TaxTMI 
TaxTMI 
The current month is going to be an extremely busy month for the remaining days of June 2026 as it is expected that all over India, around 3,00,000 appeals are likely to be filed within the next few days as the last date for all OIA dated up to 31/03/2026 happens to be 30/06/2026. Kindly do not expect any magic to happen on the last day as it is not that simple to extend the due date for filing the required appeal before the GSTAT. The honorable President GSTAT has made it very clear that any extension of due date presently kept as 30/06/2026 is not in his purview. Only the GST Council can recommend such proposals which has to be done by way of amendment to Section 112 which process is not possible within the current fortnight.
Let us start focusing on all the first appeal orders dated 01/04/2026 till 30/04/2026 now. The normal due date is three months from the date of receiving the order from the first appellate authority. Accordingly, all the second appeals before GSTAT for OIA passed during April 2026 must be filed by 31/07/2026 to avoid the rejection of the appeal on the ground of limitation. We can not expect the same kind of relief from GSTAT on extension of time as was available from various high courts through writs. It is expected that hearings also may start at various benches of GSTAT from July 2026 onwards and as such there is no scope for extension of time for filing GSTAT appeals unless such delay is condoned by GSTAT based on facts and circumstances of each case.
Section 112 (6) may not help all taxpayers in a big way as the GSTAT has powers for only three months for condoning the delays and that too only when there exists sufficient cause for not preferring the appeal in time. This being so, we may expect some leniency from GSTAT for all cases where the due date is 30/06/2026 till 30/09/2026 due to huge backlog in appeals being filed as well as system glitches etc. However, for OIA passed during April 2026, the appeals before GSTAT must be filed before 31/07/2026 to ensure that the appeal is admitted.
It is appealed to all tax professionals to ensure that the timelines discussed as above on 30/06/2026 as well as 31/07/2026 are fully met by filing the second appeals well in time. From now onwards, it is a continuous process and accordingly all OIA dated 01/04/2026 onwards have only three months for filing in normal course and further three months with condonation of delay where proper justifications are available.
Writs before the jurisdictional high courts are possible only in cases of clear violations of section 75 as well as orders being passed after the mandatory deadline etc. It is gathered from the Chennai Bench of the GSTAT that so far only less than 400 appeals have been filed before that bench whereas a rough estimate on number of appeals due before that bench prior to the deadline date on 30/06/2026 is around 16,000. Hearings of appeals are also set to commence from 23/06/2026 itself. In a similar manner all other benches may also commence the hearings soon.
As only around 16,000 GATAT appeals have been filed till 14/06/2026, the remaining 16 days of June 2026 shall definitely see a huge number of appeals being filed before the GSTAT. It is absolutely possible that GSTAT portal receives even 10,000 appeals in a single day during the last few working days of June 2026 and it is hoped that the concerned authorities keep the portal free from any kind of glitches till 30/06/2026.
The focus of the GST officials is on improving the Revenue whereas the focus of the GSTAT is to ensure that justice is done to both revenue as well as taxpayer based on the extant legal provisions. Hence, a minimum of 80% of the appeals before GSTAT preferred by taxpayers may expect substantial relief from GSTAT. Accordingly each and every appeal in all deserving cases must reach the GSTAT in time.