You received a GST demand order. You filed an appeal with the Appellate Authority — and lost, or received an order you still disagree with. Until September 2025, your only next step was the High Court: expensive, slow, and disproportionate for a ₹5 lakh GST dispute.
That gap is now closed. The GST Appellate Tribunal — GSTAT — began accepting e-filed appeals on September 24, 2025, eight years after GST launched and eight years after taxpayers first needed it. Here's exactly how to use it.
What GSTAT Is and Why It Took 8 Years
GSTAT is the second appellate forum in the GST dispute hierarchy — sitting between the GST Appellate Authority (first appeal) and the High Court. Its absence since 2017 meant that every taxpayer who lost a first appeal had only one recourse: High Court litigation starting at ₹1–3 lakh in filing costs, with timelines of 2–5 years.
For a small business disputing a ₹3 lakh demand, that was no appeal at all in practice.
GSTAT now operates through:
- A Principal Bench in New Delhi
- 31 State Benches across 45 locations covering every state
Each bench has four members: two Judicial Members, one Technical Member (Centre), and one Technical Member (State). The technical members bring GST expertise that pure judicial benches lack — meaning the forum actually understands the transactions being disputed.
The Full GST Appeals Hierarchy
Before filing at GSTAT, understand where it sits in the chain:
| Level | Forum | Form | Time Limit | Pre-Deposit |
|---|---|---|---|---|
| 1st Appeal | GST Appellate Authority | APL-01 | 3 months from order | 10% of disputed tax |
| 2nd Appeal | GSTAT | APL-05 | 3 months from AA order | Additional 20% (total 30%) |
| 3rd Appeal | High Court | Writ/Appeal | No fixed limit | None (discretionary) |
| Final | Supreme Court | SLP | No fixed limit | None |
GSTAT only hears second appeals — challenges to orders passed by the GST Appellate Authority under Section 107. If you haven't filed a first appeal yet, start there.
The Phased Filing Schedule — Your Deadlines
GSTAT introduced a phased e-filing rollout to manage portal capacity. Your filing window depends on when your prior order or notice was issued.
| Phase | Order/Notice Date | Filing Window | Final Deadline |
|---|---|---|---|
| 1 | On or before January 31, 2022 | Sept 24 – Oct 31, 2025 | June 30, 2026 |
| 2 | Feb 1, 2022 – Feb 28, 2023 | Nov 1 – Nov 30, 2025 | June 30, 2026 |
| 3 | Mar 1, 2023 – Jan 31, 2024 | Dec 1 – Dec 31, 2025 | June 30, 2026 |
| 4 | Feb 1, 2024 – May 31, 2024 | Jan 1 – Jan 31, 2026 | June 30, 2026 |
| 5 | Jun 1, 2024 – Mar 31, 2026 | Feb 1 – Jun 30, 2026 | June 30, 2026 |
If your order falls in Phase 1 or 2, your primary filing window has passed — but the June 30, 2026 final deadline still applies. If you haven't filed yet and your order predates March 2023, act now.
What You Need Before You Open the Portal
Gather all of these before starting. An incomplete application is returned for correction — and if you miss the deadline during a correction cycle, you lose the appeal.
Documents:
- Self-certified copy of the impugned order (the AA order you're challenging)
- Original demand order (the order challenged before the AA)
- Grounds of appeal — written legal arguments explaining why the order is wrong
- Appeal memorandum
- Statement of facts and case summary
- Vakalatnama (if represented by an advocate or CA)
- Payment receipt for pre-deposit (from GST portal)
- Payment receipt for court filing fee (from Bharat Kosh)
- All supporting annexures (invoices, returns, correspondence with department)
Technical requirements for all documents:
- Scanned PDFs at 300 DPI, greyscale
- File size within portal limits (check current limits on efiling.gstat.gov.in)
- Digitally signed using DSC (Digital Signature Certificate) or Aadhaar-based e-sign
- Non-English documents must have an affidavit of English translation attached
Meena runs a garment manufacturing unit in Surat. She received a GST demand of ₹8.4 lakh after the Appellate Authority upheld the officer's order on an ITC dispute. Her CA prepared the appeal memo, affidavit, and grounds over two weeks — then discovered her scanned order was 400 DPI instead of 300, and the portal rejected it at the document upload stage. The correction took three days. Don't rush the document preparation stage.
The Step-by-Step Filing Process
Step 1 — Register on the GSTAT portal.
