The Goods and Services Tax Appellate Tribunal (GSTAT) has disposed of only 83 cases despite receiving more than 75,000 appeals, highlighting the enormous task before the newly operational appellate mechanism.
According to data available on the GSTAT portal as of Sunday, 75,155 cases had been filed, but only 5,819 cases had been registered. Of these, merely 83 cases had been disposed of.
The figures underline both the rapid growth in GST litigation reaching the second appellate stage and the considerable gap between the number of appeals filed, registered and finally decided.
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Over 3,400 Appeals Filed in August Alone
The pace of filings has increased sharply. During August alone, taxpayers and tax authorities filed 3,492 cases, pushing the cumulative number of appeals beyond the 75,000 mark.
The Principal Bench in New Delhi has received 7,306 cases. However, only 134 cases have been registered, of which seven have been disposed of. The remaining registered matters continue to be pending before the Bench.
The GSTAT e-filing portal became operational on September 24, 2025, finally providing taxpayers with an operational platform to challenge orders before the Tribunal after a prolonged wait for the constitution and functionalisation of the GST appellate framework.
Deadline Was Extended Due to Rush and Technical Difficulties
The government had initially faced a significant rush of appeals as taxpayers attempted to file matters before the prescribed deadline. Technical difficulties on the e-filing system and the heavy volume of filings led to an extension of the deadline for filing appeals before GSTAT until July 31.
To further assist taxpayers whose appeals were approaching the deadline, the Tribunal introduced a token facility on its e-filing portal.
Under this mechanism, taxpayers who generated a token on or before July 31 were allowed an additional 60 days to complete their appeal filing process.
The data presented by GSTAT President Justice (Retd.) Sanjaya Kumar Mishra showed that approximately 30,000 tokens had been generated. However, a large number of these appeals were yet to be converted into completed filings. Around 28,024 tokens remained live, while only 969 had reportedly been utilised.
Justice Mishra urged tax professionals, advocates and industry stakeholders to make greater use of the available filing mechanisms and ensure that eligible appeals are properly instituted before the Tribunal.
GSTAT President Expected 2-2.5 Lakh Appeals
Interestingly, the present number of appeals has fallen substantially short of the volume expected by the GSTAT leadership.
Justice Mishra had earlier stated that he expected the Tribunal to receive approximately 2 lakh to 2.5 lakh cases. As of the figures discussed on Friday, around 74,758 appeals had been filed, a number that subsequently increased to 75,155according to the Tribunal’s portal.
The President expressed concern over the relatively low number of appeals, particularly because approximately 3.5 lakh GST disputes had reportedly reached the first appellate stage in the past.
Under the GST dispute resolution mechanism, an aggrieved taxpayer generally first approaches the Commissioner (Appeals) or another designated first appellate authority against an order passed by the adjudicating authority. GSTAT acts as the second appellate forum, where disputes can be examined further by an independent appellate tribunal.
However, there is no conclusive centralised data regarding the number of cases finally disposed of by first appellate authorities, particularly because several matters were filed or processed manually in earlier years.
Justice Mishra reportedly observed that the lower-than-expected number of appeals could have several explanations, including the possibility that some businesses may have shut down or that certain disputes may have involved alleged fake input tax credit claims where parties chose not to pursue litigation further.
Tribunal Now Beginning to Deliver Substantive GST Rulings
Despite the low disposal numbers in comparison with the overall volume of filings, tax experts believe that GSTAT is now beginning to play an increasingly important role in settling substantive legal issues under GST law.
Vivek Jalan, Partner at Tax Connect Advisory Services, stated that the various GSTAT Benches are now functioning with the President, Vice-Presidents and Members of the Principal and State Benches in place.
According to Jalan, recent decisions of GSTAT have started providing important clarity on contentious GST issues.
He referred to the Sterling Williamson ruling, where the Principal Bench reportedly examined the invocation of Section 74 of the Central Goods and Services Tax Act. The provision deals with cases involving allegations such as fraud, wilful misstatement or suppression of facts.
The significant principle emerging from the ruling, according to Jalan, is that such serious allegations cannot be sustained merely by making assertions. The invocation of the extended provisions relating to fraud or suppression requires supporting evidence.
A similar approach was reportedly reaffirmed by the Kolkata Bench in the Power Tech Global matter.
These decisions could have wider implications for GST demands where authorities invoke fraud or suppression provisions without establishing the necessary factual foundation.
Hope for Taxpayers Whose Appeals Were Dismissed on Limitation
Another important area of expectation concerns appeals dismissed on the ground of limitation.
Many GST disputes have remained unresolved because taxpayers faced procedural hurdles, uncertainty regarding the appellate mechanism and questions relating to the computation of limitation periods.
Tax professionals are now looking towards GSTAT for clarity and relief in appropriate cases, particularly where appeals may have been rejected on technical grounds.
The issue of proper service of notices and orders is also expected to receive increased judicial attention. The GSTAT President has reportedly indicated the importance of ensuring proper service, an issue that may become significant in disputes involving delayed appeals.
75,000 Appeals but Only 83 Disposals: The Challenge Ahead
The latest figures present a mixed picture for India’s GST appellate system.
On one hand, the filing of more than 75,000 appeals demonstrates the massive demand for an effective second appellate mechanism under the GST regime. On the other hand, the fact that only 5,819 cases have been registered and merely 83 matters disposed of indicates the scale of the administrative and judicial challenge ahead.
As the Tribunal’s Benches continue to become fully functional and more appeals are registered for hearing, the pace of disposal is expected to increase.
The coming months will therefore be crucial for GSTAT. The Tribunal will not only have to deal with a rapidly expanding backlog but will also be expected to lay down authoritative principles on major GST controversies involving input tax credit, fraud and suppression allegations, limitation, procedural compliance, classification and valuation disputes.
For taxpayers and professionals, the operationalisation of GSTAT marks the beginning of a long-awaited appellate era. However, with tens of thousands of appeals already filed and only a fraction reaching final disposal, the Tribunal faces an enormous responsibility in ensuring that the promise of a specialised GST appellate forum translates into timely and effective justice.
