goods and Services Tax) Act 1999 (Cth) an entity is entitled to an input tax credit for a creditable acquisition — an acquisition made for a creditable purpose, where the supply to the entity was a taxable supply, the entity provided consideration, and it is registered or required to be registered. The acquisitions in question meet each limb, and the entity holds valid tax invoices as required by Division 29. I ask the Commissioner to allow the credits.
The correct position: Input tax credits of 11,800 AUD on the September 2024 quarter fit-out and equipment acquisitions should be allowed, reducing the assessed net amount accordingly.
Grounds in detail: Each acquisition was a creditable acquisition: it was made for a creditable purpose in our taxable catering enterprise, the supplies to us were taxable supplies, we provided consideration, and we are registered for GST. We held tax invoices showing the supplier identity and ABN, the date, a description, the GST-inclusive price and the GST amount. Where the auditor considered an invoice incomplete, the supplier has since provided a corrected tax invoice, which we are entitled to hold and rely on. None of the acquisitions was of a private or input-taxed nature.
On any review or appeal of the objection decision, the burden of proving that the assessment is excessive rests on the entity (sections 14ZZK and 14ZZO of the Taxation Administration Act 1953 (Cth)). The tax invoices and evidence scheduled below are provided to discharge that burden.
The correct position: Input tax credits of 11,800 AUD on the September 2024 quarter fit-out and equipment acquisitions should be allowed, reducing the assessed net amount accordingly.
Grounds in detail: Each acquisition was a creditable acquisition: it was made for a creditable purpose in our taxable catering enterprise, the supplies to us were taxable supplies, we provided consideration, and we are registered for GST. We held tax invoices showing the supplier identity and ABN, the date, a description, the GST-inclusive price and the GST amount. Where the auditor considered an invoice incomplete, the supplier has since provided a corrected tax invoice, which we are entitled to hold and rely on. None of the acquisitions was of a private or input-taxed nature.
On any review or appeal of the objection decision, the burden of proving that the assessment is excessive rests on the entity (sections 14ZZK and 14ZZO of the Taxation Administration Act 1953 (Cth)). The tax invoices and evidence scheduled below are provided to discharge that burden.
6.
TAX INVOICE AND EVIDENCE SCHEDULE
A valid tax invoice is required under Division 29 of the A New Tax System (Goods and Services Tax) Act 1999 (Cth) to claim an input tax credit above the low-value threshold. The following tax invoices and supporting records support this objection:
1. Tax invoice — Coastline Commercial Kitchens Pty Ltd (fit-out) (dated 12 August 2024) — supplier ABN, GST-inclusive price 41,800 AUD and GST of 3,800 AUD
2. Tax invoice — Reliant Refrigeration Pty Ltd (cool room) (dated 3 September 2024) — creditable acquisition of refrigeration equipment, GST 2,600 AUD
3. Corrected tax invoice bundle from three suppliers (dated May 2026) — invoices reissued in full form after the audit query
4. Asset register and photographs of installed equipment (dated September 2024) — the equipment is installed and used in the cafe business
All listed items are enclosed with this objection.
Notes on the evidence: The acquisitions are wholly for a creditable purpose; there is no private or input-taxed use, so no apportionment is required.
1. Tax invoice — Coastline Commercial Kitchens Pty Ltd (fit-out) (dated 12 August 2024) — supplier ABN, GST-inclusive price 41,800 AUD and GST of 3,800 AUD
2. Tax invoice — Reliant Refrigeration Pty Ltd (cool room) (dated 3 September 2024) — creditable acquisition of refrigeration equipment, GST 2,600 AUD
3. Corrected tax invoice bundle from three suppliers (dated May 2026) — invoices reissued in full form after the audit query
4. Asset register and photographs of installed equipment (dated September 2024) — the equipment is installed and used in the cafe business
All listed items are enclosed with this objection.
Notes on the evidence: The acquisitions are wholly for a creditable purpose; there is no private or input-taxed use, so no apportionment is required.
7.
TIME LIMITS — INPUT TAX CREDIT AND OBJECTION WINDOW
The input tax credits in dispute are within, but approaching the end of, the four-year limit in Division 93 of the A New Tax System (Goods and Services Tax) Act 1999 (Cth). Under section 93-5 the entitlement ceases four years after the day the GST return for the relevant tax period was due, and the credits are lost unless preserved within that period. This objection is lodged to preserve the credits, and I ask the Commissioner to treat it as protecting the entitlement.
