GST Appeal — Filing APL-01 and Tribunal Appeals
A GST appeal challenges an order passed against you, in Form APL-01 within three months. We prepare the grounds, work out the 10% pre-deposit and file on the GST portal, with a practising professional appearing where needed.
What it is
A GST appeal is your formal challenge to an order that a GST officer has passed against you. It could be a tax demand under Section 73, 74 or 74A, a refund rejection, a registration cancellation or a penalty. You ask a higher authority to look at the order again.
The first appeal goes to the Appellate Authority under Section 107, in Form GST APL-01 on the GST portal. A second appeal goes to the GST Appellate Tribunal (GSTAT) under Section 112, in Form APL-05. This page is about the appeal stage; for the earlier notice stage see our GST Notice Reply service.
Who it applies to
A demand order has been passed
Picture a Faridabad trader who replied to a show cause notice and still got an order with tax, interest and penalty. The reply did not convince the officer. Appeal is the next step.
A refund claim was rejected
The order rejecting your claim can be appealed. Our GST Refund page explains how claims are built.
Your registration was cancelled
The cancellation order can be challenged, and the time limit applies from the date you receive it. See GST Cancellation.
Why it matters
It stops a wrong order from becoming final
An order not appealed in time stays as passed. Recovery can follow.
Pre-deposit is far smaller than the demand
You pay the admitted amount plus 10% of the disputed tax, not the whole demand.
Recovery is stayed on payment
Once the required deposit is made, the balance of the demand is not recovered while the appeal is pending, as provided in Section 107(7) and 112(9).
Documents required
The dispute
- Certified or portal copy of the order (DRC-07 or the relevant form)
- Show cause notice and your reply
- Hearing notices and any personal-hearing record
Your case
- Statement of facts and grounds of appeal
- Invoices, returns, reconciliations and ledgers supporting your position
- Case law or circulars you rely on, where relevant
Filing papers
- Proof of pre-deposit from the electronic cash ledger
- Authorisation for your representative
- DSC or Aadhaar e-sign of the authorised signatory
How it works
Read the order and lock the dates
We note the date of communication, the three-month limit under Section 107(1), and the amounts split into admitted and disputed.
Work out the pre-deposit
We work out the admitted amount and 10% of the disputed tax, check the ₹20 crore cap, and tell you what to keep in your cash ledger.
Draft the grounds and file APL-01
We prepare the statement of facts and grounds with a qualified professional, attach the papers and file on the GST portal.
Follow up for hearing and order
We track hearing dates, prepare written submissions, and where needed a practising CA or advocate appears under Section 116. If the order goes against you, we plan the GSTAT route.
First appeal and tribunal appeal at a glance
| First appeal | Second appeal | |
|---|---|---|
| Forum | Appellate Authority, Section 107 | GSTAT, Section 112 |
| Form | GST APL-01 | GST APL-05 |
| Time limit | 3 months, plus 1 month for sufficient cause | 3 months from communication of the first-appeal order |
| Pre-deposit | Admitted amount + 10% of disputed tax, max ₹20 crore | A further 10% of the remaining disputed tax, max ₹20 crore |
In practice, orders already communicated when the tribunal began working had a special window that closed on 31 July 2026 under notification S.O. 3502(E) of 30 June 2026. For fresh orders the normal three months apply.
Timelines
Day 0: the order is communicated
Start counting the three months from the date the order is communicated to you, not from the date you read it.
Within 3 months: file APL-01
One more month is possible on sufficient cause. After that the appeal is time-barred.
Next 3 months: GSTAT if needed
If the first appeal fails, the same three-month rule applies to APL-05.
What happens if you do not appeal
The order becomes final
Tax, interest and penalty stand as passed, and the tax is payable within three months of service under Section 78.
Recovery proceeds
The department can recover through your bank account, receivables or other steps the law allows.
You may lose the right to dispute
A late appeal beyond the extra month cannot be admitted, so only a High Court writ may remain.
Frequently asked questions
What is the time limit to file a GST appeal?
You have three months from the date the order is communicated to you to file Form GST APL-01 under Section 107(1). The Appellate Authority can allow a further one month if you show sufficient cause under Section 107(4). Nothing beyond that is condonable, so we diarise the date the day the order reaches you.
How much do I have to pay before filing the first appeal?
You must pay the full admitted amount plus 10% of the tax still in dispute, with the 10% capped at ₹20 crore under Section 107(6). In a penalty-only appeal the pre-deposit is 10% of the penalty. The payment goes through your electronic cash ledger, so keep enough balance ready before filing.
Should I reply to the notice first or go straight to appeal?
Reply to the show cause notice first. Here is why: an appeal lies only against an order, and your reply and documents on record are what the appellate officer reads. A weak reply is hard to repair later. If an order has already been passed, appeal is the next step. Our notice reply service covers the earlier stage.
What is Form APL-05 and who files it?
APL-05 is the appeal form for the GST Appellate Tribunal (GSTAT) under Section 112, filed by a taxpayer unhappy with a first-appeal order. GSTAT is now functioning after the notification of 17 September 2025. The usual limit is three months from communication of the order, and the tribunal portal handles the filing.
Is there a second pre-deposit for the tribunal?
Yes. Section 112(8) requires a further 10% of the tax still in dispute, capped at ₹20 crore, on top of what you paid in the first appeal. Once it is paid, recovery of the balance is treated as stayed. That stay is automatic and no separate application is needed.
What is the filing fee for an appeal to GSTAT?
The fee under Rule 110 is ₹1,000 for every ₹1 lakh of tax or input tax credit in dispute, subject to a minimum of ₹5,000 and a maximum of ₹25,000. It is separate from the pre-deposit and is not refunded. We calculate it before filing so that nothing is rejected for a short payment.
Can a chartered accountant argue my GST appeal?
Yes, in many cases. Section 116 lets a chartered accountant, cost accountant or company secretary in practice, an advocate or a GST practitioner appear as your authorised representative. Where the matter needs a practising advocate, as in a writ petition before the High Court, an advocate signs and appears. We prepare the papers either way.
What if the appeal order goes against me?
You can take it further. The next forum is GSTAT within three months of the order, and High Court remedies exist on questions of law. We review the order and tell you the realistic options and the deposit each route needs.
What it costs
Our fee plus the government fee that applies to your case, quoted before you commit. Tell us the situation and we will price it exactly.
Government costs in an appeal are the pre-deposit, which is part of the disputed demand and not a fee, and, for GSTAT, the filing fee under Rule 110: ₹1,000 per ₹1 lakh of tax or ITC in dispute, minimum ₹5,000, maximum ₹25,000.
Ready to begin?
Send us the order and the date it reached you, and we will confirm your deadline and pre-deposit the same day.