As we move further into 2026, the procedural framework of the Goods and Services Tax Appellate Tribunal (GSTAT) continues to refine itself to meet the practical needs of taxpayers and practitioners alike. On May 29, 2026, and June 1, 2026, the “Committee for Resolution of Representation received from various Trade / Bar Associations” held its 3rd and 4th meetings. Under the chairmanship of Hon’ble (Dr.) Justice Sanjaya Kumar Mishra, President of the GSTAT, the committee deliberated on critical Proposed amendments to the GSTAT (Procedure) Rules, 2025.
These deliberations were prompted by recommendations from various trade associations and industry stakeholders, aimed at streamlining the appellate process. I believe these changes represent a significant shift toward a more digital-friendly and pragmatic judicial environment.
I. Redefining Documentation: The “Certified Copy” and Digital Integration
One of the most persistent hurdles in appellate practice has been the strict requirement for “certified copies.” The committee has resolved to broaden the definition under Rule 2(f).
Key Change in Rule 2(f): The definition of a “certified copy” is being expanded to include a copy duly authenticated not only by a department officer but also by the appellant, the respondent, or their ‘authorised representative’. This shift acknowledges the practical reality of document management in a high-volume litigation environment.
Furthermore, Rule 21, which governs the documents required to accompany an appeal, has seen a major digital-first update.
- Rule 21(1): A new proviso clarifies that if an order appealed against is already uploaded on the common portal, the requirement to accompany the appeal with a certified copy may be waived.
- Rule 21(2): It is now explicitly stated that final acknowledgments for submitted fees and orders shall be issued under the Rules by the GSTAT Portal.
- Rule 21(6): All documents must be furnished online, duly signed or verified through an electronic verification code (EVC).
These amendments significantly reduce the physical burden of filing and align the Tribunal’s procedures with the broader digital GST ecosystem.
II. Strengthening Verification: The Role of Tax Professionals
A critical procedural addition was resolved regarding Rule 22, which deals with endorsement and verification.
The committee, by a 5-1 majority vote (with a dissent from the Chennai Bench), recommended the insertion of a specific ‘note’. This note requires a single verification by the appellant stating that the statement of facts, grounds of appeal, and annexures are true and correct to the best of their knowledge.
Most importantly for our fraternity, this verification must be accompanied by an identification by an advocate or tax professional in Form APL-05. This underscores the responsibility placed on Chartered Accountants and legal counsel to ensure the integrity of the filings submitted to the Tribunal.
III. Language and Translation: Judicial Discretion and Practicality
Rule 23 previously held a rigid stance on English translations for non-English documents. The committee has resolved to introduce flexibility here.
- A new proviso allows the Bench, at its own discretion, to relax the requirement for English translations.
- Additionally, Sub-Rule (2) of Rule 23, which prohibited hearings from being set down until all parties confirmed the availability of English translations, is recommended for omission.
This change will likely prevent unnecessary delays in regions where regional language documentation is prevalent, allowing the Bench to decide the necessity of translation on a case-by-case basis.
Iv. Reforming the Scrutiny Process: Timelines and Fair Hearing
The committee has proposed a complete substitution of Rule 24, which governs the endorsement and scrutiny of petitions. The new framework is designed to be more transparent and forgiving.
New Timelines under Rule 24:
1. Defect Notification: If an appeal is found defective, the Registrar must issue a notice on the GSTAT portal. The party then has fifteen working days (increased from seven) to remove defects or amend the document.
2. Extended Compliance: The Registrar may offer personal hearings and extend the time for compliance up to a maximum of forty-five days (increased from thirty) from the date of filing.
3. Judicial Oversight: If the Registrar remains unsatisfied with the removal of defects, the matter must be listed for a hearing before the appropriate bench, which has the final discretion to register or reject the appeal.
V. Streamlining Interlocutory Applications and Cause Lists
Rule 29 has been refined to better define the scope of Interlocutory Applications (IAs).
- The substituted rule explicitly includes applications for restoration or other interim prayers.
- Crucial Proviso: In a move that will save significant time for practitioners, a new proviso states that filing a formal IA is not mandatory for the adjournment of hearing dates of appeals or applications.
There is also a shift in how the Tribunal communicates its schedule. Rule 38 is being amended to move from a “daily cause list” to a “weekly cause list”.
- The Registrar will now publish the cause list for the next week on the notice board and the GSTAT Portal by the closing of working hours on the last working day of the previous week.
- Supplementary lists may still be published at the discretion of the President or Vice-President.
- Rule 39 further clarifies that if the Tribunal does not function on a scheduled day due to unforeseen reasons or holidays, the cases will be suitably incorporated into a subsequent day as directed by the Bench.
VI. Fee Schedules and Final Observations
While the committee noted it lacks jurisdiction to directly amend the CGST Rules, 2017, regarding fees, it made several significant observations under Rule 119.
The committee acknowledged representations regarding the relatively low fee schedules of the ITAT and CESTAT compared to GSTAT. It has formally recommended that the Ministry of Finance consider this matter. Furthermore, the committee recommended a proviso stating that no fee should be charged for applications made for the rectification of errors under Section 112(10) of the CGST Act.
Regarding Rule 108, the committee unanimously decided against amending the timeline for rectification applications. It was noted that changing the one-month limit for parties to file for rectification could lead to litigation, as the Tribunal itself loses jurisdiction to amend orders after three months under Section 113(3) of the CGST Act.
Conclusion
The minutes of the May/June 2026 meetings reveal a GSTAT that is actively listening to the concerns of the professional community. From relaxing translation rules to modernizing certified copy requirements and expanding defect-rectification timelines, these resolutions aim to make the GSTAT a more accessible and efficient forum for justice.
Note: This article is based on the GSTAT official Minutes of the Meeting F. No. GSTAT/ Pr. Bench Jurisdiction/2026-27/173 Date 10-June-2026. Proposed Amendments: Notification not issued
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