A GST first appeal under section 107 goes to the prescribed Appellate Authority and generally must be filed within three months of communication of the order. A GSTAT appeal under section 112 is the next statutory level, for challenging an order under section 107 or 108; it generally has a three-month deadline from communication. Their deposits differ: the first appeal requires 10% of the remaining disputed tax after admitted amounts are paid, while a GSTAT appeal requires a further 20% in addition to the first-stage amount. The transition filing date of 31 July 2026 has passed; it was not a general extension for every GSTAT appeal.
Which appeal fits your GST order?
| Question | First appeal | GSTAT appeal |
|---|---|---|
| What order can be challenged? | A decision or order made by an adjudicating authority. | An order made under section 107 (first appeal) or section 108 (revision). |
| Who hears it? | The prescribed Appellate Authority. | The Goods and Services Tax Appellate Tribunal (GSTAT), in the bench and category applicable to the case. |
| Statutory provision | Section 107 of the CGST Act and corresponding State GST or UTGST law. | Section 112 of the CGST Act and corresponding State GST or UTGST law. |
| Taxpayer’s ordinary deadline | Three months from communication of the decision or order. | Three months from communication of the section 107 or section 108 order. |
| Taxpayer’s possible condonation period | Up to one further month, if the Appellate Authority is satisfied that sufficient cause prevented timely filing. | Up to three further months, if GSTAT is satisfied that sufficient cause prevented timely filing. |
| Form under the CBIC appeal rules | FORM GST APL-01. | FORM GST APL-05. |
These are successive routes, not interchangeable choices. A challenge to an adjudication order ordinarily starts at the first appeal level; section 112 is the next statutory appeal after a section 107 order, or applies to a qualifying revision order under section 108. Check the exact order and the law applicable to the relevant State or Union Territory before choosing a route.
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Deadlines: ordinary filing, condonation and the expired transition date
Taxpayer deadlines
For a section 107 first appeal, the three-month period runs from communication of the adjudicating authority’s decision or order. Section 107(4) permits the Appellate Authority to admit an appeal within one further month where sufficient cause for delay is established. That additional month is a discretionary condonation window, not an automatic extension.
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Departmental timelines are different
A Commissioner-directed departmental application under section 107(2) has a six-month period. Under section 112(3), the departmental application period is six months from the date the order was passed. These are not the taxpayer’s deadlines: taxpayers’ periods run from communication, while the section 112 departmental period is stated to run from the date the order was passed.
What the 31 July 2026 transition date covered
The Ministry of Finance stated in its 30 June 2026 PIB release that the due date for the covered transitional GSTAT appeals under section 112(1), read with section 112(3), was extended to 31 July 2026. The GSTAT portal notice also addressed eligible users who encountered registration or e-filing difficulties: they could record their intent by that date, which was to be treated as filing within time. As of 4 October 2026, that date has passed. It concerned the notified transition class, not every appeal, and the reviewed official material does not establish whether a later order changed it.
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The Ministry of Finance cited 30,000 appeals filed in the final 15 days before the then 30 June 2026 deadline and a peak daily filing volume of 5,500 when announcing the extension. Those figures describe the congestion behind that announcement, not current filing volumes.
Where and how to file
First appeal: Appellate Authority, FORM GST APL-01
File the taxpayer’s first appeal with the prescribed Appellate Authority using FORM GST APL-01 under the CBIC appeal rules. The rules provide for electronic filing or another method notified by the Commissioner. They also describe a hard-copy follow-up for supporting materials within seven days under the listed procedure. Check the applicable jurisdiction’s current filing directions rather than assuming that one filing method applies everywhere.
Pay attention to the acknowledgement. Under the rules, the appeal is treated as filed when the final acknowledgement with an appeal number is issued. If supporting documents are submitted late, the rules provide for a later filing date. An initial or provisional receipt alone may therefore not establish the filing date for deadline purposes.
