A GST appeal is filed in Form APL-01 before the Appellate Authority under section 107, within 3 months of the order being communicated to you, plus 1 month if there was good reason for the delay. Before filing, you pay the admitted amount in full and 10% of the remaining tax in dispute (at most ₹20 crore), and once that is paid, recovery of the balance is deemed stayed. We prepare the grounds and papers and file as your authorised representative; a CA or advocate reviews matters needing legal representation, and hearings go to a partner.
An appeal asks a senior officer, the Appellate Authority, to look again at an order passed by an adjudicating authority (section 107(1)). It is the step after an order, not a reply: a show-cause notice has no appeal because it is not yet an order. Rule 109A names the authority: the Commissioner (Appeals) where the order was passed by an Additional or Joint Commissioner, and an officer not below Joint Commissioner (Appeals) where it was passed by a Deputy or Assistant Commissioner or a Superintendent.
What you have, Appeal under section 107?, Note
The 10% is on the tax in dispute; disputed interest, fine and penalty need no pre-deposit unless the order is penalty-only. Once it is paid, recovery of the balance is deemed stayed (section 107(7)). The Finance Act 2025 replaced the earlier 25% pre-deposit for a penalty under section 129(3). Which electronic ledger may be used has been litigated, so we confirm before payment. We never estimate the amount here.
These are estimates from the date you enter. The date the order was communicated to you is the one that counts.
Fresh evidence can be offered, and a ground left out of the appeal can be added at the hearing only if the omission was not wilful or unreasonable (section 107(10)). Account numbers on statements may be masked.
Form, What it is, Rule
Hearing: The Appellate Authority must give you a hearing and can adjourn it for sufficient cause, but not more than 3 times (section 107(8), (9)).
A second appeal lies to the GST Appellate Tribunal in Form APL-05 (section 112), within 3 months of the Appellate Authority's order being communicated, or the date the Government notifies, whichever is later. The Tribunal may admit it up to 3 months late for sufficient cause. You pay the amount under section 107 and a further 10% of the remaining tax in dispute, at most ₹20 crore, and recovery of the balance is then deemed stayed.
StampMitra / A CA or advocate partner / Not promised
Government fee: the Act prescribes none for the first appeal. The admitted amount and the pre-deposit are paid to the government and are not our fee. We confirm the exact amounts before filing.
Any person aggrieved by a decision or order passed by an adjudicating authority (section 107(1)). A show-cause notice is not an order, so you reply to it instead. The order itself is what you appeal.
3 months from the date the order is communicated to you. The Appellate Authority can allow 1 more month if you show sufficient cause (section 107(4)). There is no longer extension in the Act.
No. You pay in full the part of the tax, interest, fine, fee and penalty that you admit, plus 10% of the remaining tax in dispute (section 107(6)). The rest of the demand stays in dispute.
Yes. Under the CGST Act the 10% is capped at ₹20 crore (it was ₹25 crore until 31 October 2024). The State Act and integrated tax have their own limits, which we confirm for your order.
Once you have paid the admitted amount and the pre-deposit, recovery of the balance is deemed stayed (section 107(7)). Without that, the officer can recover under section 79 once the three months to pay under section 78 are over, or sooner if he records reasons.
Rule 109A: the Commissioner (Appeals) where the order was passed by an Additional or Joint Commissioner, and an officer not below Joint Commissioner (Appeals) where a Deputy or Assistant Commissioner or a Superintendent passed it.
The Act lets the Appellate Authority admit an appeal only up to 1 month after the 3 months. Other remedies depend on the facts and need a CA or advocate. Tell us anyway and we say so before you pay.
At the hearing, the Appellate Authority may allow a ground you left out if it is satisfied the omission was not wilful or unreasonable (section 107(10)). It is better to put every ground in the appeal.
The Appellate Authority can confirm, modify or annul the order. An order that raises a fee, fine or penalty, or reduces a refund or credit, cannot be passed unless you are first given a reasonable chance to show cause (section 107(11)).
The law asks the Appellate Authority to decide within 1 year of filing where it is possible (section 107(13)). We cannot promise a date or an outcome.
Both exist. An appeal against the cancellation order (REG-19) lies within 3 months; revocation is a separate application with its own time limit. Check the revocation page first, and an expert helps you choose.
Yes, to the GST Appellate Tribunal in Form APL-05 under section 112, with a further pre-deposit. It is argued before the Tribunal, so a partner CA or advocate handles it.
No. StampMitra is a filing assistance platform. We prepare the grounds and papers and file as your authorised representative, and a CA or advocate reviews matters needing legal representation.