How do I file a first appeal against a GST order, and how much is the pre-deposit?

Short answer

File form APL-01 online before the Appellate Authority within three months of the date the order was communicated (a further one month can be allowed for sufficient cause). You must pay the tax, interest and penalty you admit, and 10% of the disputed tax, up to ₹20 crore each for CGST and SGST. For a penalty-only order, the pre-deposit is 10% of the penalty. Once paid, recovery of the rest is stayed while the appeal is pending.

Time limit

Three months from the date the order is communicated to you (usually the date it is uploaded on the portal or served).
The Appellate Authority may allow one further month if you show sufficient cause. Beyond that, it has no power to condone delay.
For orders of the department (when the department appeals), the limit is six months.

Pre-deposit (section 107(6))

Order	Pre-deposit
Tax demand (with or without interest and penalty)	All admitted amounts, plus 10% of the tax in dispute, capped at ₹20 crore each for CGST and SGST (₹40 crore for IGST)
Penalty only, with no tax demand	10% of the penalty
Detention or seizure of goods in transit (section 129)	25% of the penalty

The pre-deposit is calculated on tax, not on interest or penalty (except in penalty-only cases). It can be paid from the electronic cash ledger, or from the electronic credit ledger for output-tax demands. Once paid, the recovery of the balance is stayed until the appeal is decided.

How to file

File APL-01 on the GST portal against the order (DRC-07 or other order), with the grounds of appeal and a statement of facts.
Pay the pre-deposit; the portal links it to the demand.
The Appellate Authority issues a provisional acknowledgement, then a final acknowledgement (APL-02) once the appeal is complete.
Attend the personal hearing. Up to three adjournments are allowed.
The Authority should decide within one year where possible.

Practical points

Grounds matter. Raise every point of fact and law now; new grounds later need the Authority's permission, and further appeals depend on what was argued here.
Additional evidence is admitted only in limited cases, so file the documents with the reply to the show cause notice, not first at the appeal stage.
Keep the second appeal in view. If you lose, the next step is the GST Appellate Tribunal, with a further 10% pre-deposit.

A model grounds of appeal format is in our formats library.

Legal basis

Section 107, CGST Act, 2017 (appeal to the Appellate Authority)
Rules 108 and 109, CGST Rules, 2017 (forms APL-01 and APL-02)
Section 129, CGST Act, 2017 (detention and seizure: pre-deposit of 25% of the penalty)

Official sources

By CA Ameesh Gupta, FCA, DISA (ICAI) | Last reviewed: 7 November 2026. General information, not advice on your facts: the law changes and outcomes depend on the details of each case.