Go to efiling.gstat.gov.in. Select your user type: Taxpayer, Tax Official, or Advocate/Legal Representative. Verify your details with OTP. Upload required identity documents. Save your GSTAT User ID and password.
Step 2 — Pay the pre-deposit.
Before starting the appeal, pay the additional 20% pre-deposit on the GST portal (in addition to the 10% already paid at first appeal stage). Generate the payment challan and save the receipt — you'll upload this as a document.
For a ₹10 lakh GST demand: you paid ₹1 lakh at the first appeal stage. Pay an additional ₹2 lakh now. Total pre-deposit: ₹3 lakh. The remaining ₹7 lakh is the disputed amount you're contesting.
Step 3 — Pay the filing fee.
Filing fee = ₹1,000 per ₹1 lakh of disputed tax/penalty, capped at ₹25,000. Pay via Bharat Kosh portal. Save the receipt.
For a ₹10 lakh dispute: filing fee = ₹10,000 (10 × ₹1,000). For a ₹30 lakh dispute: filing fee = ₹25,000 (capped).
Step 4 — Initiate the appeal on the portal.
Log in → Appellant Corner → Filing → Appeal Filing. Agree to the GSTAT disclaimer. You'll reach a multi-page form.
Step 5 — Fill the order details.
Enter the ARN/CRN of the impugned order, or fill manually: Appellate Authority name, order date, period of dispute. Upload the impugned order PDF.
Step 6 — Fill basic and case details.
Select the Act (CGST/SGST/IGST/Cess), your jurisdiction, and the section under which the order was passed. State the grounds of appeal clearly — this is the legal core of your case. Include your case summary: what happened, what the officer decided, why it's wrong.
Step 7 — Fill appellant, respondent, and representative details.
Your GSTIN, address, PAN, and contact details are auto-populated from the portal. Add respondent details — the GST officer or Appellate Authority whose order you're challenging. Add your advocate or CA representative details including their bar/ICAI enrolment number.
Step 8 — Enter demand details.
For each head (tax, interest, penalty, fees): enter the total amount, the amount you admit as payable, the amount you're disputing, and the pre-deposit paid against it. The portal calculates the balance.
Step 9 — Upload all documents.
Upload in this order: impugned order, appeal memo, grounds, statement of facts, affidavits, annexures, Vakalatnama, pre-deposit receipt, filing fee receipt. Confirm the checklist — all documents present, correct DPI, size limits met, translations included, DSC applied.
Step 10 — Preview, submit, and save acknowledgement.
Preview the entire form. Affirm the verification statement. Submit. Download the e-acknowledgement — this is your proof of filing. The GSTAT Registrar then scrutinises the appeal for defects. If clean, you receive Form GST APL-02 confirming acceptance and your appeal number.
What Happens After Filing
- Registrar scrutiny — Defects are flagged and you're given time to cure them. Non-cured defects = appeal treated as not filed.
- Admission hearing — A bench decides whether to admit the appeal. Not all appeals are admitted — frivolous or time-barred appeals are rejected at this stage.
- Notice to respondent — The department receives notice and files its reply.
- Hearing — Both sides argue. GSTAT benches conduct hearings physically at state bench locations or via video conferencing.
- Order — GSTAT passes a written order upholding, modifying, or setting aside the AA's decision.
GSTAT orders are appealable to the High Court on questions of law only.
When NOT to File a GSTAT Appeal Yourself
GSTAT is a judicial forum with specific procedural rules. The written grounds of appeal are legal documents — vague or wrong grounds get the appeal dismissed even if your substantive case is correct.
Get a CA or advocate to draft and file your appeal if:
- The demand is above ₹2 lakh (the professional fee is trivially small relative to the amount at stake)
- The dispute involves ITC reversal (complex fact-and-law mix)
- The department has alleged fraud or wilful misstatement (penalties of 100% apply — this is criminal-adjacent territory)
- You missed the first appeal deadline and are seeking condonation of delay
Our CA partner team handles GST notice responses and GSTAT appeals → Understand what caused your GST demand — underpayment guide → Can I file my GST returns myself and avoid notices? →
GSTAT's arrival closes a gap that cost Indian businesses billions in High Court litigation costs and forced settlements for disputes that deserved a fair hearing. A forum designed specifically for GST disputes, run by members who understand them, is available from ₹10,000 in filing fees. Use it correctly and it's one of the most cost-effective legal remedies in Indian tax law.