GSTAT Forms: Complete Guide with Templates & Case Scenarios

GST APPELLATE TRIBUNAL (GSTAT): Complete Reference to All Prescribed Forms with Detailed Templates & Illustrated Case Scenarios

Introduction to GST Appellate Tribunal (GSTAT)

The GST Appellate Tribunal (GSTAT) is the second appellate forum under the Goods and Services Tax framework in India. Constituted under Section 109 of the Central Goods and Services Tax (CGST) Act, 2017, as amended by the Finance (No. 2) Act, 2024, the Tribunal hears appeals against orders passed by Appellate Authorities under Section 107 (CGST/SGST) and Section 108 (Revisional Authority). The Principal Bench is located in New Delhi, while State Benches and Area Benches are established across India.

The GSTAT Procedure is governed by the CGST (Appellate Tribunal Procedure) Rules, 2024, and the corresponding State/UT GST Rules. The Tribunal has jurisdiction over disputes involving tax, interest, penalty, fine, or refund exceeding ₹50 Lakhs (for CGST) or such other threshold as may be notified.

Structure of GSTAT Forms

The GSTAT Procedure Rules prescribe specific forms for every stage of Tribunal proceedings — from filing the appeal to final verification. The key forms are:

Form No.	Title	Filed By / Purpose
GST APL-05	Appeal to Appellate Tribunal	Taxpayer / Appellant
GST APL-06	Application for Stay / Interim Relief	Taxpayer / Appellant
GST APL-07	Cross-Objections by Respondent	Department / Respondent
GST APL-08	Memorandum of Cross-Objections	Any Respondent Party
GST APL-09	Application for Restoration / Recall	Aggrieved Party
GST APL-10	Miscellaneous Application	Any Party Before Tribunal
GST APL-11	Application for Rectification of Apparent Error	Any Party / Suo Motu
GST APL-12	Certified Copy Application	Any Party
GST APL-13	Order by Tribunal	Issued by Registry/Bench

Note: Form numbers and titles may vary slightly between CGST and respective State/UT GST rules. The templates below follow CGST (Appellate Tribunal Procedure) Rules, 2024 as prescribed under Notification No. 09/2024-Central Tax dated 12.07.2024. Practitioners should verify the applicable State rules for State GST proceedings.

FORM GST APL-05 — Appeal to the Appellate Tribunal

Legal Basis: Section 112 of the CGST Act, 2017 | Rule 110 of CGST (AT Procedure) Rules, 2024

Any person aggrieved by an order passed by the Appellate Authority under Section 107 of the CGST Act, or an order passed by the Revisional Authority under Section 108, may appeal to the Appellate Tribunal by filing Form GST APL-05 within three months from the date of communication of the order. The appeal must be accompanied by a certified copy of the order and proof of pre-deposit.

ILLUSTRATIVE CASE SCENARIO — APL-05 Appellant:  M/s ABC Marble & Tiles Pvt. Ltd. (GSTIN: XXXXXXXXXXXXXX) Respondent: Additional Commissioner (Appeals), CGST Commissionerate, Agra Issue:  The AA confirmed an ITC demand of ₹38,40,000/- under Section 16(2)(c) on grounds that suppliers had not filed GSTR-3B for the corresponding tax period, thereby disallowing ITC despite the appellant having GSTR-2B reflection and proof of payment. Order Under Challenge: Order-in-Appeal No. CGA/AGR/2024-25/0087 dated 14 October 2024. Ground: Violation of principles as laid down in Writ Petition (Civil) No. 162/2021 — ITC cannot be denied to a bona fide purchaser solely on account of supplier’s default.

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BEFORE THE GST APPELLATE TRIBUNAL FORM GST APL-05 APPEAL TO THE APPELLATE TRIBUNAL [Section 112 of CGST Act, 2017 | Rule 110 of CGST (AT Procedure) Rules, 2024]

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APPEAL DETAILS	INFORMATION
Appeal Number	[ To be allotted by Registry ]
Date of Filing	22nd November 2024
Tribunal Bench	Principal Bench / Agra State Bench (GSTAT)

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APPELLANT DETAILS
Name of Appellant	M/s ABC Marble & Tiles Pvt. Ltd.
GSTIN	XXXXXXXXXXXXXX
Address	Plot No. 14, Industrial Area, Sikandra, [City – XXXXXX, State]
Email / Mobile	accounts@agramarble.in | +91-99999-11111
Represented By	CA A.B. Shah, M/s ABC Chartered Accountants, [City]
Vakalatnama / Auth.	Authorisation Letter dated 18 November 2024 enclosed

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RESPONDENT DETAILS
Name of Respondent	Additional Commissioner (Appeals), CGST Commissionerate, Agra
Address	CGST Bhawan, Sanjay Place, [City – XXXXXX, State]

