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Instructions for Filing Appeals and Scrutiny Requirements under Section 112 before GSTAT
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GSTAT appeal filing requirements under Section 112 cover documents, pre-deposit, court fee, and scrutiny defects.
Appeals filed in APL-05 before GSTAT under Section 112 must include soft copies of the Show Cause Notice, Order-in-Original, Order-in-Appeal, statement of facts and grounds of appeal. Pre-deposit and court fee are compulsory, though no defect is to be raised where higher court orders exempt them. A scanned certified Order-in-Original or Order-in-Appeal may be accepted if the scrutiny officer is satisfied from the certification endorsement. The taxpayer appellant must also upload authorization or vakalatnama. Revenue applications under Section 112(3) require specified documents, but no court fee or pre-deposit.
HSNS Cess - Login procedure and Filing Application for New Registration and Payment in the CBIC Taxpayer’s portal
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HSNS Cess registration and payment procedure on the CBIC taxpayer portal from 1 February 2026.
HSNS Cess application functionalities will be hosted on the designated CBIC taxpayer portal and made operational from 1 February 2026 for login, enrollment, registration and payment by taxable persons. The advisory provides step-by-step procedure for new registration and payment, with annexures for registration, payment and helpdesk support, and notes that separate advisories will follow for HSNS DEC-01 declarations and HSNS RET-01 returns.
Lenient Scrutiny Guidelines for GSTAT Appeals During Initial Filing Phase Under Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025
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Lenient scrutiny for GSTAT appeals eases initial portal filing, limiting defects to substantive issues and relaxing form-based objections.
Lenient scrutiny is to be adopted by the Registry of each bench during the initial GSTAT portal filing phase, with defects of substance only to be raised for six months. Defects of form not affecting the merits of the case are not to be treated as scrutiny defects. Digitally generated documents from the GSTN system need not be certified, while scanned copies of physical documents attached with the appeal must be signed.
Allocation of Benches to GSTAT Members
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GSTAT bench allocation for technical and judicial members notified, with members directed to join their allotted benches on 21.01.2026.
Allocation of benches to appointed GSTAT members is notified through an office order issued with the approval of the competent authority. The order lists the place of posting for members appointed as Technical Member (Centre), Technical Member (State), and Judicial Member, thereby assigning them to respective bench locations across different cities. All members are requested to join their respective benches on 21.01.2026.
Withdrawal of Order No. 125/2025-26/1499-1502 Dated 24-09-2025 - Regarding Staggered Filing of GST Appeals
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GST appeal filing protocol withdrawn as staggered portal filing is dispensed with, preserving earlier filings.
Withdrawal of the staggered filing protocol for GST Appellate Tribunal appeals. The order dispenses with the earlier phased filing arrangement in view of portal capabilities, with effect from 18-12-2025, while preserving the validity of appeals filed under the prior order before that date and without prejudice to the Tribunal's powers under the GST law.
Assigning proper officer under section 74A, section 75(2) and section 122 of the Central Goods and Services Tax Act, 2017 and the rules made thereunder
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Proper officer assignment under Section 74A structures issuance of notices and orders within prescribed monetary tiers.
The Board assigns Additional/Joint Commissioners, Deputy/Assistant Commissioners and Superintendents of Central Tax as proper officers to issue show cause notices and adjudicate under Section 74A and Section 122, prescribes tiered monetary limits by officer grade (including combined Central and Integrated Tax basis), clarifies determination of proper officer for subsequent statements and appellate reversals, excludes penalties when computing monetary competence, and aligns audit-commissionerate notices with the jurisdictional Central Tax Commissionerate.
System-Based Risk Scoring and Provisional Refund Mechanism for Zero-Rated and Inverted Duty Structure Claims (Effective 01.10.2025)
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GST provisional refunds for zero-rated and inverted duty claims: 90% may be sanctioned based on system risk score.
Refund applications classified as low-risk by the system shall have 90% of the claimed refund sanctioned provisionally, with issuance of FORM GST RFD-02/RFD-03 and adherence to extant timelines. Non-low-risk cases require detailed scrutiny and no provisional sanction. The officer may, for recorded reasons, proceed to examination under rule 92 instead of provisional grant; statutory conditions including non-eligibility under section 54(6) and requirements of rule 91(1) remain applicable. The risk-based provisional refund regime applies to claims filed on or after 01.10.2025 and is extended as an interim measure to inverted duty structure claims.
