The East Delhi Advocates Forum (EDAF) has made a formal representation to the Union Finance Minister and the GST Council, requesting a one-time extension of the time limit for filing first appeals under Section 107 of the CGST Act for the assessment years 2017-18 to 2020-21.
In a letter dated June 25, 2025, the forum highlighted that thousands of taxpayers—primarily from the small and medium enterprise sector—missed the prescribed timelines for appeal due to initial confusion in interpreting the newly introduced GST law and a lack of clarity around the appeal mechanism.
“Many taxpayers, acting in good faith, submitted rectification applications under Section 161 believing that the limitation period for appeal would start from the date of rejection of such applications,” said Adv. Ashok K. Sharma, President of EDAF. “This misunderstanding, coupled with administrative delays and the novelty of GST compliance, has resulted in genuine taxpayers being unfairly deprived of their right to appeal.”
The representation emphasized that these missed appeal deadlines are not due to substantive defaults but rather procedural oversights. As a result, taxpayers are now burdened with disputed tax demands and face the risk of prolonged litigation.
EDAF has urged the government to consider introducing a special amnesty scheme or issue a notification allowing delayed filing of appeals, similar to earlier relief measures like:
Amnesty for delayed filing of GSTR-1, GSTR-3B, and GSTR-9C
Waivers of late fees and penalties
Extension of timelines for availing Input Tax Credit
Relief under the newly introduced Section 128A
Granting this one-time relief, the forum asserts, would align with the government’s stated goal of ensuring ease of doing business and promoting fair opportunity for redressal in the indirect tax framework.
The appeal comes at a time when the government is already being urged from multiple quarters to address legacy GST transition issues and ease the growing burden on appellate forums.