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ORDER UNDER CHALLENGE
Order Type	Order-in-Appeal
Order Number	CGA/AGR/2024-25/0087
Date of Order	14th October 2024
Date of Communication	28th October 2024
Demand Confirmed (CGST)	₹ 19,20,000/-
Demand Confirmed (SGST)	₹ 19,20,000/-
Total Demand Confirmed	₹ 38,40,000/- (including interest & penalty)
Pre-deposit Made u/s 112(8)	₹ 3,84,000/- (20% of disputed CGST + SGST = 20% of ₹19,20,000 each)
Pre-deposit Challan No.	CIN: 09112024CGST001234 dated 20 November 2024

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SUBJECT MATTER
Tax Period	April 2021 to March 2022 (FY 2021-22)
Tax Type	CGST + SGST (ITC Reversal)
Section / Provision	Section 16(2)(c) of CGST Act, 2017
Nature of Dispute	Disallowance of Input Tax Credit — Supplier Non-compliance
Amount in Dispute	₹ 38,40,000/- (Tax ₹28,00,000/- + Interest ₹6,40,000/- + Penalty ₹4,00,000/-)

GROUNDS OF APPEAL

No.	Ground
1.	The Appellate Authority erred in confirming the demand under Section 16(2)(c) without considering that the appellant is a bona fide purchaser who had paid GST to its suppliers and had valid tax invoices. The principle that ITC cannot be denied to an innocent purchaser on account of supplier’s default has been upheld by Hon’ble High Courts.
2.	The demand is arbitrary and contrary to GSTR-2B auto-populated data, which clearly reflects the ITC in question. Reliance was wrongly placed on Section 16(2)(c) without examining Section 16(2)(aa) inserted w.e.f. 01.01.2022.
3.	The impugned order violates principles of natural justice — appellant was not given adequate opportunity to produce reconciliation statements and supplier communication records.
4.	The levy of penalty under Section 74 is unsustainable as the transaction is not tainted by fraud, wilful misstatement, or suppression of facts. The appropriate provision, if any, is Section 73.
5.	The calculation of interest at 24% per annum under Section 50(3) is incorrect; the applicable rate is 18% per annum under Section 50(1), as the ITC was reflected in electronic credit ledger and never utilised fraudulently.

RELIEFS SOUGHT

The appellant humbly prays that this Hon’ble Tribunal may be pleased to:

(a) Quash and set aside Order-in-Appeal No. CGA/AGR/2024-25/0087 dated 14 October 2024.

(b) Hold that the Input Tax Credit of ₹28,00,000/- is validly availed and cannot be denied.

(c) Quash the penalty levied under Section 74 and confirm, if any, only under Section 73.

(d) Direct re-calculation of interest at 18% per annum under Section 50(1).

(e) Grant such other and further relief as this Hon’ble Tribunal deems fit and proper.

DOCUMENTS / ENCLOSURES

S.No.	Document Description	Remarks
1	Certified copy of Order-in-Appeal No. CGA/AGR/2024-25/0087	Original enclosed
2	Certified copy of Original Order-in-Original	Original enclosed
3	Pre-deposit Challan (CIN: 09112024CGST001234)	Self-attested copy
4	GSTR-2B for April 2021 to March 2022 (downloaded)	Self-attested copy
5	Supplier invoices & payment proofs (consolidated)	Self-attested copy
6	Authorisation letter in favour of CA A.B. Shah	Original
7	Memo of appeal (this form)	4 copies

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VERIFICATION I, Mr. XYZ (Authorised Signatory), Authorised Signatory of M/s ABC Marble & Tiles Pvt. Ltd., do hereby solemnly affirm and declare that the contents of this appeal are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom. Place: Agra Date:  22nd November 2024 Signature: ___________________ Name: Mr. XYZ (Authorised Signatory) Designation: Authorised Signatory GSTIN: XXXXXXXXXXXXXX

FORM GST APL-06 — Application for Stay / Interim Relief

Legal Basis: Section 112(9) of the CGST Act, 2017 | Rule 111 of CGST (AT Procedure) Rules, 2024

Where an appeal has been filed under Section 112 before the Appellate Tribunal, the appellant may apply for a stay of operation of the order appealed against or for any other interim relief, pending hearing and disposal of the appeal. The Tribunal may, after considering the balance of convenience and prima facie case, grant such stay or interim relief as it deems fit.

ILLUSTRATIVE CASE SCENARIO — APL-06 Background: The same appellant (M/s ABC Marble & Tiles Pvt. Ltd.) has filed APL-05 (above). Stay Application: The department has issued a recovery notice under Section 78 immediately after the AA’s order. The appellant prays for a stay of recovery pending Tribunal proceedings. Total Demand: ₹ 38,40,000/-  |  Pre-deposit Already Made: ₹ 3,84,000/- Prima Facie Case: ITC disallowance on sole ground of supplier default — patently unsustainable per recent HC decisions.

