We are nowhere near. The hard reality on GSTAT appeal filing.

When this article is written in the morning hours on 13/05/2026, the statistics reveals that so far only less than 9000 e appeals have been filed and out of this only less than 1500 appeals have been filed during the current month till now before the GSTAT. This reveals the fact that on an average, 1500 appeals per month are being filed in GSTAT portal as the filing actually started only during December 2025. The daily average filing during May 2026 is around 140. We are left with exactly 48 days as per current deadline and even if the daily filing increase seven fold to 1000 per day, the total e appeals expected as per the current trend is likely to be around 70,000.

The ground reality is entirely different. The awareness on timely filing and the effects of appeal being rejected due to whatever reason is not seen amongst taxpayers as well as tax professionals. A rough estimate which is unofficially endorsed even by senior officers at NIC, GSTIN as well as CBIC is approximately a minimum of 4 lakhs which may be even as high as 6 lakhs which appears to be very fair estimate. Considering the fact that the period involved in dispute ranges over 9 financial years for which the current deadline is only 48 days is really alarming.

One principal bench and more than 30 State Benches spread over 45 locations all over India are going to commence the proceedings soon. In case the daily average filing happens to be around 500 only per day, there would be no stagnation and appeals might be taken up for hearing very quickly. Based on my personal experience, the first appeal filed during May 2026 is expected to be heard only during 2027. The number of appeals that are being filed in GSTAT as of now is alarmingly low and unless the concerned authorities look in to this serious lacuna in the system and improve the speed of the portal as well as make the e filing portal user friendly, damages are certain to the taxpayers.

The initiatives of the 56th GST Council and the involvement of JS (TRU), GSTIN, NIC, as well as the GSTAT are highly appreciable as they gave us a deadline of almost nine full months during September 2025 for filing appeals before GSTAT covering the orders passed up to 31/03/2026 by the first appellate or revision authorities. It was felt that justice has really been done for the taxpayers as based on the experience we got before CESTAT, approximately around 80% of indirect tax disputes settle at Tribunal.

Despite the fact that there are no huge filings of appeals before CESTAT on Excise and Service Tax matters pertaining to the period up to 30/06/2017, the cases before CESTAT are still heard and disposed in the 10 the year of GST. This gives us a clue that the cases likely to reach GSTAT are too many. The idea to set up required benches and to appoint required number of members and provision of support to GSTAT by Government would be purposeful if and only if the appeals in deserving cases reaches the GSTAT.

The Government is pro-active in several aspects such as identifying the principal bench of GSTAT as the top authority on issues connected with NAAR, Anti Profiteering issues, issues connected with place of supply etc. However, the drastically low number of e appeals that are reaching the GSTAT which is required to be monitored closely to ensure that there are no damages to the taxpayer is the need of the hour.

The Institute of Chartered Accountants of India is taking several steps to address these kind of issues by organizing suitable programs to reach all concerned. Ministry of Finance, GSTIN, NIC as well as GSTAT also work very hard to ensure that GSTAT is in a position to function effectively as well as efficiently. But unless and until the efforts result in desired benefit, the basic purpose of such huge efforts by several authorities may be defeated.

Many tax professionals as well as taxpayers have difficulties with the e filing portal and it is gathered that all concerned top officials are also working very hard tirelessly to ensure that all the teething issues are fully resolved. However, in order to ensure that each and every taxpayer across India pay only the applicable GST as per law and the State Government as well as Central Government do not collect any amount UNJUSTLY, the matter should attain finality at the level of Adjudication or First Appeal or Second Appeal as the case may be and the taxpayer should not be prevented from the right of filing the appeal before GSTAT due to practical difficulties.

This requires urgent action from all concerned to extend the deadline date which is at present 30/06/2026 to 31/12/2026 and make the commencement date for actual deadline of three months which stands as 01/04/2026 as 01/10/2026.

Justice should not only seem to be done but requires to be actually done.