Summary: The Government of India launched the Goods and Services Tax Appellate Tribunal (GSTAT) on September 24, 2025, mandating online filing for appeal resolution under GST. Business users can file appeals exclusively against orders from the Appellate Authority (Section 107) or Revisional Authority (Section 108) through the e-filing portal, [https://efiling.gstat.gov.in](https://efiling.gstat.gov.in). The Tribunal has implemented a staggered filing plan for pending cases, ranging from appeals before January 31, 2022 (due September 24–October 31, 2025) up to orders dated March 31, 2026 (due by June 2026). All appeals must be filed using Form GST APL-05 and verified as per CGST Rules, ensuring the submission of certified, indexed supporting documents, often requiring English translations. Key filing requirements include a formal Cause Title, systematically numbered paragraphs for facts and legal points, and clear identification of all parties. The Registrar will scrutinize the filing for defects, allowing the appellant 7-30 days for correction before admitting and registering the appeal for hearing. Applications for stay or condonation of delay require separate affidavits.
In this article, we will be confining our discussion regarding filing of appeal before GST tribunal from users’ perspective:
- First question comes in mind is which appeal to file in tribunal. Only the appeals from the appellate authority under Section 107 and revisional authority under Section 108 can be filed in tribunal.
- Now, the next query can be when to file appeal before tribunal. The tribunal has come up with a staggered plan for filing of appeals as below:
| Prior Appeals/Notices Period | Filing of appeals before tribunal | |
| 1. | Before 31-01-2022 | File during 24-09-2025 to 31-10-2025 |
| 2. | Between 01-02-2022 to 28-02-2023 | File in November, 2025 |
| 3. | Between March 2023 till January, 2024 | File in December, 2025 |
| 4. | Between February, 2024 till May, 2024 | File in January, 2025 |
| 5. | June, 2024 till March, 2026 | File between February, 2026 Till June 2026 |
| 6. | All other order upto 31-03-2026 | File before June, 2026 |
In any case, the filing is permitted till June, 2026
- Next point is where to file the appeals: The filing is required to be done on filing portal: https://efiling.gstat.gov.in The case information system:https//cis.gstat.gov.in
- Points to be considered while filing an appeal
Mode of Filing (Rule 18(1))
- File electronically via www.gstat.gov.in using Form GST APL-05.
- Appeal must be verified as per CGST Rules.
Cause Title (Rule 18(1)(a))
- Begin with: “In the Goods and Services Tax Appellate Tribunal”
- Include: order number, order date, and First Appellate Authority details.
Content Structure (Rule 18(1)(b))
- Numbered paragraphs for each fact, legal point, or allegation.
- Ensures clarity and logical flow.
Party Details (Rule 18(1)(c))
- Include name, parentage, GSTIN (if any), address, and status (Appellant/Respondent).
- Furnish only at the beginning.
Numbering & Identification (Rule 18(1)(d))
- Number parties systematically (e.g., Appellant 1, Respondent 1).
- Legal heirs get sub-numbers (1A, 1B) without changing sequence.
Drafting an appeal and other matters:
Draft & File the Appeal
- Use Form GST APL-05 on the GSTAT portal.
- Include: title, order details, appellant & respondent info, and numbered paragraphs with facts/points.
- Attach certified copy of order and prescribed fee.
Supporting Documents & Translation
- Submit certified copies of all relevant documents, paged and indexed.
- Provide translations if documents are not in English.
Verification, Scrutiny & Correction
- Documents must be signed and verified.
- Registrar checks for defects; 7–30 days to correct errors.
- Failure to correct may lead to rejection.
Admission, Registration & Records
- Appeal is numbered and entered in the register.
- Minor errors can be corrected by Registrar.
- GSTAT may call records from lower authorities.
- Representatives must submit authorization letters.
Other Applications: For stay, early hearing, or condonation of delay: use prescribed form and attach affidavit.
Grounds of Appeal
- Initially, raise only grounds listed in the appeal form.
- Additional grounds considered after notifying the other party.
Respondents & Replies
- If individual appeals → Commissioner is respondent.
- If Commissioner appeals → other party is respondent.
- Respondents reply within 1 month; appellants may file rejoinder if new facts arise.
Hearing & Final Order
- Hearing scheduled after document verification.
- GSTAT issues the final order.
By following the above structured approach, one can file an appeal. In case you have any query and require any clarification regarding GST and require any support, you may like to connect with us.
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Abhinarayan Mishra FCA, FCS, LL.B, IP, RV; Partner, KPAM & Associates, Chartered Accountants, SAM Law Associates LLP. New Delhi ; +91 9910744992; ca.abhimishra@gmail.com; samlawassociates18@gmail.com
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Insightful article!