If you disagree with a GST adjudication order, you can generally file a first appeal under section 107 of the CGST Act with the Appellate Authority. The usual deadline is three months from when the order is communicated. You must pay the amount you accept as payable and a pre-deposit equal to 10% of the remaining disputed tax. The appeal is treated as filed only after the authority issues the final acknowledgement in FORM GST APL-02.
First check that you have an appealable order
Section 107(1) allows a person aggrieved by a decision or order of an adjudicating authority under the CGST Act, or the corresponding State or Union Territory GST Act, to appeal to the Appellate Authority. This route concerns an order that has been issued and communicated; it is not the procedure for replying to a show-cause notice before an order exists.
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Read the order and identify the issuing authority, order type, tax period, demand components, date of communication, and any amounts already paid. Separate the amount you accept from the tax you dispute. The precise order, applicable State or Union Territory provisions, payment history, and jurisdiction can affect what you need to file.
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The ordinary section 107 deadline is three months from communication of the order, not simply the date printed on it. Keep evidence of when and how the order was communicated, and calculate the deadline from that date.
The Appellate Authority may allow up to one further month if it is satisfied that sufficient cause prevented filing within the ordinary period. This extension is discretionary, not automatic. If you may be late, prepare a clear account of the delay and records supporting it; do not assume that submitting an appeal within the extra month guarantees acceptance.
Calculate the payment required before appealing
Before the appeal can proceed, section 107(6) requires you to pay in full the portion of the order you admit is payable, plus 10% of the remaining disputed tax. The 10% is calculated on disputed tax, not on the entire demand including every component. Work from the figures and prior-payment information applicable to your order, and check the portal’s calculation before submitting.
After the statutory amount is paid, recovery proceedings for the balance are deemed stayed under section 107(7). The Act says: “Where the appellant has paid the amount under sub-section (6), the recovery proceedings for the balance amount shall be deemed to be stayed.” This stay follows the statutory payment; it is not a decision that the underlying demand is incorrect.
Check whether earlier payments are linked to the demand
A payment made through the portal’s “Payment towards Demand” functionality is adjusted against the demand ID in the Electronic Liability Register. A payment made through FORM GST DRC-03 is not automatically connected to that demand ID and may not be reflected in the portal’s appeal calculation.
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GSTN’s DRC-03A facility links a DRC-03 payment to the relevant demand order so the system can recognize it against the demand. Check your ledger and demand ID before assuming a payment was either lost or counted. If an earlier payment is missing from the portal calculation, investigate its mapping before paying again.
Prepare FORM GST APL-01 and supporting papers
File the appeal in FORM GST APL-01 with your grounds of appeal and verification. The appeal rules require the certified copy of the order and supporting documents to be submitted within seven days. If those documents are submitted late, the filing date shifts to the date they are submitted, which can matter near the limitation deadline.
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Set out the grounds clearly and connect each ground to the relevant part of the order and supporting record. The evidence you rely on also matters: additional evidence that was not produced before the adjudicating authority is generally restricted on appeal.
When additional evidence may be considered
The appeal rules list exceptions, including where the adjudicating authority refused evidence that should have been admitted; sufficient cause prevented you from producing it earlier; or the order was made without sufficient opportunity to produce relevant evidence. The Appellate Authority must record written reasons for admitting additional evidence. Explain why the material matters and, where applicable, why it could not be produced earlier; admission is not guaranteed.
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- Review the order and timeline. Note the authority, order type, communication date, tax period, demand components, admitted amount, disputed tax, and payments already made.
- Prepare the appeal papers. Complete FORM GST APL-01, including grounds and verification, and assemble the certified order and supporting documents for submission within the prescribed seven days.
- Check the payment calculation. Pay the admitted amount in full and 10% of the remaining disputed tax. Confirm that prior payments appear against the relevant demand ID.
- Start the portal application. The GST portal FAQ directs users to Services > User Services > My Applications, then to select Appeal to Appellate Authority, start a new application, and select Demand Order. Portal menus can change, so check the current portal instructions if labels or steps differ.
- Submit the required papers and retain proof. Submit the certified order and supporting documents within seven days, and keep proof of submission.
- Track the final acknowledgement. Retain FORM GST APL-02 and its appeal number. Under the appeal rules, the appeal is treated as filed only when this final acknowledgement is issued; submitting the online form alone is not the endpoint.
What the Appellate Authority can do
The Act requires an opportunity of hearing and a written order stating the points for determination, the decision, and the reasons. The Appellate Authority may confirm, modify, or annul the appealed order, subject to statutory limits. The Act says the authority should, where possible, hear and decide the appeal within one year; this is a statutory aim, not a guaranteed resolution deadline.
Do not confuse the first appeal with other remedies
| Situation | How it differs from a section 107 first appeal |
|---|---|
| You have received a show-cause notice but no adjudication order | The first appeal described here is against an adjudicating authority’s decision or order, not a response to a notice before the order exists. |
| You are considering correction of an apparent error | Rectification is a distinct remedy with its own trigger and requirements; it is not the section 107 appeal procedure. |
| You disagree with the first appellate decision | A later appeal is a separate stage. The material here does not establish a universal filing procedure for every subsequent forum or State, so verify the forum and current requirements for the particular case. |
For a live demand, assess the appealable order, communication date, remaining limitation period, disputed-tax calculation, payment mapping, and the grounds and evidence already presented during adjudication. The central procedure is set out in section 107 of the CGST Act and the CBIC appeal rules; portal guidance and system handling are addressed in the GST portal FAQ and GSTN’s DRC-03 payment-mapping advisory. Rules and portal behavior can change, so check the current official materials and the particular order before acting. Case-specific advice from a qualified GST professional may be appropriate where limitation, grounds, or payment calculations are uncertain.
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