BAS due date for the period: 28 October 2024 (September 2024 quarterly BAS due date)
Detail: Because the four-year window for the September 2024 quarter runs from the BAS due date of 28 October 2024, this objection is lodged to preserve the credits well before that limit expires.
BAS due date for the period: 28 October 2024 (September 2024 quarterly BAS due date)
Detail: Because the four-year window for the September 2024 quarter runs from the BAS due date of 28 October 2024, this objection is lodged to preserve the credits well before that limit expires.
8.
REFUND AND NEXT STEPS
If this objection is allowed, the corrected net amount produces a refund, and I ask that it be paid to the entity's nominated financial institution account, subject to any running balance account offset.
I also ask for interest on any amount overpaid, payable under the Commonwealth interest-on-overpayments legislation, from the date the amount was overpaid until it is refunded.
If the objection is disallowed wholly or in part, I intend to apply to the Administrative Review Tribunal for review of the objection decision under section 14ZZ of the Taxation Administration Act 1953 (Cth), within 60 days of being notified.
I also ask for interest on any amount overpaid, payable under the Commonwealth interest-on-overpayments legislation, from the date the amount was overpaid until it is refunded.
If the objection is disallowed wholly or in part, I intend to apply to the Administrative Review Tribunal for review of the objection decision under section 14ZZ of the Taxation Administration Act 1953 (Cth), within 60 days of being notified.
9.
ACKNOWLEDGEMENT AND DECISION
Please acknowledge receipt of this objection in writing and confirm the lodgment date. I ask for a written objection decision with reasons under section 14ZY of the Taxation Administration Act 1953 (Cth), and that I be contacted if any further information would assist. I reserve all review and appeal rights, including review by the Administrative Review Tribunal and appeal to the Federal Court of Australia.
YOURS FAITHFULLY,
Cedar and Stone Cafe Pty Ltd
Taxpayer
Date: ____________________
TAXPAYER
Cedar and Stone Cafe Pty Ltd
Date: ____________________
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What Is an ATO GST / BAS Objection?
A GST or BAS assessment is a reviewable taxation decision, and you dispute it by lodging an objection under <strong>Part IVC of the Taxation Administration Act 1953 (Cth)</strong>. Under Division 155 of Schedule 1, a GST return is treated as a notice of assessment of the net amount on the day it is lodged. An objection must be in writing and state the grounds fully and in detail — and importantly, it is <strong>not the same as revising a later BAS</strong>: only a formal objection (or a valid claim within the four-year window) preserves disputed credits and your review rights.
The four-year clock is the trap. Under <strong>Division 93 (section 93-5) of the A New Tax System (Goods and Services Tax) Act 1999 (Cth)</strong>, your entitlement to an input tax credit <strong>ceases four years</strong> after the day the BAS for the relevant tax period was due — and once it expires the credit is gone for good, no matter how genuine. The only way to protect a disputed credit is a valid claim or objection within that period. The objection time limit for a GST assessment is likewise generally four years from the notice under section 14ZW.
GST objections turn on the right Division. Denied input tax credits turn on Division 11 (was the acquisition creditable?) and Division 29 (do you hold a valid tax invoice?). A classification dispute turns on section 9-5 against the GST-free rules in Division 38 and the input-taxed rules in Division 40. Margin-scheme disputes turn on Division 75, and apportionment on Division 129. Because you carry the burden of proving the assessment excessive, a numbered tax-invoice schedule is what wins the objection.
What's Covered in This Template
The letter follows the structure a GST objection officer works through — entity, period, outcome, grounds, tax invoices — and adapts to the kind of GST dispute you are raising.
Issue-Aware GST Grounds
Choose denied input tax credits, classification, margin scheme or apportionment — the Expert grounds clause writes the matching Division (11, 38/40, 75 or 129) around your facts.
Four-Year ITC Window
Pins the BAS due date and shows where you sit against the Division 93 four-year limit, lodging the objection expressly to preserve credits before they burn.
Tax Invoice Schedule
A numbered list of tax invoices — supplier, ABN, date, GST amount — plus any corrected invoices obtained after an audit, satisfying the Division 29 requirement.
Classification & Margin Scheme
Frames a wrongly taxed supply against the GST-free and input-taxed rules, or a margin-scheme miscalculation against Division 75.
