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If you disagree with an Indian GST demand order, file a first appeal in FORM GST APL-01 to the Appellate Authority under section 107 of the CGST Act. The ordinary deadline is three months from the date the order was communicated to you. A further period of up to one month may be condoned only when the authority is satisfied that sufficient cause prevented timely filing.
On the GST Portal, go to Services > User Services > My Applications, choose Appeal to Appellate Authority, select New Application and then Demand Order. Complete APL-01, attach the order and supporting material, pay the admitted amount plus the applicable pre-deposit, and submit. Do not treat the submission screen as completion: GSTN treats the appeal as filed when it issues the final FORM GST APL-02 bearing an appeal number. You can then monitor the case from My Applications.
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What a GST demand-order appeal does
A first appeal asks the designated Appellate Authority to examine a decision or order that adversely affects an aggrieved person. Section 107 of the Central Goods and Services Tax Act, 2017 is the usual route for a demand arising from assessment, adjudication or enforcement. The GST Portal workflow is designed for registered taxpayers, but the statutory expression is an aggrieved person and can include an unregistered person where the order affects that person.
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1Repair Windows errors before they cause bigger problems2Scan for outdated or missing drivers - takes under a minute3Clear out junk files and repair common Windows errorsAn appeal is not a fresh return or a request to the original officer to reopen the case. It is a formal proceeding with a statutory time limit, prescribed form, payment condition and subsequent notices. The exact order category, issuing authority and applicable State or Union Territory GST law should be checked before filing because a portal label or state rule may differ from the central workflow.
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Start with the communication date and the order record
Your first task is to establish when the decision or order was communicated. Section 107(1) measures the three-month period from communication, not from the date printed on the order if those dates differ. Save the communication email, portal notification, downloaded PDF and any linked summary. Record the following before opening the application:
- the issuing authority and jurisdiction;
- the order number, date and statutory provision cited;
- the tax periods and tax heads involved;
- tax, interest, penalty and other amounts separately;
- the amount you admit, if any, and the amount you dispute;
- the order summary, DRC document or other attachment connected with the demand; and
- the date and method by which the order was communicated.
These details let you select the correct order in the portal and calculate the payment condition. They do not decide whether the assessment is legally correct; that requires reviewing the order and your evidence.
Deadline: three months, with only a limited condonation window
| Rule | How it works | Practical consequence |
|---|---|---|
| Section 107(1) | Appeal within three months from communication of the decision or order. | Use the communication record, not an assumed date, when planning the filing. |
| Section 107(4) | The Appellate Authority may allow up to one further month if satisfied that sufficient cause prevented filing in time. | This is discretionary condonation, not an automatic fourth month. Explain and support the reason for delay. |
| Late beyond the permitted period | The materials reviewed do not establish a general power to accept a first appeal after the additional month. | Do not rely on a late filing; obtain case-specific advice immediately. |
File as early as the record permits. Waiting for a response to an informal representation, a corrected invoice or a technical issue does not itself extend the statutory period. If you need condonation, include the delay explanation and documents showing the cause rather than assuming the portal will grant it.
Payment before filing and the recovery stay
Section 107(6) generally requires two payments before the first appeal can proceed:
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- the full amount of tax, interest or other amount that you admit from the impugned order, as applicable; and
- a pre-deposit equal to 10% of the remaining disputed tax.
The statutory wording refers to the disputed tax for the 10% calculation. Separate interest and penalty figures should therefore be identified rather than folded into an unexplained total. Keep challans, payment references and the portal receipt with the appeal file.
Section 107(7) says recovery proceedings for the balance are deemed stayed once the payment condition is met. The GST Portal FAQ describes the portal flagging the balance disputed amount as non-recoverable when the appeal is admitted. Opening an application, saving a draft or merely paying an amount does not by itself mean that the appeal has been filed or admitted. Preserve the APL-02 and the admitted-status entry as evidence of the procedural point reached.
Penalty-only demands require a current-law check
At its meeting on 21 December 2024, the GST Council recommended an amendment providing a 10% pre-deposit for a first appeal involving only a penalty demand with no tax, replacing a 25% requirement. A Council recommendation is not proof that an amendment has commenced. Before using a different percentage, verify the enacted provision, notification and effective date that apply to the order and jurisdiction. Until that verification, do not assume the recommendation changes the general rule.
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File FORM GST APL-01 on the GST Portal
The following sequence reflects the GSTN demand-order workflow. Use the legal name and account that received or is entitled to challenge the order.
- Sign in and open My Applications. On the GST Portal choose Services > User Services > My Applications.
- Select the application type. Choose Appeal to Appellate Authority, then select New Application.
- Choose the order category. Select Demand Order and choose the order displayed for appeal. If the expected order is absent, recheck its upload status, GSTIN or user role before selecting a different category.
- Complete APL-01. Enter the order identifiers, communication details, disputed and admitted figures, grounds of appeal and the relief sought. Keep the grounds tied to the findings and figures in the order; do not leave a material field to an unsupported estimate.
- Attach the record. Upload the order and relevant supporting documents in the format and size accepted by the portal. Organize documents so the authority can match each ground to the page or record relied on.
- Make the required payment. Pay the admitted amount and the applicable pre-deposit. Save the payment reference and transaction evidence before moving on.
- Submit the application. Complete the portal authentication or digital-signature step offered for your account, then save the provisional acknowledgement and submission details.
- Confirm APL-02. Look for FORM GST APL-02 carrying an appeal number. GSTN states that the appeal is considered filed only when this final acknowledgement is issued.
