APL-06 is the memorandum of cross objections filed before the GST Appellate Tribunal by the party on the other side of an appeal. Under Section 112(5) it is filed within 45 days of receiving notice that an appeal has been filed, and it lets you challenge parts of the order you did not appeal against.
Suppose an order of the Appellate Authority partly allowed your appeal. You accepted the result and did not appeal, but the department filed an appeal before GSTAT. Through APL-06 you can object to the parts of the order that went against you, and the Tribunal will deal with your cross objections along with the department's appeal.
Either party can file cross objections. A taxpayer files APL-06 when the department appeals, and the department files it when the taxpayer appeals. The memorandum is treated as if it were an appeal, so it must be precise about which findings are challenged and why.
APL-06 must be filed within 45 days of receipt of the notice of appeal. The Tribunal may admit it after this period if there is sufficient cause for the delay, within the further period allowed by the Act.
If you are aggrieved by a significant part of an order, do not wait to see whether the department appeals. File your own appeal in APL-05 within three months. Cross objections are a safety net, not a substitute. A professional can assess which route protects your position.
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.
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