GST · Notices, demands and appeals
Can I appeal to the GST Appellate Tribunal, and what is the time limit?
Short answer
Yes. The GST Appellate Tribunal (GSTAT) began functioning in September 2025 and hears second appeals against orders of the Appellate Authority (Commissioner (Appeals)). File online on the GSTAT portal, generally within three months of the date the appellate order is communicated, with a pre-deposit of 10% of the tax still in dispute (up to ₹20 crore each for CGST and SGST). The special window for older orders closed on 31 July 2026.
Where the tribunal fits
| Stage | Forum |
|---|---|
| Original order | Adjudicating officer (show cause notice, then order) |
| First appeal | Appellate Authority / Commissioner (Appeals), section 107 |
| Second appeal | GST Appellate Tribunal, section 112 |
| Further appeal | High Court on a substantial question of law, then the Supreme Court |
The tribunal has a Principal Bench in New Delhi and state benches across the country.
Key rules
- Time limit: generally three months from the date the order of the first appellate authority is communicated to you. Count from the date of communication, not the date on the order.
- Older orders: a special window for orders communicated before the tribunal began was extended to 31 July 2026 and has now closed. Ask whether a delay can be condoned if you missed it.
- Pre-deposit: 10% of the tax remaining in dispute, in addition to the amount paid at the first appeal stage, capped at ₹20 crore each for CGST and SGST. For a penalty-only order, 10% of the penalty. Once paid, recovery of the balance is stayed while the appeal is pending.
- Filing: online on the GSTAT e-filing portal, with the order under appeal, the grounds of appeal, the statement of facts, proof of the pre-deposit and the fee.
Practical points
- Plan the cash for the pre-deposit; it can be paid from the electronic cash ledger.
- Get the record right. The tribunal decides on the record. New documents may need an application to admit additional evidence.
- Frame the grounds carefully. They set the limits of the case, and questions of law you may later take to the High Court must be raised here.
- Smaller cases: appeals involving tax, penalty or fine up to ₹50 lakh, with no question of law, can be heard by a single-member bench.
See our update on the tribunal starting work and the GST notices and appeals service.
Legal basis
- Sections 109, 112 and 113, CGST Act, 2017
- GSTAT (Procedure) Rules, 2025