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BEFORE THE GST APPELLATE TRIBUNAL FORM GST APL-06 APPLICATION FOR STAY OF DEMAND / INTERIM RELIEF [Section 112(9) of CGST Act, 2017 | Rule 111 of CGST (AT Procedure) Rules, 2024]

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APPLICATION DETAILS
Date of Application	22nd November 2024
Related Appeal No.	As per APL-05 filed on even date / [ Allotted No. ]
Name of Applicant	M/s ABC Marble & Tiles Pvt. Ltd. (GSTIN: XXXXXXXXXXXXXX)
Respondent	Additional Commissioner (Appeals), CGST Commissionerate, Agra
Order Under Challenge	Order-in-Appeal No. CGA/AGR/2024-25/0087 dt. 14.10.2024
Total Amount in Dispute	₹ 38,40,000/-
Pre-deposit Already Made	₹ 3,84,000/- vide CIN: 09112024CGST001234
Remaining Disputed Amount	₹ 34,56,000/-
Recovery Action Initiated	Recovery Notice u/s 78 dated 05 November 2024 enclosed

GROUNDS FOR STAY / INTERIM RELIEF

No.	Ground
1.	PRIMA FACIE CASE: The demand for ITC reversal under Section 16(2)(c) is prima facie unsustainable. The Hon’ble Gujarat High Court in M/s Suncraft Energy Pvt. Ltd. (2023) and Delhi HC in Bharti Airtel Ltd. (2022) have clearly held that ITC cannot be reversed solely because the supplier has not filed GSTR-3B. Appellant has a strong prima facie case on merits.
2.	BALANCE OF CONVENIENCE: Recovery of ₹34.56 Lakhs at this stage will cause irreparable financial hardship to the appellant — a small manufacturing enterprise. The department suffers no prejudice as pre-deposit of ₹3.84 Lakhs and bank guarantee may be offered.
3.	IRREPARABLE INJURY: Forced recovery will disrupt the working capital cycle, affect ongoing production operations, and may lead to default in third-party obligations. Damage is not merely monetary but also reputational.
4.	UNDERTAKING: The applicant undertakes to abide by the final order of this Hon’ble Tribunal and offers to furnish a bank guarantee from a scheduled commercial bank for the disputed amount if directed by the Tribunal.

RELIEF PRAYED

This Hon’ble Tribunal is prayed to:

(a) Stay all recovery proceedings initiated pursuant to Order-in-Appeal No. CGA/AGR/2024-25/0087 dated 14.10.2024 pending final hearing and disposal of Appeal No. ______/2024.

(b) Direct the department to not attach any bank account or property of the applicant during the pendency of this appeal.

(c) Pass such other order as this Hon’ble Tribunal deems fit and just.

VERIFICATION I, Mr. XYZ (Authorised Signatory), Authorised Signatory, do hereby solemnly verify that the contents of this application are true and correct to the best of my knowledge and belief. Place: Agra  Date: 22nd November 2024 Signature: ___________________

FORM GST APL-07 — Memorandum of Cross-Objections by the Department

Legal Basis: Section 113(2) of the CGST Act, 2017 | Rule 114 of CGST (AT Procedure) Rules, 2024

Under Section 113(2) of the CGST Act, 2017, the respondent (typically the department) may, within 45 days of receipt of notice of appeal, file cross-objections before the Appellate Tribunal on any of the points decided against it by the lower authority. Form GST APL-07 is prescribed for the filing of such cross-objections by the department/respondent.

ILLUSTRATIVE CASE SCENARIO — APL-07 Background: M/s ABC Marble & Tiles Pvt. Ltd. filed APL-05 against Order-in-Appeal CGA/AGR/2024-25/0087. Cross-Objection by Department: The Appellate Authority had partially dropped a penalty of ₹5,00,000/- imposed under Section 122(1)(vii) for short payment on self-supply transactions. The department now cross-objects that the dropping of this penalty was erroneous and needs to be restored. Cross-Objection Amount: ₹ 5,00,000/- (Penalty only)

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BEFORE THE GST APPELLATE TRIBUNAL FORM GST APL-07 MEMORANDUM OF CROSS-OBJECTIONS BY RESPONDENT [Section 113(2) of CGST Act, 2017 | Rule 114 of CGST (AT Procedure) Rules, 2024]

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CROSS-OBJECTION DETAILS
Cross-Objection Number	[ To be allotted by Registry ]
Date of Filing	05th January 2025
Related Appeal No.	GSTAT/AGR/CGST/APL-05/0001/2024
Date of Receiving Notice of Appeal	21st November 2024
Last Date for Cross-Objection (45 days)	04th January 2025 [Filed within time]
Filed By (Respondent)	Dy. Commissioner (AR), CGST Commissionerate, Agra
GSTIN of Appellant	XXXXXXXXXXXXXX
Amount in Cross-Objection	₹ 5,00,000/- (Penalty u/s 122(1)(vii))

