The Ministry of Finance, vide Notification No. S.O. 4220(E) dated 17.09.2025, has clarified the timeline for filing appeals before the Goods and Services Tax Appellate Tribunal (GSTAT). As per the notification, appeals pertaining to orders communicated before April 1, 2026, may be filed up to June 30, 2026. For orders communicated on or after April 1, 2026, the appeal must be filed within three months from the date of communication of the order. Stakeholders are advised to refer to the said notification for detailed provisions and procedural guidance.
It is to be noted that Mr. Sanjaya Kumar Mishra, President of the Goods and Services Tax Appellate Tribunal (GSTAT), issued an Order No. GSTAT/Pr. Bench/Portal/125/25-26, dated 24 September 2025, issued by the Hon’ble GSTAT, directing that all appeals and applications before the GSTAT—arising from the orders or decisions of the appellate and revisional authorities under Sections 107 and 108 of the Central Goods and Services Tax Act, 2017—shall be filed and processed electronically. In accordance with Rule 115 of the Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025, such filing and processing shall be carried out exclusively through the online portal https://efiling.gstat.gov.in, developed by the National Informatics Centre (NIC) for this purpose. Furthermore, all hearings and records of these appeals shall be maintained on the said portal.
The GSTAT Principal Bench has received information from the GSTN indicating that numerous appeals under Section 107 have already been filed and disposed of by appellate authorities, and all such orders, including those under Section 108, are appealable before the GSTAT. The NIC has cautioned that, as the system is new, simultaneous access by many users may cause capacity issues. To avoid system overload and ensure smooth functioning, the filing of appeals will therefore be carried out in a staggered manner.
Accordingly, in view of the large number of appeals expected before the GSTAT and the technical and resource constraints of the system, it has been considered necessary to adopt a phased filing approach. To minimize inconvenience to appellants and prevent system overload, the President of the GSTAT, exercising powers under Rule 123 of the Goods and Services Tax Appellate Tribunal (Procedure) Rules, has directed that appeals be filed as per the categories and timelines specified in the table appended to the order.
Table
| Sl. No. | Period of filing appeal in Form APL-01 / APL-03 under Section 107 of the Act, or issuance of notice in Form RVN-01 under Section 108 | Period during which the appeal before GSTAT under Section 112 may be filed |
| 1 | Where the appeal in Form GST APL-01 / APL-03 or notice in Form GST RVN-01 was filed or issued on or before 31.01.2022 | Period commencing on 24.09.2025 and ending on 31.10.2025, or any date succeeding such date but not later than 30.06.2026 |
| 2 | Where the appeal in Form GST APL-01 / APL-03 or notice in Form GST RVN-01 was filed or issued 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 but not later than 30.06.2026 |
| 3 | Where the appeal in Form GST APL-01 / APL-03 or notice in Form GST RVN-01 was filed or issued 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 but not later than 30.06.2026 |
| 4 | Where the appeal in Form GST APL-01 / APL-03 or notice in Form GST RVN-01 was filed or issued 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 but not later than 30.06.2026 |
| 5 | Where the appeal in Form GST APL-01 / APL-03 or notice in Form GST RVN-01 was filed or issued 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 but not later than 30.06.2026 |
| 6 | Where the appeal in Form GST APL-01 / APL-03 or notice in Form GST RVN-01 has not been filed or issued on the common portal on or before 31.03.2026 | Period commencing on 01.03.2026, or any date succeeding such date but not later than 30.06.2026 |
Further an important information has been provided on the portal that as per Order No. GSTAT/Pr. Bench/Portal/125/25-26, dated 24 September 2025, issued by the Hon’ble GSTAT, only specific cases are eligible to be filed in the first window of filing from 24 September 2025 to 31 October 2025. These include cases where appeals were filed before the Appellate Authorities in Form APL-01 or APL-03, or where notices in Form RVN-01 were issued by the Revisional Authorities on or before 31 January 2022.
It is important to note that the mode of issuance of the first appellate authority’s order—whether manual or electronic—is not relevant for the purpose of filing before the GSTAT. Even manually issued orders are eligible for appeal, provided that the first appeal in Form APL-01 had been filed on the Common Portal on or before 31 January 2022.
Taxpayers, tax officers, and authorized representatives are advised to proceed using the Application Reference Number (ARN) or Case Reference Number (CRN) corresponding to Form APL-01, APL-03, or RVN-01 while filing appeals. For further details, users are encouraged to refer to the Presidential Order and the official Advisory available on the GSTAT portal.
Disclaimer: Nothing contained in this document is to be construed as a legal opinion or view of either of the author whatsoever and the content is to be used strictly for informational and educational purposes. While due care has been taken in preparing this article, certain mistakes and omissions may creep in. the author does not accept any liability for any loss or damage of any kind arising out of any inaccurate or incomplete information in this document nor for any actions taken in reliance thereon.
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