The Principal Bench of the Goods and Services Tax Appellate Tribunal (GSTAT) has introduced a special token based mechanism that will allow appellants to preserve their statutory right to appeal even if the complete appeal cannot be filed before the deadline due to portal-related issues.
The order notes that the online GSTAT e-filing portal, operational since September 24, 2025, is fully functional and appeals under Section 112 of the Central Goods and Services Tax (CGST) Act, 2017 are being filed electronically. It further records that the due date for filing appeals under Sections 112(1) and 112(3) has already been extended to July 31, 2026.
Recognizing that some appellants may continue to encounter technical or procedural hurdles while filing appeals before the extended deadline, the GSTAT has exercised its powers under Rule 123 of the Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025, to implement an additional safeguard. Under the new mechanism, an appellant can submit minimal details on the GSTAT portal to generate a token evidencing the intention to file an appeal on or before July 31, 2026.
The Tribunal clarified that obtaining the token on or before July 31, 2026, will be treated as sufficient compliance with the statutory filing deadline. Once the token is generated, the appellant will be allowed to complete the actual filing of the appeal within 60 days from the date of token generation without losing the benefit of filing within the prescribed limitation period.
An advisory issued along with the order explains that taxpayers experiencing filing issues should use the prescribed token generation form available through the GSTAT e-filing portal. Upon successful submission of the required information, the system will generate a Token ID along with the date and time of its generation. This token serves as electronic evidence that the appellant attempted to initiate the appeal before the statutory deadline.
The advisory further specifies that if the appellate order is already available on the GST portal, users must provide the corresponding 16-digit ARN/CRN while generating the token. Where the order is not available online, appellants may instead furnish the Order Number, Reference Number, or File Number, together with the relevant tax period. The token generation facility is available to persons holding a GSTIN, Temporary ID, UIN, or TDS Registration Number.
Importantly, the Tribunal has clarified that each appeal requires a separate token. A single token cannot be used for multiple appeals, meaning taxpayers filing more than one appeal must generate an equivalent number of tokens.
The advisory also provides relief to appellants who are unable to complete the appeal filing before the statutory deadline due to technical issues. It states that where a valid token has been generated on or before July 31, 2026, the appellant will be treated as an exception if the appeal could not be filed within the prescribed period because of portal-related or similar difficulties. In such cases, delay fees will not be required, subject to verification and compliance with the applicable legal provisions.
However, the Tribunal has also emphasized that the benefit is not indefinite. The appeal must be fully filed within 60 days from the date of token generation, failing which the token will automatically lapse and no filing can thereafter be made on its basis.
The GSTAT has advised taxpayers and authorized representatives to generate the required token on or before July 31, 2026, if they experience any filing-related issues, and to ensure that complete and accurate particulars are furnished. The advisory cautions that tokens generated using incomplete or inaccurate information may be treated as void, potentially depriving appellants of the intended relaxation.
