If you are personally challenging a GST adjudication order communicated to you, the route to examine is ordinarily an appeal under section 107 of the Central Goods and Services Tax Act, 2017 (CGST Act). Revision under section 108 is different: it is a supervisory power exercised by a Revisional Authority over certain subordinate orders, not a substitute appeal that a taxpayer files. The right route and any deadline depend on the order, the authority, the service date, and prior proceedings.
Appeal and revision do different jobs
Section 107 gives a person aggrieved by an adjudicating authority’s decision or order the right to appeal to the Appellate Authority. The appeal can result in confirmation, modification or annulment after further inquiry; the first appellate authority cannot send the case back to the original adjudicating authority.
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Section 108 gives a Revisional Authority supervisory power over specified decisions or orders made by officers subordinate to it. The authority may act on its own motion, on information received, or on a request from a State or Union Territory tax commissioner. Revision is available only against an order that the authority considers erroneous in a way prejudicial to revenue and illegal, improper or made without taking material facts into account. The authority must provide an opportunity of hearing.
These are not two interchangeable remedies. In general, a person contesting an order should assess the appeal route; section 108 concerns the Revisional Authority’s oversight, not a taxpayer’s alternative filing choice.
Compare the routes
| Question | Section 107 appeal | Section 108 revision |
|---|---|---|
| Who acts? | A person aggrieved files an appeal with the Appellate Authority. | The Revisional Authority acts on its own motion, on information received, or on a State or Union Territory tax commissioner’s request. |
| Purpose | Challenges an adjudicating authority’s decision or order. | Supervisory review of a subordinate order meeting the statutory error and revenue-prejudice conditions. |
| Ordinary timing | Three months from communication; the authority may allow a further month for sufficient cause. | Subject to section 108’s restrictions, including the period in section 107(2) and a general three-year limit from the decision or order, with statutory provisos and exclusions. |
| Payment or stay | Requires payment of admitted dues and 10% of the remaining disputed tax. Once the statutory payment is made, recovery of the balance is deemed stayed. | The Revisional Authority may stay operation of the decision or order if necessary while the revision proceeding is pending. Section 108 itself sets no taxpayer pre-deposit formula. |
| Effect of earlier appeal | An order at this stage remains subject to later statutory appellate provisions. | Generally barred if the order has been subject to specified appeals, subject to a limited provision concerning a point not raised and decided in appeal. |
| Possible next level | An appeal to GSTAT may be available under section 112. | An appeal to GSTAT may be available under section 112. |
This comparison describes the CGST Act. State GST and Union Territory GST legislation contains corresponding provisions, but the applicable authority structure and provisions should be checked for the particular order.
If you are challenging an order, check the section 107 appeal
Calculate the limitation period from communication
The ordinary appeal period is three months from the date the decision or order is communicated to you. The Appellate Authority may allow a further month if satisfied that sufficient cause prevented filing within the ordinary period. Record the communication date and verify how service is treated for your order; do not assume that the date printed on the order is necessarily the relevant date.
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Work out the statutory payment
Before an appeal is entertained, the appellant must pay the part of the tax, interest, fine, fee and penalty that is admitted, and 10% of the remaining disputed tax, subject to the statutory cap. The 10% applies to disputed tax, not to every component of the demand. On making the payment required by section 107, recovery proceedings for the balance are deemed stayed. That stay does not cancel or decide the disputed demand.
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The authority may confirm, modify or annul the decision or order after any further inquiry it considers necessary. Section 107 does not permit it to refer the case back to the original adjudicating authority. Keep the relief you seek and the grounds supporting it tied to the actual order and record.
When section 108 revision may apply
Revision is considered by the Revisional Authority, not elected and filed by a taxpayer as an alternative to a section 107 appeal. The authority must apply the statutory threshold: the subordinate order must be erroneous so far as it is prejudicial to the interest of revenue, and it must be illegal or improper or have failed to take account of material facts. The authority must give the affected person an opportunity to be heard.
Section 108 also restricts when revision may be exercised. It is generally unavailable where the order has been subject to the specified appeal proceedings. A narrow proviso addresses a point that was not raised and decided in an appeal; its availability and timing require close application of the statutory text. The section also sets a general three-year limit from the date of the decision or order, subject to its provisos and exclusions. These restrictions make it important to examine the complete procedural history rather than assume revision is always barred—or always available—after an appeal.
Further appeal to GSTAT
A person aggrieved by an order under section 107 or section 108 may have a further appeal to the Goods and Services Tax Appellate Tribunal (GSTAT) under section 112. Section 112 has its own limitation and pre-deposit requirements; do not carry over the section 107 calculation or deadline without checking the Tribunal provision that applies to the order. GSTAT describes its appellate remit and provides for electronic filing. Its portal displayed an extension to July 31, 2026 for specified section 112 filings; that date has passed and is not an open deadline. Check the current official Tribunal notices and portal instructions for any later extension or category-specific direction.
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CBIC’s Appeals and Revision Rules prescribe forms and filing procedures, including acknowledgement conditions, and limit additional evidence to specified circumstances. Since filing mechanics and portal instructions can change, confirm the current rules and portal guidance rather than relying on older hard-copy instructions.
- Identify the exact order, issuing authority and statutory provision.
- Keep the order and evidence of when it was communicated.
- List earlier appeals, revision proceedings, stays and decisions on individual grounds.
- Separate admitted amounts from disputed tax and other components of the demand.
- Check the CGST Act, the applicable State or Union Territory GST Act, current rules and official filing instructions before acting on a deadline or payment requirement.
The CGST Act provisions are available in the CBIC CGST Act, 2017; the procedural requirements are in the CBIC CGST Rules, 2017. GSTAT’s official portal provides Tribunal information and electronic filing access. This is general information about the central statutory framework, not advice on a particular order or case.
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