Taxpayers and professionals facing difficulties in filing second appeals before the Goods and Services Tax Appellate Tribunal (GSTAT) where the first appeal in FORM GST APL-01 was filed manually will soon have relief.
The Goods and Services Tax Network (GSTN) has clarified that the electronic filing (e-filing) functionality for such cases is currently not available but will be enabled from 1 March 2026, following the directives of the President of GSTAT.
Current Issue on the GSTAT Portal
Several taxpayers and tax professionals have reported challenges while attempting to file second appeals electronically when the first appeal was submitted manually and the corresponding Order-in-Appeal (OIA) has not been uploaded on the GST portal. A ticket raised on the GSTAT portal highlighted this issue, prompting a response from the GSTN.
According to the portal reply “Dear User, currently the functionality for filing appeals against orders where the first appeal in FORM GST APL-01 was filed manually is not enabled. Appeals in such cases will be available for electronic filing from 01.03.2026 in accordance with Order No. GSTAT/Pr. Bench/Portal/125/25-26/1499-1502 dated 24.09.2025 issued by the Hon’ble President GSTAT.”
GSTAT’s New E-Filing Advisory
In addition to this clarification, GSTAT has issued a comprehensive User Advisory for the new e-filing portal, applicable to second appeals under Section 112 of the CGST Act. The advisory lays down a staggered filing schedule that extends up to 31 March 2026, depending on the ARN/CRN of the first appeal (APL-01/03) or notice (RVN-01).
- Appeals linked to orders/notices dated before 31 January 2022 can be filed electronically between 24 September and 31 October 2025.
- Subsequent filing windows have been scheduled until March 2026.
- Missed timelines can be regularized up to 30 June 2026.
- Appeals against APL-04 orders issued after 1 April 2026 must be filed within the standard three-month statutory period.
- For cases where ARN/CRN is not traceable, electronic filing will be open from midnight of 31 December 2025 until 30 June 2026.
Preparatory Steps for Taxpayers
GSTAT has advised users to prepare in advance to ensure smooth e-filing. Taxpayers should:
- Complete the offline Excel draft filing sheet.
- Keep scanned copies of all supporting documents ready, including:
- The impugned order
- APL-04 (if not available online)
- Pre-deposit challans
- Affidavits
- Vakalatnamas
- Ensure that each PDF file does not exceed 20 MB in size.
This initiative aims to streamline the appellate process and provide a consistent electronic mechanism for taxpayers who had previously filed manually, ensuring better transparency and ease of access to the GST appellate system.
