Is It Mandatory to File an English Translated Copy Along With a GSTAT Appeal? A Detailed Analysis of Rule 23(1) of the GSTAT (Procedure) Rules, 2025
Introduction
The operationalisation of the Goods and Services Tax Appellate Tribunal (GSTAT) is one of the most awaited reforms under the GST regime. After more than seven years of running without a functional appellate forum dedicated exclusively to GST matters, the Tribunal has finally begun receiving appeals under the GSTAT (Procedure) Rules, 2025. With benches being constituted across the country and the registry beginning to scrutinise filings, several procedural concerns have started to surface — and among the most debated of them is the question of language. Author can be reached at 9953077844.
Many appellants, particularly from non-metro States such as Uttar Pradesh, Bihar, Madhya Pradesh, Rajasthan and parts of the Hindi heartland, receive their original adjudication orders, appellate orders and notices in Hindi. When these taxpayers approach the GSTAT, they are being asked to furnish a certified English translation of the impugned order along with the appeal memorandum. This has created a peculiar situation: the State authority issues the order in Hindi exercising its right under the Official Languages Act, 1963, while the appellant is expected to bear the cost and effort of translating that very order before he can seek justice from the Tribunal.
A recent communication from the GSTAT to a grievance petitioner — vide F. No. GSTAT/CPGRAM/2025-26/136 dated 22.04.2026 — has now placed the Tribunal’s authoritative position on record. This article explains, in plain language, what Rule 23(1) actually says, what the Tribunal has clarified through this CPGRAM reply, where the law currently stands, and what an appellant should practically do today.
What Rule 23(1) of the GSTAT (Procedure) Rules, 2025 Actually Provides
Rule 23(1) of the GSTAT (Procedure) Rules, 2025 governs the form in which documents are filed before the Registry of the Tribunal. The rule provides that any document filed before the Tribunal — including the impugned order, show cause notice, reply, written submissions, annexures and supporting evidence — if not in the English language, must be accompanied by a certified English translation. The rule does not carve out an exception for orders passed by departmental authorities in Hindi or any regional language. On a plain reading, therefore, the obligation to translate falls squarely on the appellant filing the appeal, irrespective of whether the language barrier was created by the appellant or by the issuing authority.
The Registry of the Tribunal acts as the gatekeeper at the filing stage. It does not examine the merits; its mandate is to verify that the documents tendered comply with the procedural requirements. If the impugned order is in Hindi and is not accompanied by a certified English translation, the Registry is technically empowered to mark the appeal as defective and call upon the appellant to cure the defect within a specified period.
The Grievance That Triggered the Clarification
A taxpayer named Shri Asim Zafar from Varanasi, Uttar Pradesh, raised a grievance through the CPGRAM portal (Grievance No. PMOPG/E/2026/0043871 dated 16.03.2026). His contention was simple and persuasive: when the departmental authority itself issues an order in Hindi, why should the burden of translating that order fall on the appellant? The departmental authority is the originator of the document. The appellant has not “created” the language barrier. Yet, the maintainability of his statutory right of appeal becomes contingent on curing a defect that has its origin in the issuing authority.
This is not just an academic concern. Certified legal translations are expensive, often costing between ₹15 and ₹40 per word, and a typical adjudication order under Section 73 or Section 74 of the CGST Act, 2017 can run into 30 to 80 pages. For a small taxpayer contesting a demand of even ₹5 to 10 lakhs, the translation cost alone can become a meaningful entry barrier to the appellate remedy. The grievance therefore raised a question of access to justice, not merely a question of paperwork.
The Tribunal’s Response: Five Key Clarifications
The Tribunal’s reply dated 22.04.2026 lays down the legal position on five distinct points.
First, the rule is mandatory and unambiguous. The Tribunal has confirmed that Rule 23(1) plainly requires every document not in English, including a Hindi departmental order, to be accompanied by a certified English translation. The Tribunal further clarifies that it has no independent authority to amend or read down this rule, because legislative and procedural formulations vest with the parent Ministry — namely the Department of Revenue, Ministry of Finance. The Tribunal cannot, by judicial fiat, dilute a rule framed by the executive in exercise of its delegated power.
Second, the rule is a standard procedural safeguard, not a penalty. The Tribunal has defended Rule 23(1) as a normal feature of appellate practice across India. The party invoking the statutory remedy of appeal is required to present a complete and compliant set of papers, so that the Bench can proceed without language-related impediments. The reply specifically clarifies that this is not a “penalty” on the appellant for a defect committed by the issuing authority; it is simply the outcome of two different procedural codes operating side by side — one governing how original orders may be passed at the departmental level, and another governing how the appellate forum receives them.
Third, departmental orders in Hindi are themselves protected by statute. The Tribunal has explained that the issuance of adjudication and appellate orders in Hindi is governed by the Official Languages Act, 1963, particularly Section 3(3), read with Rule 6 of the Official Languages Rules, 1976. These provisions expressly permit the use of Hindi for certain official communications. The Tribunal therefore has no jurisdiction to direct departmental authorities to issue orders only in English. In short, the language of the original order and the language of the appellate filing are governed by two different statutory regimes, and the Tribunal cannot impose its own preferences on departmental authorities.
Fourth — and most relief-bearing for current appellants — there is a transitional leniency. Vide Office Order dated 20.01.2026 and further instructions dated 10.03.2026, the Tribunal has directed that for an initial period of six months, where Members of the Bench are able to read and understand Hindi, appeals filed along with the original Hindi orders and documents are being accepted without insisting on immediate translation. This is a significant administrative concession and offers real relief to appellants from Hindi-speaking States during the transitional phase.