GSTAT appeal: Tribunal, FORM GST APL-05 and portal procedure
The CBIC appeal rules prescribe FORM GST APL-05 for a GSTAT appeal and list a seven-day hard-copy follow-up procedure, with the final acknowledgement and appeal number governing the filing date under that procedure. Separately, GSTAT’s Procedure Rules, 2025 require appeals and applications to be uploaded electronically through the GSTAT portal and provide for electronic processing and communications. Follow the live portal instructions and applicable Presidential orders: portal access or filing eligibility may depend on the case category or order date.
GSTAT describes a Principal Bench in New Delhi and State Benches. Confirm the correct bench and category from current Tribunal orders and portal directions; the available official material does not settle territorial allocation for every State, case type or taxpayer. The Tribunal describes hearings as hybrid, but its Procedure Rules provide for physical hearings or electronic hearings with the President’s permission. A remote hearing is not an entitlement that can be assumed in every case.
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The fee specified in the CBIC appeal rules is ₹1,000 per ₹1 lakh of the tax or input tax credit difference, or relevant fine, fee or penalty, subject to a cap of ₹25,000. Confirm the amount and payment method against the live portal instructions before filing.
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The deposit requirements are cumulative at the two appeal stages; the GSTAT amount does not replace the first-appeal amount.
| Stage | Payment required under the cited sections | Effect on recovery |
|---|---|---|
| First appeal, section 107(6) | Pay the admitted tax, interest, fine, fee and penalty in full, plus 10% of the remaining disputed tax. | Once the required payment is made, recovery proceedings for the balance are deemed stayed under section 107(7). |
| GSTAT appeal, section 112(8) | Pay admitted amounts in full, plus a further 20% of the remaining disputed tax, in addition to the section 107(6) amount. | After payment, section 112(9) provides a stay of recovery for the balance. |
The cited statutory text states these percentages. It does not, by itself, establish every potentially applicable monetary cap or later amendment; do not assume a cap without checking the consolidated law and notifications in force for the relevant date.
Prepare the appeal and protect the filing date
- Identify the challenged order. Note the issuing authority and determine whether the order is an adjudication, a first-appellate order or a revisional order. That determines whether section 107 or section 112 is the relevant route.
- Record when it was communicated. Calculate the ordinary taxpayer deadline from the communication date. Separately record the outer condonation window; do not treat it as time automatically granted.
- Confirm the forum and filing channel. Use the prescribed Appellate Authority for a first appeal. For GSTAT, verify the case category, current portal eligibility, applicable bench directions and current filing procedure.
- Assemble the case record. Keep the impugned order, any prior appeal or application, grounds of appeal, statement of facts, proof of communication, payment or deposit evidence, and supporting records in the currently accepted formats. This is practical preparation guidance, not a claim that every item is mandatory in every case.
- Verify the deposit and acknowledgement. Reconcile admitted and disputed amounts, make the required payments, and track the final acknowledgement and appeal number. Do not rely solely on an initial provisional receipt when establishing the filing date.
Can you add evidence that was not filed earlier?
Additional evidence before either the Appellate Authority or GSTAT is restricted under the CBIC appeal rules. The specified circumstances include an earlier refusal to admit evidence, sufficient cause that prevented its earlier production, or inadequate opportunity to produce it. The authority or Tribunal must record reasons in writing for admitting additional evidence. An appeal is not an unrestricted chance to introduce any material omitted at the earlier stage.
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Repair common Windows errors and clear accumulated junk for a smoother, more stable PC - no reinstall needed.Free scan · no reinstallWhich route should a taxpayer take?
- Adjudicating authority order: assess a section 107 first appeal to the prescribed Appellate Authority.
- Section 107 order: if challenging the first-appellate outcome, assess a section 112 appeal to GSTAT.
- Section 108 revision order: section 112 also provides the GSTAT appeal route for a qualifying revisional order.
- Missed deadline: determine whether the statutory condonation period remains available and prepare to establish sufficient cause; filing within that window does not guarantee admission.
For a live dispute, check the order, the current consolidated CGST and corresponding State or UT provisions, current GSTAT directions and portal instructions. The applicable deadline and filing procedure can turn on the order type, communication date and jurisdiction.
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