The long-awaited Goods & Services Tax Appellate Tribunal (GSTAT) has started functioning with effect from 24 September 2025, bringing relief to taxpayers and professionals who were left without a second appellate remedy since the introduction of GST. In order to manage the huge volume of appeals and prevent system overload, the GSTAT has issued a staggered filing schedule through its order dated 24.09.2025.
Background and Significance
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Since the rollout of GST in July 2017, appellate litigation was stuck at the first level due to the non-constitution of GSTAT.
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Appeals rejected, dismissed, or kept pending before High Courts on account of “absence of Tribunal remedy” can now be revived.
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The transitional filing schedule ensures orderly access to the system and clears a backlog of over 1.36 lakh cases.
Order Dated 24.09.2025 — Staggered Filing Windows
The Tribunal has prescribed five separate windows for filing appeals based on the date of the order appealed against:
| Window | Orders covered | Filing period |
|---|---|---|
| 1 | Orders passed on or before 31.01.2022 | 24.09.2025 – 31.10.2025 |
| 2 | 01.02.2022 – 28.02.2023 | 01.11.2025 – 30.11.2025 |
| 3 | 01.03.2023 – 31.01.2024 | 01.12.2025 – 31.12.2025 |
| 4 | 01.02.2024 – 31.05.2024 | 01.01.2026 – 31.01.2026 |
| 5 | 01.06.2024 – 31.03.2026 | 01.02.2026 – 31.03.2026 |
Final Cut-off: All appeals relating to orders up to 31.03.2026 must be filed by 30.06.2026.
For orders issued on or after 01.04.2026, the normal limitation under Section 112 (3 months + condonable 3 months) will apply.
Statutory Framework
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Section 107, CGST Act, 2017 – Appeal to Commissioner (Appeals).
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Section 108 – Revision by Commissioner.
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Section 112 – Appeal to GSTAT within 3 months from communication of order; condonation possible for a further 3 months.
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Section 112(8) – Mandatory pre-deposit:
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100% of admitted dues, and
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10% of disputed tax (max. ₹25 crore).
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Rules 108–109, CGST Rules, 2017 – Forms, manner of filing, authentication.
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GSTAT (Procedure) Rules, 2025 – Governs e-filing, hearing, and disposal.
Procedure for Filing Appeal
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Portal: efiling.gstat.gov.in (mandatory e-filing).
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Forms:
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GST APL-05 – Appeal to GSTAT,
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GST APL-07 – Cross-objections.
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Documents to Attach:
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Certified copy of the impugned order,
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Statement of facts,
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Grounds of appeal,
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Proof of pre-deposit,
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Copy of Commissioner (Appeals) order where applicable.
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Acknowledgement: Appeal is treated as filed only after ARN generation.
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Hearings: Commence from December 2025 before Principal and Area Benches.
Practical Implications for Professionals
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Case Identification: Match every order with its designated GSTAT window.
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Litigation Revival: Re-file appeals earlier dismissed for want of Tribunal remedy.
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Client Advisory: Educate clients on funding requirements for pre-deposit.
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Central Tracker: Maintain a litigation tracker with order dates mapped against filing slots.
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Timely Action: Ensure appeals are filed by 30.06.2026 — no further relaxation is expected.
Illustrative Case Examples
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Order dated 20 Jan 2022 → Must be filed between 24.09.2025 and 31.10.2025.
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Order dated 15 Apr 2024 → Falls under Window 4 (01.01.2026 – 31.01.2026).
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Order dated 10 Jun 2026 → Subject to standard Section 112 limitation (3 + 3 months).
Strategic Takeaways
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Earlier filing = earlier listing. Professionals should aim for Window 1 & 2 cases immediately.
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Transitional relief is time-bound. The 30.06.2026 cut-off is absolute for past orders.
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This mechanism is a once-in-a-lifetime opportunity to regularize appeals pending since 2017.
Conclusion
The GSTAT’s phased appeal filing schedule marks a turning point in GST litigation. For taxpayers and professionals, it is both an opportunity and a responsibility.
- Act now for orders falling in the current window.
- Prepare systematically for subsequent phases.
- Do not miss the 30 June 2026 deadline — beyond this, appeals may be permanently barred.
The staggered appeal system is not just a procedural formality; it is a compliance milestone that will shape GST jurisprudence for years to come.
