Today is the best day to file the appeal in GSTAT portal.

Contrary to the expectations of many, the due date for filing the appeal before GSTAT stands as 31/07/2026 for all orders passed in the first appeal up to 30/04/2026. Many taxpayers successfully filed the appeals till now as the count has already crossed 53,000 e appeals. During July 2026, on an average around 500 appeals are only filed in one day. This is remarkably low as the deadline date is mandatory and the condonation of delay is not a matter of birth right but applicable only in deserving cases wherever proper justifications are available.

It is really amazing to have 24 full benches (consisting of 48 judicial members, 24 Technical members -Centre and 24 Technical members -State). We also have 8 sitting benches as well as 13 Circuit benches making the availability of Tribunal at 45 places all over India. To start with, it may be sufficient to address the need of the taxpayers as there is no physical filing of appeal. Moreover, the option of virtual hearing or personal hearing also available when the case is heard by the Benches. Some of the benches have started operations and regular hearings across all the benches may also take place soon.

The minimum amount for which the taxpayer may prefer the appeal is above 50,000 as Section 112 (2) provides for discretion to the Benches to reject the appeal in case the amount of dispute is up to 50,000. The minimum amount of dispute for Revenue to go on appeal before GSTAT is 20,00,000. The fee payable for filing the appeal before GSTAT is 5,000 per appeal as the minimum amount with the fee kept as 1000 per lakhs or part thereof subject to a maximum of 25,000 only. The taxpayer, in case he is conversant with the issue may file himself as well as appear before GSTAT to minimize the expenses.

Due to the recent Tripura High Court decision on 30/06/2026, there are several decided cases wherein the SCN was issued after permissible time limit or OIO was passed after the permissible time limit which till now, were presumed to be correct. The GSTAT is most likely to admit the appeals wherever the first appellate authority order has been passed during 01/07/2017 till 30/04/2026. This is really a one -time opportunity which each and every deserving taxpayer must take advantage.

In order to create awareness amongst all concerned, a table is furnished below which the taxpayer may use as a check list as on date and in case the answer is YES for 2 or 3 cases, it is a fit case for the second appeal. However, wherever the OIO has already attained finality and the first appeal was not preferred in time, it is not worth to reopen the case now. In case your answer to 3 or more questions happens to be yes, the chances of substantial relief are absolutely possible.

The above list is only illustrative and not exhaustive. More than anything else, High Courts are still entertaining writs and passing orders to help taxpayers depite the availability of efficacious alternate remedy. Best example is Sri Shekhar Chandra Podder, Prop. of M/s. Shekhar Chandra Podder Versus The Union of India, The Director, Government of India, Ministry of Finance (Department of Revenue), Central Board of Indirect Taxes and Customs, The Chief Commissioner of State Tax, Government of Tripura, The Joint Commissioner of State Tax, Government of Tripura, The Joint Commissioner, Ministry of Finance, Revenue Department, Government of India, Central Goods and Services Tax, Tripura, The Assistant Commissioner (Anti-Evasion), Tripura, The Superintendent of State Tax, Government of Tripura, The Superintendent (Enforcement), Central Goods and Services Tax, Tripura, The Superintendent (Anti-Evasion), Tripura - 2026 (7) TMI 223 - TRIPURA HIGH COURT  wherein the High Court is of the view on timelines for issuing SCN as well as passing OIO as below:

Above all, the division bench of the High Court of Madras has also passed an order on 15/06/2026 in WP (MD) 14115 to 14119 of 2022 in categorical terms in the matter of M/s. Guru and Co., M/s. Jeyabalan and Co. And Others Versus Union of India, Government of Tamil Nadu, Rep. by its Principal Secretary and Commissioner of Commercial Taxes, Goods And Services Tax Council, The Deputy Director, Directorate General of Good and Services Tax Intelligence Unit, Madurai, Central Board of Indirect Taxes and Customs, New Delhi And Others - 2026 (6) TMI 1289 - MADRAS HIGH COURT in unambiguous terms as 'Neither the Constitution nor any statute has invested the GST Council with the power of ratification. We, therefore, hold that ratification made by the GST Council in 22nd meeting is without

jurisdiction. The second issue is answered accordingly. Since the impugned show cause notices are a fallout of the impugned notifications, they are liable to be set aside and stand set aside. Liberty is given to the department to issue fresh show cause notices if they can be issued in terms of the impugned notifications to the extent they have been held valid.

20.The writ petitions stand allowed accordingly. No costs.

Consequently, connected miscellaneous petitions are closed'.

Not only the next two weeks or not only the next 15 days are crucial to file required GSTAT appeal in time, but in my view, each and every hour till 31/12/2026 midnight are golden hours for a GST professional.