Got a GST demand order you believe is wrong? You have exactly three months to fight it, you must pay 10 percent of the disputed tax up front, and the whole appeal is filed online in Form GST APL-01. Miss the clock and you lose the right to a first appeal.
If a GST officer passes an order against you, file a first appeal to the Appellate Authority under section 107 of the CGST Act in Form GST APL-01 on gst.gov.in within three months of the order. Pay any admitted dues in full plus 10 percent of the disputed tax. You then get acknowledgment in Form GST APL-02 and a hearing.
A GST appeal is your formal request to a higher authority to review and overturn a decision made against you by a GST officer. The first appeal goes to the Appellate Authority under section 107 of the CGST Act, 2017. It covers demand orders, refund rejections, registration cancellations and penalties.
The right of first appeal sits in section 107 of the CGST Act, 2017. Section 107(1) gives any person aggrieved by a decision or order of an adjudicating authority three months from the date the order is communicated to file an appeal to the Appellate Authority. Under section 107(4), the Authority can condone a delay of up to one further month if you show sufficient cause, so the absolute outer limit is four months.
Section 107(6) sets the money condition. You must pay in full the tax, interest, fine, fee and penalty you admit, plus a sum equal to 10 percent of the remaining amount of tax in dispute, subject to a maximum of twenty crore rupees under CGST. This cap was reduced from twenty-five crore to twenty crore rupees by section 141 of the Finance (No. 2) Act, 2024, effective 1 November 2024. From 1 April 2025, where an order demands only penalty without any tax, you must pre-deposit 10 percent of that penalty.
Once you pay the pre-deposit, section 107(7) treats recovery of the balance as stayed during the appeal. If the first appeal fails, the next stage is the GST Appellate Tribunal (GSTAT) under sections 109 and 112. The GSTAT was launched on 24 September 2025 and its benches, including Kolkata and Cuttack, have begun functioning in 2026. An appeal to the GSTAT under section 112 needs a further 10 percent pre-deposit of the remaining disputed tax, separate from the section 107 deposit. Beyond the Tribunal, the route is a writ or appeal before the jurisdictional High Court.
Dr. Shrawan Kumar Pathak runs a small diagnostic lab in Patna district, Bihar. In January 2026 a GST officer passed a demand order disallowing input tax credit and raising a disputed tax of ₹4,00,000. He disagreed and decided to appeal. Within the three-month window he logged in to gst.gov.in, paid a pre-deposit of ₹40,000 (10 percent of the ₹4,00,000 disputed tax) from his electronic cash ledger, and filed Form GST APL-01 with his ledgers and invoices. He received the provisional acknowledgment at once and Form GST APL-02 with an appeal number a few days later. Because the disputed tax was modest, the twenty crore cap never came into play, and recovery of the balance stayed paused while his appeal was heard.
Three months from the date the order is communicated to you. The Appellate Authority can allow one further month under section 107(4) if you show sufficient cause, making the outer limit four months.
Under section 107(6) you pay the full admitted amount plus 10 percent of the remaining disputed tax, capped at twenty crore rupees under CGST. For orders that demand only penalty, you pay 10 percent of the penalty.
Form GST APL-01, filed electronically on gst.gov.in. You receive a provisional acknowledgment immediately and a final acknowledgment in Form GST APL-02 with an appeal number once the appeal is accepted.
The portal issues a provisional acknowledgment. After verification and any required self-certified copy, the Appellate Authority issues Form GST APL-02. You then get a personal hearing before the order is passed.
Yes. Section 107(7) provides that once you pay the section 107(6) pre-deposit, recovery of the balance amount is deemed to be stayed while the appeal is pending.
Yes. The next stage is the GST Appellate Tribunal under section 112, which became operational from 24 September 2025. A further 10 percent pre-deposit of the remaining disputed tax applies. After the Tribunal, the route is the High Court.
No, you can file it yourself on the portal. Many taxpayers use an advocate, chartered accountant or authorised representative for complex demands, but it is not mandatory.
The Appellate Authority generally cannot admit an appeal filed beyond three months plus the one-month condonation. Your remaining option is usually a writ petition before the High Court, which is harder and discretionary.