Manual GST appeal filing cannot be rejected where Rule 108 allows another notified mode and none was prescribed.

Rule 108 of the Andhra Pradesh GST Rules permits an appeal to be filed either electronically or in another mode notified by the Chief Commissioner, so the absence of a notification does not make electronic filing the only valid method. The appeal in FORM GST APL-01 remains mandatory, but rejection solely because the appeal was filed manually is unsustainable where no notified alternative mode exists. In a tax matter, any ambiguity in the filing procedure must operate in favour of the assessee. The appellate authority was directed to receive and process the appeal in accordance with law.

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Issues: Whether, under Rule 108 of the Andhra Pradesh Goods and Services Tax Rules, 2017, an appeal to the appellate authority could be filed manually in the absence of a notification by the Chief Commissioner prescribing the other mode, and whether the rejection of the appeal solely for non-electronic filing was sustainable.

Analysis: Rule 108(1) uses the expression "either electronically or otherwise as may be notified by the Chief Commissioner", which indicates a choice between electronic filing and another notified mode. The wording does not make electronic filing the only permissible mode merely because the Chief Commissioner had not yet issued a notification. The requirement of filing the appeal in FORM GST APL-01 is mandatory, but the phrase "either electronically or otherwise" preserves both modes until a specific notification is issued. Rule 26(1) also refers to submission of applications and appeals electronically with digital signature or through e-signature, while the record showed a notification prescribing verification modes, creating an apparent inconsistency in the filing procedure. As the matter arose under a tax statute, the ambiguity was required to be resolved in favour of the subject.

Conclusion: The appeal could not be rejected merely because it was not filed electronically, and the impugned rejection order was unsustainable.

Final Conclusion: The petitioner obtained relief against the rejection of the appeal, and the appellate authority was directed to receive and process the appeal in accordance with law.

Ratio Decidendi: Where the governing rule provides for filing an appeal either electronically or in another mode to be notified, and no such notification exists, the appellant cannot be denied consideration of the appeal solely for using the manual mode, especially in a tax matter where ambiguity must operate in favour of the assessee.

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