The portal may send an email to the appellant and the Appellate Authority after filing and an SMS to the taxpayer. Treat those messages as notifications, not as substitutes for downloading the final acknowledgement and appeal number.
When the order is not uploaded: the seven-day document rule
Sometimes the selected demand order is not available as an uploaded document in the portal. GSTN says you must submit a self-certified copy within seven days. If you submit that copy later, the filing date is treated as the date on which the copy is submitted, rather than the date you first entered or saved the application.
This creates two separate checks:
- Was the application completed and submitted in the portal?
- Was the required self-certified order copy delivered within seven days?
Keep proof of the copy submission and monitor for APL-02. The portal FAQ treats the appeal as filed only when APL-02 bearing an appeal number is issued. A provisional acknowledgement without that number is not the final filing confirmation.
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The sources for this process do not determine the merits of an individual demand or prescribe a winning argument. Your APL-01 should nevertheless make the dispute intelligible and auditable. A practical file normally contains:
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- a copy of the impugned order and every linked summary or annexure;
- the communication evidence used for the deadline calculation;
- a schedule reconciling the order’s tax, interest, penalty and other figures with your admitted and disputed amounts;
- returns, invoices, ledgers, payment records, contracts or correspondence directly relevant to each ground;
- copies of earlier replies, statements, notices and hearing submissions; and
- payment evidence for the admitted amount and pre-deposit.
State each ground clearly, identify the finding being challenged and point to the document that supports it. Avoid submitting an unindexed bundle that makes the authority reconstruct your position. If a document is unavailable, explain that fact rather than implying that an attachment was filed.
How to track the appeal
Return to Services > User Services > My Applications. Select the appeal application type, enter a From and To date that covers the filing, and use the search function. Open the case entry and read the status together with any notice, hearing communication, reply request or order stored in the case folder.
| Portal status | What it indicates |
|---|---|
| Appeal Submitted | The application has been submitted in the workflow. Check that the final acknowledgement and appeal number are present. |
| Appeal Admitted | The Appellate Authority has admitted the appeal procedurally. It is not a prediction that your grounds will succeed. |
| Appeal Rejected | The appeal has been rejected. Read the order and any stated reason rather than inferring it from the label. |
| Appeal Withdrawn | The appeal record shows withdrawal. |
| Hearing Notice Issued | A hearing communication has been generated; open it for the date, mode and response requirements. |
| Reply Submitted | A reply or response has been uploaded in the case. |
| Adjournment Granted | An adjournment request has been allowed. Check the case record for the resulting schedule. |
| Show Cause Notice Issued | A show-cause communication requires attention and a response within the period stated in that notice. |
| Appeal Order Passed | An appellate order has been issued; download and review the document, not only the status label. |
| Rectification Order Passed | A rectification order has been recorded. Read the order to see what was corrected and what remains. |
GSTN also lists withdrawal, rectification and remand-related statuses. The displayed sequence is procedural information, not a guaranteed timetable, and the official materials do not provide a universal service-level deadline, average disposal period or success rate. Do not infer delay, merit or likely outcome from a status remaining unchanged.
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Responding to notices and hearings
A status change matters only when you open the associated communication. Download every hearing notice, show-cause notice, reply request and order; note the response deadline and the documents requested. Submit the reply through the case’s available response function, retain the acknowledgement and keep a copy of exactly what was uploaded.
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If an adjournment is needed, use the procedure and reason stated in the notice. An adjournment status means a request was granted; it does not erase the original record or guarantee another postponement. Continue checking My Applications after submitting a reply because a later notice may be issued without a separate phone call.
Common filing failures and how to avoid them
- Counting from the order date instead of communication: preserve the communication evidence and calculate section 107(1) from that event.
- Treating the extra month as automatic: request condonation only with a specific sufficient-cause explanation.
- Paying the wrong base: separate admitted amounts from the remaining disputed tax before calculating the 10% pre-deposit.
- Stopping at provisional acknowledgement: verify that APL-02 with an appeal number has been issued.
- Missing the seven-day copy period: when the order is not uploaded, submit the self-certified copy promptly and retain proof.
- Assuming payment alone stops recovery: the stay protection is linked to satisfying the statutory payment condition and the appeal’s procedural status.
- Choosing an incorrect order category: confirm whether the order is an assessment, enforcement or another appealable demand type before selecting Demand Order.
- Ignoring state or Union Territory differences: check the applicable GST law and portal implementation for the jurisdiction that issued the order.
- Relying on a status label without opening documents: notices and orders contain the operative dates, directions and reasons.
When professional help is sensible
Individual advice may be worthwhile where the demand is large, several tax periods are involved, records are incomplete, the deadline is close or a penalty-only rule may apply. Compare a prospective adviser’s GST appellate qualifications, experience with the issuing jurisdiction, scope of work, fee structure, conflict disclosures and responsibility for portal filing and hearing appearances. No particular provider is required to use the GST Portal, and a printed CGST Act and GST Rules reference can help with section 107, but neither replaces checking the current enacted law and notifications.
Limits of what the portal can tell you
My Applications can show whether the case moved to submission, admission, hearing, reply, order or related procedural states. It cannot, by itself, establish that the demand is legally valid, that your evidence is sufficient, that recovery will never resume after an adverse order, or that an appeal will succeed. Those questions depend on the order, the record, the applicable central or state law and the authority’s decision.
For a live matter, verify the current GSTN instructions and the law in force on the day you file, particularly if the demand contains only a penalty. Keep the final APL-02, appeal number, payment records and every portal communication together until the proceeding and any follow-on action are complete.
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