If you are personally challenging a GST adjudicating authority’s order, the usual route to examine is an appeal under section 107 of the Central Goods and Services Tax Act, 2017 (CGST Act). Revision under section 108 is different: it is a supervisory power exercised by a revisional authority, not an alternative appeal that a taxpayer files. The applicable State or Union Territory GST law and the specific order can affect the route, so check both before acting.
Appeal and revision serve different purposes
Section 107 gives a person aggrieved by an adjudicating authority’s decision or order a right to appeal to the Appellate Authority. The appeal asks that authority to review the decision and allows it, after any further inquiry it considers necessary, to confirm, modify or annul the order. It cannot send the case back to the original adjudicating authority.
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Section 108 instead gives a Revisional Authority supervisory power over specified subordinate orders. The authority may act on its own motion, on information received, or on a request from a State or Union Territory tax commissioner. It may proceed when it considers an order erroneous in a way that is prejudicial to revenue and also illegal, improper or made without taking material facts into account. The person affected must have an opportunity to be heard.
| Question | Section 107 appeal | Section 108 revision |
|---|---|---|
| Who initiates it? | A person aggrieved by an adjudicating authority’s decision or order. | The Revisional Authority, on its own motion, on information, or on a specified State/UT commissioner’s request. |
| What is it for? | To challenge the decision or order through the statutory appellate process. | To supervise a subordinate order that meets the statutory error and revenue-prejudice tests. |
| Ordinary timing | Three months from communication; the Appellate Authority may allow up to one further month for sufficient cause. | Restricted by section 108’s timing rules, including the period in section 107(2) and a general three-year limit from the order, subject to statutory provisions and exclusions. |
| Payment or stay | Requires payment of admitted dues and 10% of the remaining disputed tax for the first appeal; statutory payment deems recovery of the balance stayed. | No taxpayer pre-deposit formula is stated in section 108 itself. The Revisional Authority may stay operation of the order if necessary while proceedings are pending. |
| Possible next level | An appeal to GSTAT under section 112 may follow. | An appeal to GSTAT under section 112 may follow. |
When to examine a section 107 appeal
You received an order and want it reviewed
For someone challenging an order communicated to them, section 107 is the direct appeal route to assess. The CGST Act says a person aggrieved by a decision or order passed under the Act or the corresponding State or Union Territory GST law by an adjudicating authority may appeal within three months of communication. The Appellate Authority may admit an appeal during the further month if satisfied that sufficient cause prevented filing within the initial period. Do not assume that this extension is automatic.
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Calculate the first-appeal payment carefully
Before the appeal can be filed, the appellant must pay the part of the tax, interest, fine, fee and penalty arising from the order that they admit. They must also pay 10% of the remaining disputed tax, subject to the statutory limit. The 10% calculation is on disputed tax, not on every component of the demand. Once the required payment under section 107 is made, recovery proceedings for the balance are deemed stayed; the demand itself is not cancelled.
Know what the Appellate Authority can do
The Appellate Authority may confirm, modify or annul the order after any further inquiry it considers necessary. Section 107 does not permit it to refer the case back to the original adjudicating authority. That limitation is specific to this first appeal stage and should not be confused with the separate powers of GSTAT.
When section 108 revision may apply
It is a supervisory review, not a taxpayer-filed substitute
Section 108 does not describe revision as a remedy a taxpayer can file in place of an appeal. It authorizes the Revisional Authority to call for and examine records of proceedings and take action if the statutory threshold is met. A taxpayer’s objection to an order does not, by itself, establish the conditions for revision: the order must be considered prejudicial to revenue and illegal, improper or deficient in its treatment of material facts.
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Prior appeals and timing can restrict revision
Section 108 contains bars and time limits. Revision is generally unavailable where the order has been subject to the specified appeals. There is a narrow statutory proviso concerning a point that was not raised and decided in an appeal; whether it applies requires close examination of the order, appeal record and relevant timing rule. The section also generally limits revision to three years from the decision or order, subject to its provisions and exceptions. These restrictions make it unsafe to treat revision as a routine second chance after an appeal deadline.
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What to check before choosing a route
- Identify the order and authority. Confirm whether the document is an adjudicating authority’s decision or order, who issued it, and which CGST and State/UT provisions apply.
- Record the communication date. The ordinary section 107 period runs from communication, not simply from the date printed on the order. Preserve the notice, delivery record and portal information relevant to service.
- Separate admitted and disputed amounts. Identify admitted tax, interest, fine, fee and penalty, then calculate the first-appeal pre-deposit against the remaining disputed tax under the statute.
- Check prior proceedings. Review whether an appeal or other specified proceeding has affected the availability of revision, and whether any point was actually raised and decided.
- Verify current procedure and deadlines. The CBIC’s Appeals and Revision rules address forms, acknowledgement and limits on additional evidence. Filing instructions can change, so confirm the current applicable rules and portal directions rather than relying on old hard-copy procedures.
If the matter proceeds to GSTAT
A person aggrieved by an order under section 107 or section 108 may appeal to the Goods and Services Tax Appellate Tribunal (GSTAT) under section 112. Section 112 has its own limitation and pre-deposit requirements; do not carry the section 107 deadline or payment calculation forward as though it were the same. GSTAT’s official portal describes its appellate role and electronic filing process: GSTAT official portal.
The portal has displayed a section 112 extension through July 31, 2026. That date has passed, so it is not an open filing deadline. Check for a current official notice and apply the deadline relevant to the particular order and appellant.
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Bottom line for a person disputing an order
If you are the person challenging an adjudicating authority’s order, assess the section 107 appeal first: its communication date, grounds, required payment and applicable State/UT law. Section 108 is a separate supervisory power for the Revisional Authority, subject to its own threshold, exclusions and time limits. Because a missed limitation period or incorrect pre-deposit can affect the case, have a qualified Indian GST tax-litigation professional review the order and record where the stakes or procedural questions are significant.
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