If you disagree with a GST adjudication order, an ordinary first appeal under section 107 of the Central Goods and Services Tax Act, 2017 generally must be filed within three months from the date the order was communicated to you. You must pay the full amount you admit and 10% of the remaining disputed tax. Once that payment is made, recovery of the balance is deemed stayed under section 107(7). The prescribed form is GST APL-01, and the appeal is treated as filed only when the final acknowledgement showing an appeal number is issued.
Use the order and its communication record—not merely the order date—to calculate the deadline and the amount payable. Check the current CGST, SGST or UTGST provisions and portal instructions before filing, especially if the order is penalty-only, relates to a waiver application, or includes payments already made.
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What a first GST demand appeal is
Section 107 provides the ordinary appeal route for a person aggrieved by a decision or order under the GST law. The appeal goes to the designated Appellate Authority, not directly to the GST Appellate Tribunal. This article addresses that first appeal route and its statutory pre-deposit. A different procedure may apply to a particular type of order, a later-stage appeal, or a special relief scheme.
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One free scan finds every outdated or missing driver and matches the right update for your exact hardware.Free scan · exact hardware matchThe governing section is published by the Central Board of Indirect Taxes and Customs (CBIC) in the Central Goods and Services Tax Act. The equivalent State GST or Union Territory legislation, notifications and the live filing portal should also be checked for the jurisdiction in which the order was issued.
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What you are appealing
Before opening the form, identify the exact order: for example, an adjudication order confirming tax and interest, an order imposing only a penalty, or an order connected with a special waiver provision. Record the section under which it was made, the tax period, the officer, the order number and date, and every component of the demand. The category affects both the calculation and the documents you need.
How much time you have
Three months from communication
Section 107(1) gives an aggrieved person three months to appeal, counted from the date the decision or order is communicated. The date printed on the order is not automatically the start date. Preserve the email, portal notice, electronic acknowledgement, registered-post record or other evidence showing when you received or could access the order.
A possible extra month is discretionary
Under section 107(4), the Appellate Authority may allow a further period of up to one month if it is satisfied that sufficient cause prevented filing within the original three months. This is a condonation power, not an automatic four-month period. A late filing should explain the delay with dates and supporting evidence; do not assume that the extra month will be granted.
Build a deadline record
- Write down the communication date supported by your evidence.
- Calculate the date three calendar months later and treat it as the ordinary last day, subject to the applicable computation rules and portal availability.
- Set an internal deadline several days earlier for payment, document review and upload.
- If the ordinary period has expired, prepare a specific sufficient-cause explanation and file within the possible one-month condonation window, understanding that acceptance remains with the Appellate Authority.
- Keep screenshots or downloaded receipts showing each submission attempt, particularly if the portal is unavailable near the deadline.
Do not wait for a recovery notice to start the appeal. Recovery action and appeal preparation are separate administrative events, and missing the statutory period can restrict the Appellate Authority’s power to entertain the case.
How to calculate the section 107(6) pre-deposit
The ordinary calculation has two distinct parts. First, pay in full every amount from the order that you admit. Second, pay 10% of the remaining amount of tax in dispute. The 10% limb is tied to disputed tax; it is not described in the statute as 10% of the entire demand including every item of interest, fine, fee and penalty.
| Order component | Amount required for the ordinary first appeal | How to classify it |
|---|---|---|
| Admitted tax | 100% of the admitted amount | Amount you accept as payable |
| Admitted interest | 100% of the admitted amount | Include the interest you accept |
| Admitted fine, fee or penalty | 100% of the admitted amount | Include each admitted component |
| Disputed tax | 10% of the remaining disputed tax | Apply the percentage to tax still contested after admitted amounts are identified |
| Disputed interest, fine, fee or penalty | Not automatically a separate 10% base under the ordinary wording | Check the order and the law in force; obtain case-specific advice before adding a payment |
The statutory text lists admitted tax, interest, fine, fee and penalty in the full-payment limb, while the percentage limb refers to the remaining amount of tax in dispute. Your calculation should therefore start with a line-by-line reconciliation of the demand, amounts already paid and the position you will take in APL-01.