GROUNDS OF CROSS-OBJECTION

No.	Ground
1.	The Appellate Authority erred in dropping the penalty of ₹5,00,000/- imposed by the Adjudicating Authority under Section 122(1)(vii) of the CGST Act. Section 122(1)(vii) mandates penalty for ‘short payment of tax’ and the transactions in question — inter-state supply of marble slabs to related parties at below-market price — constitute a clear case of undervaluation.
2.	The AA incorrectly held that the valuation issue was not established. However, the comparative sales data placed on record unambiguously demonstrates that the supply price was 32% below the open market value of identical goods. Rule 28 of CGST Rules read with Section 15(4) mandates open market value as the transaction value for related party supplies.
3.	The penalty provision u/s 122(1)(vii) is a strict liability provision and does not require mens rea to be established once the fact of short payment is proven. The AA’s reasoning to the contrary is contrary to the plain language of the statute.

RELIEF PRAYED BY RESPONDENT

This Hon’ble Tribunal is prayed to restore and confirm the penalty of ₹5,00,000/- imposed by the Adjudicating Authority under Section 122(1)(vii) of the CGST Act, 2017, which was incorrectly dropped by the Appellate Authority.

VERIFICATION I, Mr. DEF (AR), Dy. Commissioner (AR), CGST Commissionerate, Agra, do hereby verify that the contents of this memorandum are true and correct to the best of my knowledge. Place: Agra Date: 05th January 2025 Signature: ___________________ Designation: Dy. Commissioner (AR)

FORM GST APL-08 — Memorandum of Cross-Objections (Any Party)

Legal Basis: Section 113(2) of the CGST Act, 2017 | Rule 114 of CGST (AT Procedure) Rules, 2024

Where a taxpayer has filed an appeal before GSTAT (APL-05), and the department also seeks to challenge certain findings in the AA’s order, Form GST APL-08 is used by any party who is a respondent in another party’s appeal, to file Memorandum of Cross-Objections on points decided against them. This is distinct from APL-07 in that APL-08 may be used by either the taxpayer or the department as a respondent.

ILLUSTRATIVE CASE SCENARIO — APL-08 Scenario: The Department filed an appeal (APL-05) against M/s XYZ Exporters Pvt. Ltd. challenging the AA’s decision to drop 60% of the demand. The taxpayer (now Respondent in the department’s appeal) files APL-08 as cross-objection to challenge the remaining 40% demand that the AA had confirmed. Cross-Objection: Taxpayer contends that the entire demand should have been dropped and that the 40% confirmation is also erroneous on the same factual and legal matrix. Appeal by Dept (APL-05): GSTAT/MUM/CGST/APL-05/0055/2024

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BEFORE THE GST APPELLATE TRIBUNAL FORM GST APL-08 MEMORANDUM OF CROSS-OBJECTIONS (FILED AS RESPONDENT) [Section 113(2) of CGST Act, 2017 | Rule 114 of CGST (AT Procedure) Rules, 2024]

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CROSS-OBJECTION DETAILS
Cross-Objection No.	[ Registry Allotted ]
Date of Filing	18th February 2025
Related Appeal (by Dept.)	GSTAT/MUM/CGST/APL-05/0055/2024
Date of Receipt of Notice of Appeal	04th January 2025
Filing Party (as Respondent)	M/s XYZ Exporters Pvt. Ltd. (GSTIN: XXXXXXXXXXXXXX)
Address	504, Neptune Business Park, Andheri East, [City – XXXXXX]
Representative	M/s ABC Advocates & Solicitors, Mumbai
Amount of Cross-Objection	₹ 14,20,000/- (Confirmed CGST + SGST + Interest)

GROUNDS OF CROSS-OBJECTION

The respondent (cross-objector) respectfully submits that the AA erred in confirming 40% of the demand for the following reasons:

1. The ITC disallowance for FY 2019-20 transactions is barred by time under Section 73(10) as the SCN was issued beyond the three-year limitation period.

2. The confirmed demand relates to invoices that were reported in GSTR-1 by the supplier but erroneously excluded from GSTR-2A due to a system glitch acknowledged by the GSTN portal — confirmed by GSTN Help Desk Ticket No. HLP/2021/99342.

3. The impugned order lacks reasons for confirming the 40% demand, violating Section 75(6) which mandates a reasoned order.

VERIFICATION I, Mr. MNO (Authorised Signatory), Authorised Signatory of M/s XYZ Exporters Pvt. Ltd., verify that the contents herein are true and correct. Place: Mumbai Date: 18th February 2025 Signature: ___________________

FORM GST APL-09 — Application for Restoration / Recall of Order

Legal Basis: Section 112 of the CGST Act, 2017 | Rule 116 of CGST (AT Procedure) Rules, 2024

Where an appeal or matter before the Appellate Tribunal has been decided ex parte (in the absence of a party) or has been dismissed for non-prosecution, the aggrieved party may apply for restoration or recall of such order by filing Form GST APL-09 accompanied by satisfactory explanation for non-appearance. The Tribunal may, after hearing the parties, restore the matter to its original position.

