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GSTAT Revokes Staggered Filing Protocol for Appeals U/s 112

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The Goods and Services Tax Appellate Tribunal (GSTAT) has revoked its earlier order mandating staggered filing of appeals under Section 112 of the Central Goods and Services Tax (CGST) Act, 2017. 

The revocation comes with immediate effect from December 18, 2025, paving the way for unrestricted filing of appeals on the GSTAT portal.

The decision has been formalised through Order No. 315/2025, issued by Justice Sanjaya Kumar Mishra, President of the GST Appellate Tribunal.

Earlier, on September 24, 2025, the Tribunal had issued an order under Rule 123 of the GST Appellate Tribunal (Procedure) Rules, 2025, introducing a staggered mechanism for filing appeals. The measure was aimed at regulating the inflow of appeals and managing the portal’s technical capacity during the initial phase of GSTAT operations.

Under that order, appeals arising from decisions of appellate and revisional authorities under Sections 107 and 108 of the CGST Act, and corresponding provisions under State and Union Territory GST laws, were to be filed in phases as per a prescribed schedule.

However, the Tribunal has now reviewed the operational readiness of the GSTAT portal and concluded that the staggered filing protocol is no longer necessary.

“In consideration of the current assessment of the portal’s capabilities, it is deemed appropriate to dispense with the staggered filing protocol to promote unhindered access while preserving system efficacy,” the order states.

Accordingly, the September 24 order stands revoked with effect from December 18, 2025.

Importantly, the Tribunal has clarified that the revocation will not affect the validity of appeals already filed pursuant to the earlier staggered filing order before December 18, 2025. This assurance is perceived as crucial in avoiding procedural uncertainty for taxpayers and practitioners who had already complied with the phased filing requirements.

The order further specifies that the revocation is without prejudice to the powers of the Appellate Tribunal under Section 112 of the CGST Act, reaffirming the Tribunal’s statutory authority over appeal procedures.

Read More: Garnet Exports Are Regulated Irrespective of Inland or Beach Origin, Upholds Confiscation and Penalties: CESTAT

Mariya Paliwala
Mariya Paliwalahttps://www.jurishour.in/
Mariya is the Senior Editor at Juris Hour. She has 7+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started her career as a freelance tax reporter in the leading online legal news companies.

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