Third, final and golden opportunity for filing appeal before GSTAT.

As on date, it is a well settled position of law that for orders passed under section 107 by the first appellate authority on and from 01/05/2026, the time limit for filing the appeal before GSTAT is only three months. Considering the legacy cases commencing since inception of GST in India on 01/07/2017, the Government on 17/09/2025 allowed time limit up to 30/06/2026 for the period ending on 31/03/2026. However, only around 50,000 appeals could be filed as on 30/06/2026 necessitating the extension for the second time.

As the genuine hardships of all concerned were properly understood in the right perspectives by the Government, on 30/06/2026, the timelines were extended by one month against the earlier time lines specified on 17/09/2025. This was the most appropriate step which Government has taken in the larger interest of justice to the GST payers. But it is to be noted that as on 13/07/2026, when an attempt is made on this article, it is noticed that only around 5200 appeals have been successfully filed in the e portal of GSTAT during the last 13 days. This slow filing of around 400 appeals per day may not be sufficient to achieve the desired benefits of the GSTAT. As this fact was analyzed by NIC and GSTAT, a novel scheme of issuing tokens till 31/07/2026 for all cases pertaining to the period ending on 30/04/2026 has been announced by the principal bench of GSTAT on 10/07/2026.

This is really a wonderful development and the taxpayer may not get any other better things under the present circumstances. The tax professionals must utilize this golden opportunity to an optimum extent to ensure that none of the deserving appeals before GSTAT miss the opportunity on time lines.

For a moment, it is suggested to assume that there are no provisions for condonation of delay and the deadlines are as below so as to ensure that the maximum appeals reach GSTAT in line with the latest order of GSTAT which now requires wider publicity.

First Suggestion: Wherever possible, the second appeal may be filed complete in all respects latest by 31/07/2026 so as to stay in comfort zone one.

Second suggestion: Wherever for reasons beyond control, the full appeal could not be filed by 31/07/2026, the formalities of filing OIA, paying second pre- deposit as well as court fees may be completed now and a token be obtained as per instructions discussed below. This still enables to timely filing provided proper appeal is filed subsequently within 60n days of token generation. It is to be noted here that token generation is possible only up to 31/07/2026 and only for cases up to 30/04/2026.

Third suggestion: This is a time where one has to strictly adhere all time lines as discussed above to ensure the second appeal is accepted by the GSTAT. Hence one has to simultaneously take care of cases up to 30/04/2026 as well as cases pertaining to May 2026. It goes without saying that none of the above three are applicable for the cases commencing from 01/05/2026 and accordingly, only a period of three months is available for timely filing and to be more precise, for an order passed on 02/05/2026 by the first appellate authority, the last date for filing second appeal is 01/08/2026.

In order to ensure that this recent and important development must reach all taxpayers and tax professionals in large numbers, relevant extracts are furnished from the order of the principal bench of GSTAT which reads as

'Process for Token Generation Complete all required fields in the form. If the First Appellate Order being challenged before the GSTAT is available on the GST portal, provide the corresponding 16-digit ARN/CRN. If it is not available online, enter Order No./Reference No./File No. along with the relevant tax period. Upon successful submission of the complaint on this portal, a Token ID will be generated and shared with the user along with the date and time of the token generation. This facility is available to taxpayers and tax officials who possess a GSTIN, Temporary ID, UIN, Or TDS Registration Number. A separate token must be generated for each appeal. For example: If a taxpayer is required to file two appeals, two separate tokens must be generated. One token cannot be used for multiple appeals. Multiple appeals require the generation of an equivalent number of tokens. The Token generated on or before 31 July 2026 serves as evidence that the user has attempted to initiate the appeal filing process before the statutorily prescribed date. Accordingly, users who have generated a valid token before the said will be considered an exception in cases where the appeal could not be filed within the prescribed time limit due to some technical issues or otherwise with the portal. In such cases, they will not be required to pay the delay fee, subject to applicable provisions and verification. Important Timeline As per the order of the Hon'ble President of GSTAT, the appeal must be filed within 60 days from the date of token generation. Filing of appeal or application completed within 60 days of generation of this token shall only be considered validly filed within the due date prescribed under the Act. Users are advised to keep a record of the token generated and ensure that the appeal is completed within the stipulated period'.

It is expected that the maximum advantage of the above order is taken by all concerned and the purpose of this article would be served in full in case the total number of appeals filed in GSTAT portal as on 30.09/2026 exceeds at least 2,50,000/.