GST APL-03: when the department appeals an order in your favour

When APL-03 is filed

Orders that drop a demand, reduce it substantially, or sanction a refund are reviewed by the department. If the Commissioner considers the order wrong in law or not proper, an authorised officer files APL-03 before the Appellate Authority. The review and filing must take place within six months from the date of communication of the order.

How you will know

You will receive notice of the appeal and of the hearing through the portal or by the usual modes of service. The department's grounds of appeal are shared, and you are given an opportunity to file a written reply and be heard before the Appellate Authority decides.

How to respond

Treat a department appeal as seriously as a fresh notice. The Appellate Authority can confirm, modify or annul the original order, and can enhance the demand after giving you an opportunity to be heard.

• Collect the original order, your earlier reply and every document relied on
• Answer each ground raised by the department, showing where the original officer considered the same point
• Point out any new ground the department is raising for the first time
• Check whether the appeal was filed within the six-month period

Refunds sanctioned under appeal

Where a refund order is under appeal by the department and the Commissioner believes payment would adversely affect revenue because of malfeasance or fraud, the refund may be withheld under Section 54(11) through RFD-07. A professional can draft the reply to the department's appeal 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.