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Illustrative calculation
Suppose an order shows ₹20,000 of tax that you admit, ₹5,000 of interest that you admit and ₹1,00,000 of tax that you dispute. On the ordinary statutory components, the admitted payment is ₹25,000. Ten per cent of the disputed tax is ₹10,000. The illustrated pre-deposit is therefore ₹35,000, subject to checking the actual order, credits for previous payments, the correct communication date and any amendment applicable to your case.
This example is arithmetic only. It does not decide whether a particular interest or penalty is legally disputed, whether an earlier payment satisfies part of the statutory requirement, or whether a special rule changes the amount.
Reconcile payments before you pay again
Match the demand register and order with your electronic liability ledger, cash ledger, credit ledger and bank challans. Identify the date, head and amount of every payment. A payment may have been made against a different tax period or component and may not automatically be credited to the pre-deposit required for the appeal. Keep the reconciliation and proof of payment with the appeal file.
Prepare FORM GST APL-01
CBIC’s prescribed form is available in the CGST rules PDF containing FORM GST APL-01. The form requires enough detail for the Appellate Authority to identify the order, the dispute and the relief sought. Prepare the information before starting the online submission.
| APL-01 area | Information to assemble |
|---|---|
| Appellant identity | GSTIN or other taxpayer identification, legal name, address and contact details |
| Order details | Order number and date, issuing officer, relevant section and date of communication |
| Representative | Authorised representative’s name and authority documents, where applicable |
| Dispute scope | Tax period, issue or issues, demand created, amount admitted and amount disputed |
| Demand breakup | Tax, interest, penalty, fee and any other charge shown in the order |
| Facts and grounds | A chronological statement of facts and numbered legal or factual grounds |
| Prayer | The precise relief requested, such as setting aside or modifying the disputed portion |
Use the form’s demand fields to make the admitted-versus-disputed split internally consistent. If the written grounds challenge only part of a tax period but the amounts table disputes the entire period, the inconsistency can create avoidable queries.
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Documents to assemble
- The complete demand order, including annexures and computation sheets.
- Proof of the date and mode by which the order was communicated.
- A demand reconciliation showing tax, interest, penalty, fee, other charges, admitted amounts, disputed amounts and prior payments.
- Payment evidence for the admitted liability and the statutory pre-deposit.
- Returns, invoices, e-way bills, contracts, ledgers, correspondence and other records supporting each ground.
- A concise statement of facts and a numbered grounds-of-appeal document that cross-references the evidence.
- Authority documents for a signatory or authorised representative, where required by the current portal or rules.
This is a practical preparation list derived from the prescribed form and filing rules, not a guarantee that every case will need only these documents. An order involving classification, valuation, input-tax credit, limitation, jurisdiction or fraud allegations may require additional technical evidence.
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How to file the appeal
Follow the current portal workflow and the applicable appeal rules. Labels and upload screens can change, so compare the live instructions with the rule text before submitting.
- Open the appeal service and select the correct order. Confirm the GSTIN, order number, issuing authority and tax period. If the order is not listed, do not substitute a different order; resolve the portal or jurisdiction issue first.
- Complete APL-01. Enter the communication date, representative details, issue and period, demand breakup, admitted and disputed amounts, statement of facts, grounds and prayer. Review every amount against the signed order.
- Calculate and make the required payment. Pay the admitted amount in full and 10% of the remaining disputed tax for the ordinary section 107(6) route. Save the challan, transaction reference and ledger entry.
- Upload the order and supporting documents. Use legible files, preserve the original page order and check that annexures referenced in the grounds are actually attached.
- Submit within the three-month period. If filing after that period, include the sufficient-cause explanation for condonation and supporting proof within the possible additional month.
- Complete the certified-copy requirement. The CBIC appeal rules describe submission of a certified copy of the decision or order and supporting documents within seven days in the stated procedure. Follow the current channel and instructions for that submission; do not assume an upload alone satisfies every requirement.
- Obtain and preserve the final acknowledgement. The rules provide for FORM GST APL-02 and explain that the appeal is treated as filed only when the final acknowledgement indicating the appeal number is issued. Save the provisional receipt, uploaded files, payment proof and final acknowledgement together.
The seven-day document step and the final acknowledgement are not cosmetic formalities. If a certified copy or supporting document is submitted after the stated period, the rule text addresses when the appeal is treated as filed; preserve evidence of the dates and follow any query or deficiency notice promptly.
