TaxTMI 
TaxTMI 
TaxTMI 
According to GSTN, common portal for GST, huge number of appeals under section 107 have been filed and disposed of by the first appellate authority and also by the revisional authorities. All such orders passed by the first Appellate Authorities and decisions of the Revisional Authorities passed under Section 108 of the Act, are appealable before the second Appellate Authority i.e., GST Appellate Tribunal (GSTAT).
All appeals before GSTAT are required to be filed and processed electronically on the portal developed by NIC for this purpose and all such appeals shall be heard and recorded on the said portal.
NIC who has developed the electronic platform has indicated an apprehension that there is a statable probability that the portal may face capacity and concurrency issues if most of the appellants visit the portal for filing appeals to overcome limitation and that this might adversely affect the performance of the newly designed system, leading to problems for the appellants. In view of this it would be desirable that the filing of appeals may be staggered over a period of time to lower the burden on the system.
Accordingly, GSTAT has issued an Order vide GSTAT Order No. F.No. GSTAT/Pr. Bench/Portal /125/25-26/1499-1502 dated 24.09.2025 to allow for staggered filing of appeals before the GSTAT.
Staggered filing of Appeals before GSTAT
GSTAT President has issued an order exercising the powers under Rule 123 of GSTAT (Procedure) Rules, 2025 to streamline the filing system of appeals before GSTAT against the orders of first Appellate Authority under section 107 of CGST Act, 2017 or orders of Revisional Authority under section 108 of CGST Act, 2017 in view of the huge pendency of appeals to be filed.
- The filing of appeals before GSTAT shall be staggered over a period of time to reduce the burden on the electronic system.
- The staggered time schedule is a under:
Category | Period of filing appeal in Form APL-01 or APL-03 under section 107 of the Act or issuance of notice in Form RVN-01 in terms of Section 108 of the Act | Period during which the appeal under section 112 of the Act before the GSTAT may be filed |
1 | On or before January 31, 2022 | September 24, 2025 – October 31, 2025 |
2 | February 1, 2022 – February 28, 2023 | November 1, 2025 - November 30, 2025 |
3 | March 1, 2023 – January 31, 2024 | December 1, 2025 – December 31, 2025 |
4 | February 1, 2024 – May 31, 2024 | January 1, 2026 – January 31, 2026 |
5 | June 1, 2024 – March 31, 2026 | February 1, 2026 onwards |
6 | Not filed by March 31, 2026 | March 1, 2026 onwards |
- However, in all the above cases, the last date by which appeals shall be filed will be 30th June, 2026. As per Notification No. S.O. 4220(E) dated 17.09.2025.
- These time lines have been issued in exercise of powers to President under Rule 123 of the GSTAT (Procedure) Rules, 2025 and are not in conflict with section 112(6) of the CGST Act, 2017.
Notification for Filing Appeals
Vide Notification No. S.O.4220(E) dated 17.09.2025, Central Government has notified time lines for filing appeals before the GSTAT as follows:
Communication of orders | Filing of appeal |
Before 1st April, 2026 | Latest by 30th June, 2026 |
On or after 1st April, 2026 | Within 3 months of order |
Thus, for entire back log of appeals to be filed before GSTAT as on 31.03.2026, the appeals before GSTAT shall be filed by on or before 30.06.2026. For orders communicated / served on or after 01.04.2026, the appeals shall be filed in ordinary course i.e., within three months of the service of the impugned order.