https://www.taxtmi.com/caselaws?id=796212 A substituted proviso to Section 107(6) of the CGST Act, effective from 1 October 2025, requiring a ten per cent pre-deposit for appeals against penalty-only orders, is analysed as inapplicable to proceedings initiated through an earlier show-cause notice. The note explains that the right of appeal vests when the lis commences and includes the applicable appellate conditions. As the amendment imposes a new and burdensome filing condition without an express or necessarily implied transitional provision, appeals arising from pre-amendment notices remain governed by the earlier appellate regime, without a mandatory pre-deposit of disputed penalties. en-us Fri, 31 Jul 2026 00:00:00 +0530 Sat, 01 Aug 2026 08:34:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796212 A substituted proviso to Section 107(6) of the CGST Act, effective from 1 October 2025, requiring a ten per cent pre-deposit for appeals against penalty-only orders, is analysed as inapplicable to proceedings initiated through an earlier show-cause notice. The note explains that the right of appeal vests when the lis commences and includes the applicable appellate conditions. As the amendment imposes a new and burdensome filing condition without an express or necessarily implied transitional provision, appeals arising from pre-amendment notices remain governed by the earlier appellate regime, without a mandatory pre-deposit of disputed penalties. Case-Laws GST Fri, 31 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796212