GST APL-01: filing an appeal to the Appellate Authority

Which orders can be appealed

Almost any decision or order under the CGST or SGST Act by an adjudicating authority can be appealed, including demand orders in DRC-07, refund rejections in RFD-06, cancellation of registration, rejection of registration applications, and detention penalty orders in transit cases.

Pre-deposit

An appeal is not admitted unless you pay:

• In full, the tax, interest, fine, fee and penalty that you admit
• 10% of the remaining tax in dispute, subject to the statutory maximum
• Where the order demands only penalty without any tax, 10% of the penalty, under the proviso to Section 107(6) in force from 1 October 2025
• For orders under Section 129(3) relating to goods in transit, the proviso now also works on 10% of the penalty

Stay of recovery

Once the pre-deposit is paid and the appeal is filed, recovery of the balance amount is deemed to be stayed until the appeal is disposed of. Keep the acknowledgement handy, as you may need to show it to the officer or bank if recovery action has already begun.

How the appeal is filed

APL-01 is filed on the GST portal against the order reference. You enter the disputed and admitted amounts, the grounds of appeal and the statement of facts, upload documents, and pay the pre-deposit through the electronic ledgers. If the order was uploaded on the portal, a certified copy is not required.

A provisional acknowledgement is generated immediately and a final acknowledgement with appeal number is issued in APL-02.

Common mistakes

Missing the deadline, paying the pre-deposit on the wrong demand, and writing grounds that do not engage with the findings of the order are frequent problems. Courts have been divided on whether the 10% penalty-only pre-deposit applies to proceedings started before October 2025, so check that point for older cases. A professional can draft the grounds and represent you at the hearing.

Get it handled for you

Facing an order you disagree with? We draft and file the appeal with the pre-deposit and attend the hearing as your authorised representative. Call or WhatsApp +91 63677 44602, or use the form below.

This guide explains the law in general terms as of October 2026. Time limits and requirements can depend on the facts of your case and on the notice you received.