What the pre-deposit does after filing
Section 107(7) states: “Where the appellant has paid the amount under sub-section (6), the recovery proceedings for the balance amount shall be deemed to be stayed.” The effect is limited to recovery of the balance covered by that statutory payment. It does not guarantee that the appeal will succeed, erase the order, cancel interest that may continue under the law, or remove every compliance consequence connected with the dispute.
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Penalty-only orders need a separate check
An order imposing only a penalty is not automatically interchangeable with an order demanding tax and interest. The applicable pre-deposit percentage and the amending law in force on the relevant dates must be verified from the operative Act and commencement notification.
A GST Council press release dated 21 December 2024 described a recommendation to change the penalty-only pre-deposit from 25% to 10%, with an intended effective date of 1 April 2025. A press release records the recommendation and stated intention; it does not, by itself, establish the final enacted text or commencement for every case. Before relying on a 10% penalty-only figure, locate the final amending provision and its commencement instrument and check whether it covers your order.
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When reviewing a penalty-only order, record the exact statutory section, order date, communication date, amount admitted, amount disputed and any payment already made. If the order also contains tax, interest or another recoverable component, analyse it under the ordinary split rather than treating the entire demand as penalty-only.
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Special situations, including section 128A
Some disputes arise from a special statutory process rather than a routine adjudication appeal. For example, CBIC Circular No. 238/32/2024-GST discusses appeals connected with rejection of certain section 128A waiver applications and whether an additional pre-deposit is due. The circular addresses that defined context; it should not be generalized to every GST demand order.
If your order refers to section 128A, a waiver application, an amnesty or another special notification, identify the application and rejection dates, the amount paid under that scheme and the exact relief sought. Then read the operative notification and circular together with section 107 before calculating a new payment. A payment made for a waiver process and a section 107 appeal pre-deposit may not be interchangeable without a specific legal basis.
Common mistakes and how to avoid them
Counting from the order date
Using the date printed on the order instead of the communication date can make an apparently timely appeal late. Preserve objective delivery evidence and state the communication date consistently in APL-01 and any condonation request.
Applying 10% to the whole demand
Do not multiply the total of tax, interest, penalty and fees by 10% without first separating admitted amounts and disputed tax. The ordinary statutory wording requires full payment of admitted components and 10% of remaining disputed tax.
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Ignoring admitted liability
Disputing one issue does not remove the obligation to pay amounts you expressly admit. Reconcile the admission with the order and ledger before filing.
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Assuming the extra month is automatic
The additional month is available only if the Appellate Authority is satisfied that sufficient cause prevented timely filing. A bare statement that the deadline was missed is weaker than a dated explanation supported by records.
Stopping after a provisional receipt
A provisional upload or transaction screen is not the same as the final acknowledgement with an appeal number. Track the certified-copy step, respond to defects and retain FORM GST APL-02.
Using an outdated portal or form
Form fields, upload limits and filing channels can change. Use the current portal labels and instructions while retaining the prescribed APL-01 information and the rule-based document evidence.
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The deemed stay concerns recovery of the balance after payment under section 107(6). It is not a decision on the merits and does not discharge other GST compliance duties.
A final pre-submission checklist
- Communication date evidenced and three-month deadline calculated.
- Any condonation request prepared with a dated sufficient-cause explanation, if needed.
- Order classified as ordinary tax demand, penalty-only or special-provision matter.
- Demand reconciled into admitted tax, interest, fine, fee and penalty; disputed tax; other disputed components; and prior payments.
- Admitted amounts paid in full and 10% of remaining disputed tax paid for the ordinary section 107(6) route.
- APL-01 fields, statement of facts, grounds and prayer checked against the order.
- Order, communication proof, evidence and payment records uploaded or otherwise submitted as currently required.
- Certified copy and supporting documents delivered within the stated seven-day procedure where applicable.
- Final acknowledgement showing the appeal number received and stored.
- Current CGST, relevant SGST or UTGST law, notifications and portal directions checked for amendments or special rules.
For an individual case, verify the exact order category, communication date, admitted-versus-disputed split, prior payments and law in force on the filing date with a qualified GST professional or the jurisdictional authority. Those details determine whether the ordinary section 107 formula described here applies.
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