GSTAT Resources

    Complete GSTAT Appeals Guide 2025

    Comprehensive legal guide covering the complete appeals process, timelines, and procedural requirements

    What does the GSTAT appeal process cover end-to-end?

    An appeal under Section 112 must be filed within 3 months of the order, with a 10% pre-deposit on the disputed tax (capped at ₹20 crore CGST + ₹20 crore SGST, over and above the Section 107 pre-deposit already paid). Procedure, e-filing, cross-objections (45 days) and interlocutory applications are governed by the GSTAT (Procedure) Rules, 2025.

    GSTAT Appeal Process Flowchart

    Complete 10-step process from impugned order to final disposal

    Step 1
    Starting point
    Impugned Order

    First appellate authority or revisional authority passes order

    Order passed against assessee or department by Appellate/Revisional Authority

    Step 2
    1-30 days after order
    Preparation of Appeal/Cross-Objections

    Detailed pleadings and supporting documents collated

    Prepare comprehensive case documentation and legal grounds

    Step 3
    Taxpayer: 3 months, Department: 6 months
    Filing of Appeal

    Submit appeal in prescribed form with pre-deposit and fees

    Form GST APL-05 for appeals, GST APL-06 for cross-objections

    GST APL-05
    GST APL-06
    Step 4
    Immediate
    Acknowledgement

    Receipt of acknowledgement in Form GST APL-02

    Official confirmation of appeal receipt from GSTAT registry

    GST APL-02
    Step 5
    5-15 days
    Scrutiny by Registrar

    Rule 24 scrutiny and defect notice (if required)

    Registry examines appeal for completeness and compliance

    Step 6
    30-45 days
    Admission of Appeal

    Registration and numbering per Rule 25

    Appeal admitted and registered after defect rectification

    Step 7
    60-90 days
    Opportunity of Hearing

    Oral hearing granted to both parties

    GSTAT schedules hearing, Rule 37 permits rejoinders

    Step 8
    As required
    Interlocutory Applications

    Filing applications for stay, directions, etc.

    GSTAT FORM-01 for various interim applications under Rule 29

    GSTAT FORM-01
    Step 9
    Within 1 year target (Section 113(4))
    Final Order of Tribunal

    GSTAT passes final order under Section 113

    Confirm, modify, annul or remand back with directions

    Step 10
    As applicable
    Further Appellate Remedies

    Appeal to High Court (Section 117) or Supreme Court (Section 118)

    Higher appeal options available if required

    Process Timeline Summary

    Total expected timeline from filing to final order: 12-18 months

    Legal Updates 2025
    • GSTAT Procedure Rules 2025 implemented
    • Form GST APL-05 for main appeals
    • Form GST APL-06 for cross-objections
    • GSTAT FORM-01 for interlocutory applications
    • Backlog appeals deadline: 30.06.2026
    Practice Contacts

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    Practice contacts for GSTAT appeals and GST litigation matters

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