Apportionment Methodology
Sets out a fair and reasonable apportionment of credits for partly creditable acquisitions, with the Division 129 adjustment rules.
Refund & Interest
Claims a refund of the corrected net amount and interest on any overpaid amount, subject to running balance account offset.
ART / Federal Court Path
Records whether you will seek review at the Administrative Review Tribunal or appeal to the Federal Court of Australia within the 60-day limit.
Single-Signer Letter Format
Letterhead, the Commissioner of Taxation as recipient, subject line and a single signature block — ready to lodge through Online services for business or post.
How to Create an ATO GST / BAS Objection
Five steps from a GST assessment to a lodged objection.
- 1
Identify the Period and Assessment
Note the tax period, the date of the notice and any reference. The four-year input-tax-credit clock and the four-year objection window both run from dates tied to that period.
- 2
Say What You Want
Choose the outcome — allow the credits, amend and reduce the net amount, or set the assessment aside — and add two or three sentences on why it is wrong.
- 3
Build the Grounds (Expert)
Pick the issue — input tax credits, classification, margin scheme or apportionment — and the template writes the matching GST framework around your facts.
- 4
Schedule the Tax Invoices (Expert)
List each tax invoice and record with its date and what it proves — supplier ABN, GST amount, creditable use — including any corrected invoices.
- 5
Lodge Within the Window
Lodge through Online services for business, your registered agent or by post, before the four-year limit, and keep a dated copy to fix the lodgment date.
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Legal Considerations
GST objections sit inside Part IVC, but the four-year input-tax-credit window can defeat a valid claim on timing alone.
This template provides general information for Australian businesses and is not tax or legal advice. For complex GST disputes — large amounts, going-concern or margin-scheme questions, or property and financial-supply issues — get advice from a registered tax agent or tax lawyer. Complaints about ATO conduct can go to the Inspector-General of Taxation and Taxation Ombudsman.
Reviewed for Australian tax law
Objecting Under Part IVC
A GST or BAS assessment is a reviewable taxation decision disputed by an objection under <strong>Part IVC of the Taxation Administration Act 1953 (Cth)</strong>, stating the grounds fully and in detail (s 14ZU). Under Division 155 of Schedule 1, a GST return is treated as a notice of assessment of the net amount on lodgment. Revising a later BAS is not an objection and does not preserve your review rights — only a Part IVC objection does that.
The Four-Year Input Tax Credit Window (Division 93)
Under <strong>Division 93 (section 93-5) of the A New Tax System (Goods and Services Tax) Act 1999 (Cth)</strong>, your entitlement to an input tax credit ceases four years after the day the BAS for the relevant tax period was due. Once that period passes the credit cannot be revived, however genuine the claim. A valid claim or objection within the period is the only way to protect it — which is why the template pins the BAS due date and lodges expressly to preserve the credits.
Input Tax Credits and Tax Invoices
Division 11 of the GST Act gives an entitlement to an input tax credit for a creditable acquisition — made for a creditable purpose, where the supply to you was taxable, you provided consideration, and you are registered. Division 29 requires a valid <strong>tax invoice</strong> to claim the credit above the low-value threshold. The template schedules your tax invoices and any corrected invoices, which is what an objection officer checks first.
Classification, Margin Scheme and Apportionment
A supply is taxable under section 9-5 unless it is GST-free (Division 38) or input-taxed (Division 40); a wrong classification overstates the net amount. The margin scheme (Division 75) calculates GST on the margin rather than the full price. Where an acquisition is only partly creditable, the credit is apportioned and Division 129 deals with later adjustments. The template frames the grounds for whichever issue applies.
After the Objection — ART or Federal Court
If the Commissioner of Taxation disallows the objection, you may apply to the <strong>Administrative Review Tribunal</strong> (which replaced the former tribunal on 14 October 2024) for a review, or appeal to the <strong>Federal Court of Australia</strong> — within 60 days of the objection decision (s 14ZZ; s 14ZZN for the Court). For an income tax assessment, use our ATO income tax objection template; for penalties and interest, our ATO penalty and interest remission request; and to arrange a GST debt, our ATO payment plan request.
Frequently Asked Questions
Protect Your Credits — Object Before the Four-Year Window Closes
Create your ATO GST / BAS objection in minutes: issue-aware grounds, a tax-invoice schedule and the Division 93 four-year window analysis, in formal Australian letter format. Download the PDF free, or unlock Expert for the full grounds, evidence and refund sections.
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