The Goods and Services Tax Appellate Tribunal (GSTAT) has formally notified the timelines for filing appeals and applications before it, vide Order No. F.No. GSTAT/Pr.Bench/Portal/125/25-26 dated 24.09.2025. This direction, issued by the President of the GSTAT, provides much-needed clarity for taxpayers and professionals on the staggered process of filing second appeals before the Tribunal.
Electronic Filing of Appeals
In line with Rule 115 of the Goods and Services Tax Appellate (Procedure) Rules, 2025, all appeals and applications arising out of orders of the Appellate Authorities (u/s 107) and Revisional Authorities (u/s 108) are to be filed electronically on the GSTAT portal developed by NIC. Hearings and records will also be maintained through the same system.
The move towards complete digitalisation ensures transparency, efficiency, and ease of compliance for appellants. However, owing to the large expected volume of appeals and potential system capacity issues, the GSTAT has directed a staggered filing schedule to avoid technical disruptions.
Staggered Filing Schedule for Appeals
The President, exercising powers under Rule 123 of the Rules, has notified specific timelines based on when the first appeal (Form APL-01/03) or Revisional notice (RVN-01) was filed/issued. The staggered schedule is as follows:
| Sl. No. | Category of Cases (Based on filing of APL-01/03 or RVN-01) | Timeline for Filing Appeal before GSTAT (u/s 112) |
| 1 | Filed/issued on or before 31.01.2022 | 24.09.2025 to 31.10.2025 (extendable up to 30.06.2026) |
| 2 | Filed/issued between 01.02.2022 – 28.02.2023 | 01.11.2025 to 30.11.2025 (extendable up to 30.06.2026) |
| 3 | Filed/issued between 01.03.2023 – 31.01.2024 | 01.12.2025 to 31.12.2025 (extendable up to 30.06.2026) |
| 4 | Filed/issued between 01.02.2024 – 31.05.2024 | 01.01.2026 to 31.01.2026 (extendable up to 30.06.2026) |
| 5 | Filed/issued between 01.06.2024 – 31.03.2026 | From 01.02.2026 onwards, but not later than 30.06.2026 |
Additional Clarifications
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- Extended Time Limit: Even if an appeal is not filed within the prescribed staggered window, appellants can still file it up to 30th June 2026.
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- Fresh Appeals after April 1, 2026: For orders communicated in Form APL-04 on or after 01.04.2026, the statutory period of 3 months from the date of communication will apply.
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- Cases without ARN/CRN records in GSTN: Such appeals can be filed between 31.12.2025 (midnight) to 30.06.2026.
Key Takeaway
This order provides a structured approach for filing appeals before the GSTAT, balancing both system limitations and taxpayer convenience. Taxpayers and professionals are advised to closely follow the filing windows applicable to their cases to avoid last-minute complications.
The staggered schedule ensures that the transition to the new e-filing regime is smooth, efficient, and transparent — marking a significant step in the evolution of GST dispute resolution.
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