Withdrawal of circular No. 212/6/2024-GST dated 26th June, 2024 - Related to Reversal of ITC corresponding to Discount.
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Withdrawal of circular ends prescribed procedure for evidence of compliance with Section 15(3)(b)(ii), prompting trade notices.
The Board has withdrawn Circular No. 212/6/2024-GST, rescinding the previously prescribed procedure for providing evidence of compliance with Section 15(3)(b)(ii) regarding reversal of input tax credit for discounts; trade notices should be issued to publicize the withdrawal and any implementation difficulties reported to the Board.
CBIC Clarifies the Requirement for Separate GST Registration for Importers Storing Goods in Warehouses in other States
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Importers storing goods in out of State warehouses must register and comply with GST where supplies originate.
Importers must obtain separate GST registration in a State where goods are stored and outward taxable supplies originate from third party warehouses, since a warehouse is a place of business. Movements between establishments require tax invoices and e way bills; intra State supplies from the storage facility attract CGST and SGST of the State where delivery terminates. Establishments in different States under the same PAN are distinct persons and inter establishment transfers are taxable. Cold storage services are taxable at the location of the immovable property and records must be maintained at each place of business.
Presidential Order on Staggered Filing of Appeals Before GST Appellate Tribunal and Guidelines to Manage Portal Capacity and Ensure Smooth Processing
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Staggered filing of GST appellate tribunal appeals addresses portal capacity constraints and allocates time windows for electronic filing.
Staggered filing of appeals and related applications before the Goods and Services Tax Appellate Tribunal is prescribed for matters arising from orders or decisions of appellate and revisional authorities under sections 107 and 108 of the Central Goods and Services Tax Act, 2017. The appeals are to be filed and processed electronically on the designated NIC portal in accordance with the procedural rules governing GSTAT practice. Separate filing periods are allocated based on the date on which the underlying appeal or revisional notice was filed or issued on the common portal, and the arrangement does not derogate from the tribunal's powers under the relevant appellate provision.
Communication to taxpayers through eOffice - requirement of Document Identification Number (DIN)
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Document Identification Number recognition: eOffice Issue number deemed DIN for public option communications; DIN required otherwise.
Communications dispatched using the public option in CBIC's eOffice application bearing a verifiable electronically generated Issue number shall be deemed to carry the Document Identification Number (DIN) and be treated as valid; officers must accurately populate metadata for verification. The DIN utility must still be used and quoted for communications not sent via eOffice public option or lacking a verifiable Reference Number (RFN) from the GST common portal.
Request for comments/inputs on the legality of bunching multiple financial years into a single demand notice under the GST Act
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Composite GST show-cause notices may cover multiple financial years where each year's limitation and tax breakup remain independently protected.
Composite show-cause notices under sections 73 and 74 may cover multiple financial years where demands arise from a common factual matrix. Consolidation is procedural only: each financial year retains its independently calculated statutory limitation, and a later year's timeline cannot extend an earlier year's deadline. The use of any period and such periods supports statements for additional periods on the same grounds. Clear year-wise tax breakups allow liabilities to be disaggregated for limitation, adjudication, statutory benefits, and defence, preserving natural justice.
Clarification on various doubts related to treatment of secondary or post-sale discounts under GST
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Post-sale discounts: inclusion in taxable consideration depends on whether discount induces dealer's supply to the end customer.
Where suppliers issue financial or commercial credit notes without reducing the original transaction value, recipients need not reverse Input Tax Credit; post-sale discounts that merely lower a dealer's sale price in independent principal-to-principal transactions are not consideration for inducement, whereas discounts linked to an agreement to supply to end customers at a reduced price must be included in overall consideration as inducement. GST applies when dealers render distinct promotional or other services under a contract specifying such services and consideration.
Order Prescribing Dress Code for Hon'ble President and Members During GSTAT Court Proceedings
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Tribunal dress code prescribed for Judicial and Technical Members, setting formal attire requirements for court proceedings.