ILLUSTRATIVE CASE SCENARIO — APL-09 Applicant: M/s XYZ Textile Mills Pvt. Ltd. (GSTIN: XXXXXXXXXXXXXX) Background: The appellant’s appeal GSTAT/KNP/CGST/APL-05/0023/2024 was set for final hearing on 10 March 2025. The authorised representative (AR) could not appear due to sudden hospitalisation. The Tribunal dismissed the appeal for non-prosecution on 10 March 2025. Prayer: Restore appeal to its pre-dismissal position and list for fresh hearing. Medical Evidence: Discharge summary from Regency Hospital, Kanpur dated 12 March 2025 enclosed.

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BEFORE THE GST APPELLATE TRIBUNAL FORM GST APL-09 APPLICATION FOR RESTORATION / RECALL OF DISMISSED ORDER [Rule 116 of CGST (AT Procedure) Rules, 2024]

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APPLICATION DETAILS
Application Date	17th March 2025
Name of Applicant	M/s XYZ Textile Mills Pvt. Ltd.
GSTIN	XXXXXXXXXXXXXX
Address	14/2, Naveen Market, [City – XXXXXX, State]
Representative	Advocate Suresh Kumar Sharma, Bar Council No. UP/12345
Appeal No. Dismissed	GSTAT/KNP/CGST/APL-05/0023/2024
Date of Dismissal Order	10th March 2025
Order No. to be Recalled	GSTAT/KNP/DISC/0023/2025 dated 10 March 2025
Reason for Non-Appearance	Medical emergency — AR Advocate Suresh Kumar Sharma hospitalised
Date of Application (within 30 days?)	17 March 2025 (7 days from dismissal — within limitation)

REASONS FOR RESTORATION

1. Counsel was suddenly admitted to Regency Hospital, Kanpur on 09 March 2025 due to acute myocardial infarction and was discharged on 12 March 2025. No alternate arrangement could be made on such short notice.

2. The applicant is a bona fide litigant with a genuine and meritorious appeal. The appeal involves ₹72,00,000/- in dispute — dismissal for want of prosecution would cause grave and irreparable injustice.

3. The applicant was not personally responsible for non-appearance and had specifically engaged the AR for this hearing, evidenced by the brief dated 05 March 2025.

RELIEF PRAYED

(a) Recall Order No. GSTAT/KNP/DISC/0023/2025 dated 10 March 2025 dismissing the appeal for non-prosecution.

(b) Restore Appeal No. GSTAT/KNP/CGST/APL-05/0023/2024 to its pre-dismissal stage.

(c) List the appeal for fresh hearing on the next available date.

S.No.	Enclosure	Remarks
1	Discharge Summary — Regency Hospital, Kanpur (Advocate Suresh Kumar Sharma)	Original
2	Brief dated 05 March 2025 by M/s XYZ Textile Mills to Advocate	Copy
3	Copy of Dismissed Order dated 10 March 2025	Certified copy

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VERIFICATION I, Mr. PQR (Authorised Signatory), Authorised Signatory of M/s XYZ Textile Mills Pvt. Ltd., verify that the above is true and correct to the best of my knowledge. Place: Kanpur Date: 17th March 2025 Signature: ___________________

FORM GST APL-10 — Miscellaneous Application

Legal Basis: Rule 117 of CGST (AT Procedure) Rules, 2024

Form GST APL-10 is a multi-purpose miscellaneous application form used before the Appellate Tribunal for various procedural applications that are not specifically covered by other dedicated forms. Common uses include: application for adjournment, application for amendment of appeal, application to produce additional evidence, application for impleadment of additional party, application for directions, and similar interim/ancillary prayers.

ILLUSTRATIVE CASE SCENARIO — APL-10 Applicant: M/s XYZ Auto Components Ltd. (GSTIN: XXXXXXXXXXXXXX) Related Appeal: GSTAT/DEL/CGST/APL-05/0078/2024 Application Type: Application to Produce Additional Evidence (documentary) — Audited financial statements for FY 2020-21 and a laboratory test report that were not available at the time of filing the appeal but are critical to establish the classification dispute (HSN 8708 vs 8714). Basis: Rule 117(3) of CGST (AT Procedure) Rules, 2024 — Tribunal may permit additional evidence in the interest of justice with sufficient cause shown.

