Period during which appeal under Section 112 of Central Goods and Services Tax (“CGST”) Act, 2017, may be filed before Goods and Services Tax Appellate Tribunal (GSTAT)
Summary: The President of the Goods and Services Tax Appellate Tribunal (GSTAT) has issued a mandatory staggered schedule for filing appeals under Section 112 of the CGST Act, 2017, in response to potential technical limitations of the electronic portal. Appeals to the GSTAT are filed against orders from First Appellate Authorities (Section 107) and decisions of Revisional Authorities (Section 108), and are processed electronically via the NIC-developed portal under Rule 115 of the GST Appellate Tribunal (Procedure) Rules, 2025. Recognizing that a large volume of pending appeals could overload the system, Order No. 1499-1502, dated September 24, 2025, directs appellants to file based on the date the initial appeal (Form GST APL-01 or GST APL-03) or revision notice (Form GST RVN-01) was filed or issued on the common portal. For instance, cases where the initial action was on or before January 31, 2022, must file the GSTAT appeal between September 24, 2025, and October 31, 2025 (or not later than June 30, 2026). Subsequent categories have filing windows starting on November 1, 2025, December 1, 2025, and so on, with the final deadline for all categories being no later than June 30, 2026. This schedule is designed solely for system efficiency and does not supersede the GSTAT’s inherent power under Sub-Section (6) of Section 112 to admit appeals.
Prior to knowing about the timelines by which appeals may be filed before GSTAT, it is relevant to note on the provisions, the orders under which are appealable to GSTAT.
- Section 107 of CGST Act, 2017 – Orders passed by First Appellate Authorities.
- Section 108 of CGST Act, 2017 – Orders arising from the decision of Revisional Authorities.
The appeals and applications before GSTAT are governed by Rule 115 of Goods and Services Tax Appellate (Procedure), Rules 2025, these appeals are to be filed and processed electronically on the portal developed by NIC.
It has come to the information of the Principal Bench of GSTAT that large number of orders passed by First Appellate Authorities and decisions of Revisional Authorities are appealable before GSTAT.
As per the communication from NIC, the portal may face capacity and concurrency issues, if most of the appellants visit the portal during similar time span. Accordingly, to avoid the problems for potential appellants, it has been suggested to file the appeals in sequential manner over a period for lowering burden on the system.
In order to overcome the issues that potential appellants may face and also for smooth functioning of the system, the President GSTAT, in exercise of power conferred by rule 123 of Rules, has directed vide Order No. 1499-1502, dated September 24, 2025, that appeals in respect of the category of cases specified in column (2) of the Table manifested below shall be filed before the Appellate Tribunal during the period specified in the corresponding column (3) of the said Table;
| Sl. No. (1) | Period of filing appeal in Form APL-01 or APL-03 under Section 107 of the Act or issuance of notice in Form RVN-01 in terms of Section 108 of the Act.
(2) |
Period during which the appeal under Section 112 of the Act before the GSTAT may be filed.
(3) |
| 1. | Such orders of the Appellate authorities or revision authorities sought to be appealed before the appellate tribunal where the Appeal in Form GST APL-01 or GST APL-03 or notice in Form GST RVN-01 filed or, as the case may be, issued on the common portal on or before 31.01.2022. | Period commencing on 24.09.2025 and ending on 31.10.2025 or any date succeeding such date being not later than 30.06.2026. |
| 2. | Such orders of the Appellate authorities or revisional authorities sought to be appealed before the appellate tribunal where the Appeal in Form GST APL-01 or GST APL-03 or notice in Form GST RVN-01 filed or, as the case may be, issued on the common portal on or after 01.02.2022 but on or before 28.02.2023.
|
Period commencing on 01.11.2025 and ending on 30.11.2025 or any date succeeding such date being not later than 30.06.2026. |
| 3. | Such orders of the Appellate authorities or revisional authorities sought to be appealed before the appellate tribunal where the Appeal in Form GST APL-01 or GST APL-03 or notice in Form GST RVN-01 filed or, as the case may be, issued on the common portal on or after 01.03.2023 but on or before 31.01.2024. | Period commencing on 01.12.2025 and ending on 31.12.2025 or any date succeeding such date being
not later than 30.06.2026. |
| 4. | Such orders of the Appellate authorities or revisional authorities sought to be appealed before the appellate tribunal where the Appeal in Form GST APL-01 or GST APL-03 or notice in Form GST RVN-01 filed or, as the case may be, issued on the common portal on or after 01.02.2024 but on or before 31.05.2024. | Period commencing on 01.01.2026 and ending on 31.01.2026 or any date succeeding such date being not later than 30.06.2026. |
| 5. | Such orders of the Appellate authorities or revisional authorities sought to be appealed before the appellate tribunal where the Appeal in Form GST APL-01 or GST APL-03 or notice in Form GST RVN-01 filed or, as the case may be, issued on the common portal on or after 01.06.2024 but on or before 31.03.2026. | Period commencing on 01.02.2026 or any date succeeding such date being not later than 30.06.2026. |
| 6. | All orders of the Appellate authorities or revisional authorities sought to be appealed before the appellate tribunal where the Appeal in Form GST APL-01 or GST APL-03 or notice in Form GST RVN-01 filed or, as the case may be, has not been filed or, as the case may be, issued on the common portal on or before 31.03.2026. | Period commencing on 01.03.2026 or any date succeeding such date being not later than 30.06.2026. |
It is pertinent to note the expression “Common Portal” used in above table shall have same meaning assigned under Clause 26 of Section 2 of the CGST Act, 2017.
Further, the above-mentioned order is not in derogation of the powers of the Appellate Tribunal under Sub-Section (6) of Section 112 of the CGST Act, 2017.
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