How to File a GST Appeal Under Section 107 With Form APL-01

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.

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.

1. Log in to the GST portal at gst.gov.in and go to Services then User Services then My Applications, and select Appeal to Appellate Authority.
2. Enter the order number and order date of the decision you are challenging, and the portal pulls up the order.
3. Pay the mandatory pre-deposit: the full admitted amount plus 10 percent of the disputed tax, using your electronic cash or credit ledger.
4. Fill Form GST APL-01 with the grounds of appeal and the prayer, and upload supporting documents.
5. Submit and file the form. The portal issues a provisional acknowledgment immediately.
6. If the order is not already on the portal, submit a self-certified copy within seven days of filing APL-01.
7. The Appellate Authority issues a final acknowledgment in Form GST APL-02 with an appeal number, which confirms the appeal is filed.
8. Attend the personal hearing when listed, present your case, and wait for the order, which the Authority should aim to pass within one year.

• Copy of the impugned demand or adjudication order being appealed
• Form GST APL-01 with detailed grounds of appeal and statement of facts
• Proof of pre-deposit payment from your electronic cash or credit ledger
• Self-certified copy of the order if it is not uploaded on the portal
• Supporting invoices, returns, ledgers and correspondence relied upon
• Authorisation letter if an authorised representative or advocate appears for you

• Missing the three-month limit under section 107(1); beyond the further one-month condonation under section 107(4), the appeal is time-barred.
• Not paying the 10 percent pre-deposit; under section 107(6) no appeal can even be filed without it.
• Forgetting the full admitted amount; section 107(6) requires admitted tax, interest, fine, fee and penalty to be paid in full before appeal.
• Treating penalty-only orders as deposit-free; since 1 April 2025 a 10 percent deposit of the penalty is required.
• Not submitting the self-certified order copy within seven days when the order is off-portal, which delays the APL-02 acknowledgment.
• Filing weak, vague grounds instead of specific legal and factual objections to each finding in the order.

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.

• Section 107, CGST Act, 2017 (CBIC tax information portal): https://taxinformation.cbic.gov.in/content/html/tax_repository/gst/acts/2017_CGST_act/active/chapter18/section107_v1.00.html
• Section 107(6)(b), CGST Act on Indian Kanoon: https://indiankanoon.org/doc/143007962/
• Section 112, CGST Act, 2017 (CBIC tax information portal): https://taxinformation.cbic.gov.in/content/html/tax_repository/gst/acts/2017_CGST_act/active/chapter18/section112_v1.00.html
• GST portal appeal user guide and FAQs (Form GST APL-01 and APL-02): https://tutorial.gst.gov.in/userguide/appeal/appeal_faq.htm
• GSTAT operational guide, Tax Guru: https://taxguru.in/goods-and-service-tax/gstat-operational-complete-guide-gst-appellate-tribunal-appeals.html

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