The Goods and Services Tax Appellate Tribunal (GSTAT) has reiterated that 30 June 2026 remains the final date for filing eligible backlog appeals before the Tribunal.
According to the GSTAT, the Tribunal does not possess jurisdiction to extend the statutory limitation period prescribed for filing appeals under Section 112 of the Central Goods and Services Tax (CGST) Act, 2017. Consequently, taxpayers and departmental authorities intending to challenge appellate orders before the Tribunal must ensure that their appeals are filed on or before the prescribed deadline.
GSTAT Issues Advisory to Avoid Last-Minute Rush
The Tribunal has urged all taxpayers, tax professionals, and departmental officers to complete the filing process well before the deadline to avoid technical glitches and last-minute congestion on the GSTAT e-filing portal.
The advisory specifically relates to the category of backlog appeals, which became eligible for filing following the operationalisation of the GST Appellate Tribunal framework across the country.
Importance of Section 112 Appeals
Section 112 of the CGST Act provides the statutory mechanism for filing a second appeal before the GST Appellate Tribunal against orders passed by the First Appellate Authority under Section 107 or revisional orders under Section 108.
With the Tribunal now functional, taxpayers who were awaiting the constitution of GSTAT to pursue their appellate remedies have been provided a specified window to file such pending appeals. The latest clarification makes it clear that the benefit of this special filing window cannot be assumed to continue beyond the notified date.
Tribunal Cannot Relax Statutory Limitation
The GSTAT emphasized that the limitation period is governed by the provisions of the CGST Act and related notifications. Since the Tribunal derives its powers from the statute, it cannot independently extend or relax the filing deadline once the prescribed period expires.
This clarification is expected to have a significant impact on taxpayers who have been delaying the filing of appeals in anticipation of a possible extension.
Taxpayers Advised to Review Pending Matters
Tax experts have advised businesses to immediately review pending appellate matters and determine whether any order qualifies for filing before the GSTAT under the backlog appeal mechanism.
Failure to file within the stipulated period could result in the appeal becoming time-barred, potentially depriving taxpayers of an important statutory remedy against adverse GST orders.