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BEFORE THE GST APPELLATE TRIBUNAL FORM GST APL-10 MISCELLANEOUS APPLICATION BEFORE THE TRIBUNAL [Rule 117 of CGST (AT Procedure) Rules, 2024]

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APPLICATION DETAILS
Application Date	01st April 2025
Application Type	Application to Produce Additional Evidence
Related Appeal No.	GSTAT/DEL/CGST/APL-05/0078/2024
Name of Applicant	M/s XYZ Auto Components Ltd. (GSTIN: XXXXXXXXXXXXXX)
Address	B-44, Okhla Industrial Area Phase II, [City – XXXXXX]
Respondent	Commissioner, CGST Commissionerate, Delhi South
Next Date of Hearing	15th April 2025
Nature of Additional Evidence	Audited Financial Statements FY 2020-21 + NABL Accredited Lab Test Report for Products

SUBJECT & PRAYER

The applicant most respectfully states that:

1. The core dispute in the appeal relates to classification of ‘Electronic Control Units for Automotive Suspension Systems’ – whether classifiable under HSN 8708.99 (Parts & Accessories of Motor Vehicles) or HSN 8714.99 (Parts & Accessories for Vehicles of Heading 8711-8713).

2. An NABL accredited independent laboratory test report (Report No. NTL/DEL/2024/4421 by National Testing Laboratory, New Delhi) was received on 25 March 2025 post-filing of appeal. The report conclusively establishes the technical specifications confirming HSN 8708.99 classification.

3. The applicant could not produce this evidence earlier as the laboratory testing was pending, and there was no negligence or deliberate withholding. Production of this evidence is essential for a just decision.

PRAYER: The applicant prays that this Hon’ble Tribunal permit the applicant to produce the following additional documents on record and direct the same to be taken up at the time of final hearing:

(a) NABL Lab Test Report No. NTL/DEL/2024/4421 dated 20 March 2025.

(b) Audited Financial Statements and Cost Audit Report for FY 2020-21.

VERIFICATION I, Mr. RST (Authorised Signatory), Authorised Signatory of M/s XYZ Auto Components Ltd., verify that the contents herein are true and correct. Place: New Delhi Date: 01st April 2025 Signature: ___________________

FORM GST APL-11 — Application for Rectification of Apparent Error

Legal Basis: Section 161 of the CGST Act, 2017 | Rule 118 of CGST (AT Procedure) Rules, 2024

Under Section 161 of the CGST Act, 2017, any authority (including the Appellate Tribunal) may rectify any apparent error in any order or decision passed by it, within a period of three months from the date of such order, provided that no such rectification shall be made where the effect thereof would be to enhance the assessment or to increase the liability. Form GST APL-11 is the prescribed application for seeking such rectification from the Appellate Tribunal.

ILLUSTRATIVE CASE SCENARIO — APL-11 Applicant: M/s XYZ Gems & Jewellery Pvt. Ltd. (GSTIN: XXXXXXXXXXXXXX) Background: The Tribunal vide its Order dated 20 March 2025 in Appeal No. GSTAT/JAI/CGST/APL-05/0112/2024 allowed the appeal and reduced the demand from ₹45,00,000/- to ₹18,00,000/-. However, while computing interest, the order mentions 24% p.a. instead of the correct 18% p.a. under Section 50(1), resulting in an apparent error in the calculation portion of the order. Error: Incorrect interest rate — stated as 24% p.a., correct rate is 18% p.a. Impact: Excess interest of approximately ₹1,44,000/- if not rectified.

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BEFORE THE GST APPELLATE TRIBUNAL FORM GST APL-11 APPLICATION FOR RECTIFICATION OF APPARENT ERROR [Section 161 of CGST Act, 2017 | Rule 118 of CGST (AT Procedure) Rules, 2024]

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APPLICATION DETAILS
Date of Application	07th April 2025
Related Appeal No.	GSTAT/JAI/CGST/APL-05/0112/2024
Order Date (to be Rectified)	20th March 2025
Order Number	GSTAT/JAI/ORDER/0112/2025
Name of Applicant	M/s XYZ Gems & Jewellery Pvt. Ltd. (GSTIN: XXXXXXXXXXXXXX)
Address	G-7, MI Road, [City – XXXXXX, State]
Within Limitation (3 months)?	Yes — application filed on 07.04.2025 (18 days from order date)
Nature of Error	Arithmetic / transcription error in interest rate applied

DETAILS OF APPARENT ERROR

Parameter	As Stated in Order	Correct Value
Interest Rate Applied on Confirmed Demand	24% per annum	18% per annum
Legal Provision	Sec. 50(3)	Sec. 50(1)
Principal Tax Demand (Confirmed by GSTAT)	₹ 18,00,000/-	₹ 18,00,000/-
Interest for 2 Years as per Order	₹ 8,64,000/-	₹ 6,48,000/-
Excess Interest due to Error	—	₹ 2,16,000/-

The error is apparent from the face of the order — Para 18 of the impugned order states the rate as ‘24% per annum’ while the operative portion of the order and all settled law (including CB Circular 2021) confirms 18% p.a. for normal ITC disputes not involving fraud or suppression.

PRAYER: Rectify Para 18 of Order No. GSTAT/JAI/ORDER/0112/2025 to read ‘18% per annum under Section 50(1)’ in place of ‘24% per annum under Section 50(3)’ and issue a corrigendum accordingly.