Fifth, a committee has been constituted to examine systemic amendments. A committee has been constituted vide Office Order No. 147/2025 dated 08.09.2025 to scrutinise multiple representations received in this regard, including representations seeking amendment of Rule 23(1) in favour of Hindi and other vernacular languages. The very constitution of this committee indicates that the position is not entirely settled and may evolve through formal rule-making in due course.
So Is Translation Mandatory or Not?
The accurate, lawyer-like answer is this: as a matter of black-letter rule, yes — Rule 23(1) makes a certified English translation mandatory. But as a matter of current Tribunal practice, no — for an initial six-month window, Hindi orders are being accepted by Benches whose Members can read Hindi, without forcing the appellant to file translations at the time of filing.
These two positions are reconcilable. The rule has not been amended; the Tribunal has only chosen, for now, not to enforce it strictly in clearly identified situations. The moment the transitional period ends, or the matter is listed before a Bench whose Members do not read Hindi, the rule applies in full force. An appellant who chooses to skip translation today must therefore be prepared to file one at short notice if directed by the Bench or the Registry.
Why the Tribunal’s Position Is Legally Sound (Even If Practically Inconvenient)
It is tempting to read the situation as unfair — and the inconvenience is real — but the Tribunal’s position is legally defensible. Appellate forums across India, from the Income Tax Appellate Tribunal to the Customs, Excise and Service Tax Appellate Tribunal, function predominantly in English. The constitutional scheme under Articles 343 to 351 contemplates English as a language of official record alongside Hindi, and Section 7 of the Official Languages Act, 1963 separately deals with the use of Hindi in courts.
A central appellate body has Benches in multiple regions, and Members may come from any State of the country. Mandating English at the appellate stage promotes uniformity, judicial economy and predictability of record. If every regional Bench were required to accept regional-language filings without translation, operational fragmentation would follow: an appeal filed in Hindi at Lucknow, if transferred to Mumbai, would have to be retranslated mid-proceeding; an appeal filed in Tamil at Chennai would be unintelligible to a Member from Punjab. The rule, harsh as it may appear on first impression, is consistent with the design of a national tribunal handling appeals from all 28 States and 8 Union Territories.
Practical Guidance for Appellants Filing Today
A few practical takeaways for taxpayers and professionals filing appeals before the GSTAT during this transitional phase.
If your impugned order is in Hindi and the Bench having jurisdiction is in a Hindi-speaking State (such as Allahabad, Lucknow, Patna, Jaipur, Bhopal), you may rely on the transitional relief and file the appeal along with the original Hindi order. Even so, keep a translation ready. The leniency is administrative, not statutory, and may be withdrawn the moment the six-month window ends or the composition of the Bench changes.
If your impugned order is in Hindi but the matter is to be filed before a Bench in a non-Hindi-speaking State (Mumbai, Bengaluru, Chennai, Hyderabad, Kolkata), the safer course is to file a certified English translation along with the appeal itself. Otherwise the appeal risks being marked defective by the Registry, and the time spent in curing the defect may eat into limitation if not handled promptly.
The translation must be “certified” — typically by a translator whose certificate accompanies the document, or by an advocate, chartered accountant or other authorised professional attesting to the accuracy of the translation. A casual, uncertified translation downloaded from an automated tool may not satisfy the Registry.
Where the cost of translation is significant relative to the demand, the appellant may consider applying for condonation of any small delay caused by translation work, supported by an affidavit setting out the practical difficulty. Tribunals generally take a pragmatic view of genuine hardship at the threshold stage.
Finally, watch the GSTAT website and notification pages closely. The committee constituted under Office Order No. 147/2025 may, in due course, propose an amendment to Rule 23(1) in favour of Hindi or other vernacular languages. Until then, the legal position remains as stated above.
Conclusion
The question “Is a translated copy mandatory while filing a GSTAT appeal?” has a layered answer. By the strict text of Rule 23(1) of the GSTAT (Procedure) Rules, 2025, a certified English translation of every non-English document — including departmental orders in Hindi — is mandatory. The CPGRAM reply dated 22.04.2026 reaffirms this position and clarifies that the Tribunal itself has no power to dilute the rule, because that power lies with the parent Ministry. However, a six-month transitional leniency, formalised through the Office Order dated 20.01.2026 and instructions dated 10.03.2026, allows Hindi appeals to be accepted by Benches whose Members can read Hindi. A committee under Office Order No. 147/2025 dated 08.09.2025 is also examining structural amendments.
Until the rule is formally amended, the prudent course for any appellant — particularly one filing outside the Hindi heartland — is to file the certified English translation along with the appeal itself. For the Hindi-speaking States, the transitional relief offers breathing room, but it is a concession and not a right. The grievance raised by Shri Asim Zafar has done a quiet service to the GST community by drawing out an authoritative clarification on a question that affects thousands of small and mid-sized appellants across the country, and the trade should watch closely as the language committee’s recommendations unfold.
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Disclaimer: This article is for educational and informational purposes only. It reflects the position of law and Tribunal practice as on the date of writing and should not be construed as legal, tax or professional advice. Readers are advised to consult a qualified professional for advice specific to their own facts and circumstances. The views expressed are personal and not those of any institute, authority or employer.
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