Dress code is prescribed for the Hon'ble President and Hon'ble Members during GST Appellate Tribunal proceedings, because the GSTAT Procedural Rules 2025 are silent on the subject. Judicial Members are to wear the dress prescribed for Judges of the Hon'ble Supreme Court or Hon'ble High Court, without the gown, while Technical Members must wear specified formal court attire. Female Technical Members have a separate saree-based dress code, and Members wearing a turban are to use a white or light-coloured turban.
Reviewing authority, Revisional Authority and Appellate Authority in respect of orders passed by Common Adjudicating Authority (CAA) for show cause notices issued by DGGI
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Review and revision authority for CAA GST orders rests with the Principal Commissioner/Commissioner; appeals to Commissioner (Appeals).
The Principal Commissioner or Commissioner of Central Tax under whom the Common Adjudicating Authority is posted shall be the reviewing authority under Section 107 and the revisional authority under Section 108 for Orders-in-Original passed by the CAA; appeals against such orders shall lie before the Commissioner (Appeals) corresponding to the territorial jurisdiction of that Principal Commissioner or Commissioner, who shall represent the department in appeal proceedings and may appoint a subordinate officer to file departmental appeals. The reviewing or revisional authority may seek comments from the concerned DGGI formation before deciding.
Generation and quoting of Document Identification Number (DIN) on any communication issued by the officers of the Central Board of Indirect Taxes and Customs (CBIC) to tax payers and other concerned persons
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Document Identification Number (DIN) requirement relaxed where verifiable Reference Number (RFN) on common portal suffices.
Quoting of Document Identification Number (DIN) is not required on communications issued through the GST common portal that bear a verifiable Reference Number (RFN), since the RFN is electronically verifiable and provides requisite document metadata; earlier Board circulars mandating DIN are modified to that extent and such RFN-bearing portal communications are to be treated as valid electronic communications without DIN.
Timely production of records/information for audit
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Audit access to records: field formations must promptly provide custody records and secure taxpayer documents for statutory audit teams.
Field formations must promptly provide records and information in their custody or required to be maintained by them to the national audit authority conducting statutory audits; where documents reside with taxpayers, jurisdictional officers should request and follow up with taxpayers to procure and submit the records without delay.
Grievance Redressal Mechanism for processing of application for GST registration
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Grievance redressal mechanism for GST registration enables applicants to raise ARN-based complaints with zonal commissioners for resolution.
A grievance redressal mechanism requires Principal Chief Commissioners/Chief Commissioners to publicize an email for receipt of ARN-based GST registration grievances, receive ARN, jurisdiction and issue summary, forward State-jurisdiction matters to the concerned State with copy to the GST Council Secretariat, ensure timely resolution or advise applicants where queries are proper, and submit monthly grievance status reports to DGGST for Board compilation.
Instructions for processing of applications for GST registration
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GST registration verification: clarified permissible documentary proof and limits on additional document demands during processing.
Clarifies procedural standards for processing GST registration applications, limiting additional documentary demands to the indicative list in FORM GST REG-01. For proof of Principal Place of Business, any one prescribed document (property tax receipt, municipal khata, electricity or water bill, or equivalent) suffices; rented premises require rent/lease agreement plus one ownership document of the lessor, with consent and identity proof acceptable in specific cases. Unwarranted presumptive queries are prohibited. Physical verification is required for risk-flagged or Aadhaar-unverified cases with GPS-tagged photographs, and officers must follow prescribed forms and timelines for notices, replies and final action.
Various issues related to availment of benefit of Section 128A of the CGST Act, 2017
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Section 128A benefit: earlier GSTR 3B tax payments accepted; subsequent payments must use prescribed DRC 03 procedure.
Payments made through FORM GSTR 3B before the statutory provision came into force are eligible for the Section 128A waiver if paid prior to the effective date and intended for the demand; once the provision is in force, payments must be made by the prescribed modes including the dedicated payment form and electronic liability register credits. For notices/orders covering periods both within and outside the waiver window, taxpayers may pay tax for covered periods, file the prescribed special application form to avail the waiver, and must inform the appellate authority or tribunal that they will not pursue appeals for the covered periods, whereupon the authority will pass orders for the remaining periods.

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