VERIFICATION I, Ms. UVW (Authorised Signatory), Authorised Signatory of M/s XYZ Gems & Jewellery Pvt. Ltd., verify the above to be true. Place: Jaipur Date: 07th April 2025 Signature: ___________________

FORM GST APL-12 — Application for Certified Copy of Order

Legal Basis: Rule 119 of CGST (AT Procedure) Rules, 2024

Any party to proceedings before the Appellate Tribunal may apply for a certified copy of any order, judgment, or record by filing Form GST APL-12 with the Registry of the Tribunal. Certified copies are required for: filing High Court writ petitions, compliance with orders, use in related proceedings before other authorities, and submission to banks/financial institutions. The Tribunal charges prescribed fees for certified copies.

ILLUSTRATIVE CASE SCENARIO — APL-12 Applicant: M/s ABC Marble & Tiles Pvt. Ltd. (GSTIN: XXXXXXXXXXXXXX) Background: GSTAT has passed a Final Order dated 28 April 2025 in Appeal No. GSTAT/AGR/CGST/APL-05/0001/2024 — partially allowing the appeal. The company needs certified copies to: (a) implement the order, (b) file Writ Petition before Allahabad High Court against the unfavourable portion, and (c) submit to Canara Bank for release of bank guarantee. Number of Certified Copies Required: 3 (three)

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BEFORE THE GST APPELLATE TRIBUNAL FORM GST APL-12 APPLICATION FOR CERTIFIED COPY OF ORDER / RECORD [Rule 119 of CGST (AT Procedure) Rules, 2024]

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APPLICATION DETAILS
Date of Application	05th May 2025
Name of Applicant	M/s ABC Marble & Tiles Pvt. Ltd.
GSTIN	XXXXXXXXXXXXXX
Address	Plot No. 14, Industrial Area, Sikandra, Agra – 282007
Appeal / Case No.	GSTAT/AGR/CGST/APL-05/0001/2024
Order / Document Required	Final Order dated 28 April 2025 (Order No. GSTAT/AGR/FINAL/0001/2025)
No. of Certified Copies Required	3 (Three)
Purpose	HC Writ Petition + Compliance + Bank Guarantee Release
Urgency	Urgent (HC limitation period running — 90 days from order date)
Prescribed Fee (if any)	As per fee schedule of GSTAT — payment proof enclosed

DECLARATION: The applicant declares that the certified copies are required for lawful purposes only and shall not be used for any purpose other than stated above.

VERIFICATION I, Mr. XYZ (Authorised Signatory), MD, M/s ABC Marble & Tiles Pvt. Ltd., verify the above application. Place: Agra Date: 05th May 2025 Signature: ___________________

FORM GST APL-13 — Final Order / Decree by Appellate Tribunal

Legal Basis: Section 113 of the CGST Act, 2017 | Rule 115 of CGST (AT Procedure) Rules, 2024

Form GST APL-13 is the prescribed format for Orders passed by the GST Appellate Tribunal. The Tribunal, after hearing parties and perusing the records, passes its order under Section 113 of the CGST Act. The order may confirm, vary, annul, or remand the order of the Appellate Authority. The order is certified by the Registrar/Registry and communicated to all parties.

ILLUSTRATIVE CASE SCENARIO — APL-13 This is the Final Order passed by GSTAT in Appeal No. GSTAT/AGR/CGST/APL-05/0001/2024 (ABC Marble & Tiles Pvt. Ltd. vs. CGST Commissionerate, Agra) Outcome: Appeal partly allowed — Tax demand dropped, penalty reduced, interest re-calculated at 18%.

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BEFORE THE GST APPELLATE TRIBUNAL FORM GST APL-13 ORDER OF THE GST APPELLATE TRIBUNAL [Section 113 of CGST Act, 2017 | Rule 115 of CGST (AT Procedure) Rules, 2024]

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ORDER DETAILS
Order No.	GSTAT/AGR/FINAL/0001/2025
Date of Order	28th April 2025
Bench	Principal Bench / Agra State Bench
Hon’ble Members	Hon’ble Justice A.K. Sharma (Judicial Member) & Shri R.P. Gupta (Technical Member)
Appeal No.	GSTAT/AGR/CGST/APL-05/0001/2024
Appellant	M/s ABC Marble & Tiles Pvt. Ltd., Agra (GSTIN: XXXXXXXXXXXXXX)
Respondent	CGST Commissionerate, Agra
Order-in-Appeal Challenged	Order-in-Appeal No. CGA/AGR/2024-25/0087 dated 14.10.2024
Date of Hearing	22nd April 2025
Counsel for Appellant	CA A.B. Shah, M/s ABC Chartered Accountants, [City]
Counsel for Respondent	Shri Mr. DEF (AR), Dy. Commissioner (AR), CGST Commissionerate, Agra

ORDER

The appeal filed by M/s ABC Marble & Tiles Pvt. Ltd. under Section 112 of the CGST Act, 2017, against Order-in-Appeal No. CGA/AGR/2024-25/0087 dated 14.10.2024 came up for hearing on 22 April 2025.

