GST

Appeals to the GST Appellate Tribunal (GSTAT)

When and how to appeal to the GST Appellate Tribunal under section 112, time limits, pre-deposit and the transition for older orders.

By CMA Pravin B. Mahadik · Published 14 November 2026 · Last reviewed 14 November 2026

The GST Appellate Tribunal (GSTAT) hears appeals against orders of the Appellate Authority (Commissioner (Appeals)) and the Revisional Authority. It began accepting appeals in September 2025.

The appeal chain

  1. Adjudicating authority passes the order (demand, refund rejection).
  2. Appeal to the Appellate Authority under section 107, within 3 months (plus 1 month on sufficient cause), with a pre-deposit of 10% of the disputed tax.
  3. Appeal to the GSTAT under section 112.
  4. Appeal to the High Court on substantial questions of law (section 117), and then to the Supreme Court.

Time limit before GSTAT

  • 3 months from the date the order is communicated.
  • The Tribunal may condone a further delay of up to 3 months for sufficient cause.
  • For orders communicated before 1 April 2026, a special deadline of 30 June 2026 applied.

Pre-deposit

In addition to the pre-deposit made at the first appeal, the appellant pays 10% of the remaining tax in dispute before the Tribunal, subject to the monetary cap in section 112(8). On payment, recovery of the balance is stayed until the appeal is decided.

Preparing the appeal

  • Order under appeal and the first appellate order, with dates of communication.
  • Statement of facts and grounds of appeal, framed on the issues decided against the appellant.
  • Proof of pre-deposit.
  • Paper book with documents and case law relied on.

A Cost Accountant may appear as an authorised representative under section 116.

Practical points

  • Note the communication date of every order on the day it is received.
  • Ensure grounds raised before the Tribunal were argued at the earlier stages; new facts are admitted only in limited cases.
  • Where the issue is common across several years, consider the effect of the decision on all of them.

Official sources

Disclaimer. This article explains the law as understood on the review date shown above. It is general information, not advice on any particular case. Provisions may have changed since; refer to the official sources and obtain professional advice before acting. Full disclaimer.