GST form guide · updated October 2026

GST APL-05: appealing to the GST Appellate Tribunal

APL-05 is the appeal to the GST Appellate Tribunal (GSTAT) against an order of the Appellate Authority or the Revisional Authority. It is filed under Section 112 within three months from communication of the order, and requires a further pre-deposit on top of the amount paid at the first appeal.

GSTAT is now functioning

After years of delay, GSTAT benches are operational, including the Mumbai bench from June 2026. Appeals are filed electronically through the Tribunal's online filing system. Special transition deadlines were notified for orders passed before the Tribunal began working; those windows have now passed, so new appeals follow the normal three-month rule.

Time limit

APL-05 must be filed within three months from the date the order under appeal is communicated. The Tribunal can admit an appeal within a further three months if you show sufficient cause for the delay. Condonation is at the Tribunal's discretion, so do not rely on it.

Pre-deposit

In addition to the amount paid under Section 107(6) at the first appeal, Section 112(8) requires:

  • Full payment of any amount you admit
  • 10% of the remaining tax in dispute, subject to the statutory maximum
  • For penalty-only orders, a further 10% of the penalty, under the 2025 amendment
  • Once paid, recovery of the balance is deemed stayed until the appeal is decided

What to prepare

A Tribunal appeal is decided largely on the record. Prepare a concise statement of facts, clear grounds of appeal, the orders of the original and appellate authorities, the replies filed earlier and an indexed paper book of documents. New evidence not produced before the lower authorities may face objections.

The Tribunal may refuse to admit an appeal where the amount involved does not exceed Rs. 50,000. A professional can prepare the paper book and argue the appeal.

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.

Questions

APL-05 — FAQs

What is the time limit to appeal to GSTAT?+
Three months from the date the order is communicated, with a further three months possible if the Tribunal accepts the reason for delay.
How much pre-deposit is needed at GSTAT?+
A further 10% of the remaining disputed tax, subject to the statutory cap, in addition to what was paid at the first appeal, and 10% of penalty for penalty-only orders.
Can the department respond to my GSTAT appeal?+
Yes. The department can file a memorandum of cross objections in APL-06 within 45 days of receiving notice of the appeal.
Is a GSTAT appeal filed on the GST portal?+
No. Appeals to the Tribunal are filed through the GSTAT's own electronic filing system, separate from the GST common portal. Keep the orders, earlier replies and proof of pre-deposit ready before you start.
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