Having heard the learned counsel for the appellant and the departmental representative, and having perused the records, this Tribunal holds:

Issue	Finding / Decision	Amount Confirmed	Amount Set Aside
1	ITC Reversal u/s 16(2)(c) — GSTR-2B reflects the ITC; supplier default alone cannot negate bona fide purchaser’s credit. ALLOWED.	Nil	₹ 28,00,000/-
2	Interest u/s 50 — Rate corrected from 24% to 18% p.a. (Section 50(1) applies, not Section 50(3) as no fraud involved). MODIFIED.	₹ 3,24,000/-	₹ 3,16,000/-
3	Penalty u/s 74 — No fraud/suppression established; penalty u/s 74 is unsustainable. Penalty under Section 73 confirmed at 10% of tax. MODIFIED.	₹ 2,80,000/-	₹ 1,20,000/-
4	Cross-Objection by Department (APL-07) re: Penalty u/s 122(1)(vii) — DISMISSED for want of merit. Related party pricing did not constitute short payment on established record.	Nil	Dismissed

OPERATIVE ORDER:

(a) Appeal No. GSTAT/AGR/CGST/APL-05/0001/2024 is PARTLY ALLOWED.

(b) Order-in-Appeal No. CGA/AGR/2024-25/0087 dated 14.10.2024 is SET ASIDE to the extent it confirms CGST + SGST demand of ₹28,00,000/-. The same is hereby DELETED.

(c) Interest is re-computed at 18% per annum under Section 50(1) — confirmed at ₹3,24,000/-.

(d) Penalty under Section 74 is set aside. Penalty under Section 73 at 10% of confirmed tax (if any) is confirmed.

(e) Pre-deposit of ₹3,84,000/- shall be refunded to the appellant within 30 days from communication of this order.

(f) Cross-Objection filed by Respondent (Department) vide APL-07 is DISMISSED.

Pronounced in Open Court on 28th April 2025 Sd/- (Justice A.K. Sharma) Judicial Member, GSTAT Sd/- (R.P. Gupta)  Technical Member, GSTAT Certified true copy issued by:  Registrar, GST Appellate Tribunal, Agra Bench Date of Dispatch: 02nd May 2025

Quick Reference: GSTAT Forms — Limitation Periods & Key Requirements

The table below summarises key procedural requirements for all GSTAT forms:

Form	Purpose	Time Limit	Pre-deposit	Filed By
APL-05	Main Appeal to GSTAT	3 months from AA order communication	20% of disputed CGST/SGST (Sec.112(8))	Appellant
APL-06	Stay / Interim Relief	Along with or after APL-05	Pre-deposit for APL-05 needed	Appellant
APL-07	Cross-Objections by Dept.	45 days from receipt of notice of appeal	None	Department (Respondent)
APL-08	Cross-Objections by Any Party	45 days from receipt of notice of appeal	None	Any Respondent
APL-09	Restoration / Recall	30 days from ex-parte order	None	Aggrieved Party
APL-10	Miscellaneous Application	Before final disposal	None	Any Party
APL-11	Rectification of Apparent Error	3 months from order date	None	Any Party / Suo Motu
APL-12	Certified Copy Application	Any time after order	Prescribed Fee	Any Party
APL-13	Order by Tribunal	N/A — issued by Tribunal	N/A	Tribunal (Registry)

Key Procedural Points — GSTAT Practice Tips

Tip	Detail
1	PRE-DEPOSIT MANDATORY: Section 112(8) — 20% of the disputed tax amount (CGST separately + SGST separately) must be deposited before filing APL-05. No pre-deposit for cross-objections (APL-07/08). Failure to deposit is fatal to the appeal.
2	CONDONATION OF DELAY: Under Section 112(4), delay up to 3 months beyond the initial 3-month period may be condoned if sufficient cause is shown. Total limitation = 6 months from communication of order.
3	FORMAT COMPLIANCE: All appeals/applications must be typed in double space, on one side of paper, in the prescribed format. Handwritten applications are not accepted except in exceptional circumstances.
4	E-FILING: GSTAT has provisions for online filing through the GST portal / dedicated GSTAT portal. Physical filing is accepted at respective State Bench registries.
5	COPIES: For physical filing — 4 copies of the appeal (1 original + 3 copies) along with copies of all enclosures are required.
6	AUTHORIZATION: A Chartered Accountant, Advocate, or any other authorized representative appearing before GSTAT must hold a valid authorization/vakalatnama from the appellant.
7	HIGH COURT APPEAL: Orders of GSTAT are appealable before the High Court under Article 226 / 227 of the Constitution or under Section 117 of the CGST Act (questions of law only) — certified copy via APL-12 is essential.