Summary: GSTN has enabled taxpayers to file appeals against demand orders where the demand amount is reflected as “NIL” or “Zero” but a dispute regarding liability continues to exist. The change addresses cases where taxpayers had already made payment before issuance of the demand order, resulting in the order reflecting no outstanding demand. Earlier, a validation on the GST Portal restricted taxpayers from filing an appeal against such NIL or Zero demand orders. That validation has now been removed. Consequently, taxpayers facing such cases can file an appeal in Form GST APL-01 against the relevant demand order even though the demand amount displayed in the order is NIL or Zero. The change is significant where the taxpayer disputes the underlying liability or findings recorded in the order notwithstanding that the monetary demand has already been discharged before the order was issued. The GSTN advisory specifically states that taxpayers affected by the earlier portal restriction may now proceed with filing their appeals in Form GST APL-01. Taxpayers experiencing any query or technical difficulty while filing such an appeal may raise a ticket with the GST Helpdesk for assistance. The update was issued by Team GSTN on September 7, 2026 and relates specifically to removal of the GST Portal validation that previously prevented appeal filing where the demand order reflected a NIL or Zero demand amount.
Form GST APL-01 is the prescribed form for filing an appeal before the First Appellate Authority against an appealable decision or order passed under the GST law. Under Section 107 of the CGST Act, 2017, a taxpayer must ordinarily file the appeal within three months from the date the disputed order is communicated, subject to a further condonable period of one month. The appellant must generally deposit the admitted amount of tax, interest, fine, fee and penalty in full, along with the prescribed pre-deposit—normally 10% of the disputed tax—before filing the appeal electronically through the GST portal. A certified copy of the impugned order may also be required in accordance with Rule 108 of the CGST Rules, subject to the applicable electronic-document provisions.
Goods and Services Tax
Government of India, States and Union Territories
Enabling Filing of Appeals in Cases Involving NIL or Zero Demand Amount – reg.
Sep 7th, 2026
In cases where a dispute regarding liability exists but the demand amount is reflected as “NIL” or “Zero” in the demand order, and payment has been made by the taxpayer prior to the issuance of the demand order, the previous validation restricting the filing of an appeal against such demand orders has been removed from the GST Portal. Accordingly, taxpayers are now enabled to file an appeal in Form GST APL-01 against demand orders reflecting a NIL or Zero demand amount.
Taxpayers facing the above issue may now file an appeal in Form GST APL-01 against such demand orders.
In case of any query or difficulty while filing the appeal, taxpayers may raise a ticket with the GST Helpdesk for assistance.
Thanks,
Team GSTN
