The Goods and Services Tax Appellate Tribunal (GSTAT) has issued a significant directive mandating that all appeals and applications under Sections 107 and 108 of the CGST Act, 2017, be filed exclusively through its newly developed online portal.
The move, aimed at streamlining the appeals process, comes with a staggered filing schedule to prevent system overload and ensure smooth functioning.
According to the order issued by GSTAT President Justice Sanjaya Kumar Mishra, information received from GSTN revealed that a massive volume of appeals has already been filed before first appellate authorities under Section 107. Many of these cases, along with revisional authority decisions under Section 108, are now appealable before the GSTAT.
However, the National Informatics Centre (NIC), which developed the portal, has flagged potential capacity and concurrency issues if too many appellants attempt to file appeals simultaneously. To mitigate risks such as portal crashes and user inconvenience, GSTAT has invoked powers under Rule 123 of the GSTAT (Procedure) Rules, 2025, to prescribe a phased filing mechanism.
Key Features of the Order
- Mandatory E-Filing – All appeals must be filed electronically in prescribed forms (GST APL-01, GST APL-03, or GST RVN-01) on the GSTAT portal.
- Staggered Timelines – Appeals have been divided into categories based on when they were originally filed before the appellate or revisional authority.
Appeals filed up to 31 January 2022 must be submitted between 24 September 2025 and 31 October 2025, but no later than 30 June 2026.
Appeals filed between 1 February 2022 and 28 February 2023 must be submitted between 1 November 2025 and 30 November 2025.
Appeals filed between 1 March 2023 and 31 January 2024 must be submitted between 1 December 2025 and 31 December 2025.
Appeals filed between 1 February 2024 and 31 May 2024 must be submitted between 1 January 2026 and 31 January 2026.
Appeals filed between 1 June 2024 and 31 March 2026, as well as all pending cases, must be submitted between 1 February 2026 and 30 June 2026.
- Final Deadline – No appeal under Section 112 of the CGST Act can be filed beyond 30 June 2026 under this staggered scheme.
Objective of the Directive
The phased approach is designed to balance technological capacity with taxpayer convenience, ensuring the portal does not suffer from sudden surges in usage. The Tribunal emphasized that the order was framed to “remove any difficulty” that could arise from simultaneous mass filings.
Notification Details
Date: 24-09-2025
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