GSTAT Procedure Rules 2025 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
The Goods and Services Tax Appellate Tribunal (Procedure) Rules, 2025 set out how an appeal is filed, scrutinised, listed and heard. Most Tribunal appeals that fail early do so on procedure: the wrong number of appeals, documents not certified, defects not cured, or a hearing missed. This guide covers the rules that decide those points, and our GST appeal team prepares Tribunal filings against them.
Under the GSTAT (Procedure) Rules, 2025 (124 rules in 15 chapters, made under section 111), an appeal is filed online on the GSTAT Portal (Rule 18), with a certified copy of the order (Rule 21). Defects must be cured within 7 working days of return (Rule 24). The respondent replies within one month (Rule 36). If the appellant does not appear, the Tribunal may dismiss for default or decide on merits, and must restore on sufficient cause (Rule 42). Adjournment is a discretionary power under Rule 47, but section 113(2) caps it at three per party.
Filing: one order, one appeal
Rule 18 requires an online filing in the prescribed form, headed "In the Goods and Service Tax Appellate Tribunal", identifying the order appealed against. Paragraphs are numbered, each covering a single fact or point, and full party details including GSTIN are given once at the start.
| Situation | What to file |
|---|---|
| One order-in-appeal arising from one order-in-original covering several SCNs, refund claims or demands | One appeal |
| One order-in-appeal covering more than one order-in-original | A separate appeal for each order-in-original |
| Order affects more than one aggrieved person | Each person files separately; joint or common appeals are not entertained |
Grounds are set out concisely under distinct heads and numbered (Rule 20). The form is signed and verified by the appellant or authorised representative, who also certifies the documents as true copies. Non-English documents need an English translation, and no appeal is set down for hearing until all parties confirm the documents are in English or translated (Rule 23).
Documents: what the Registry looks for
Rule 21 needs a certified copy of the order appealed against along with the relevant and relied-upon documents, neatly paged and indexed. "Certified copy" means the original copy received by the party, or a copy authenticated by the department or by the authorised representative. The Background Material notes that the Procedure Rules do not turn on whether the order was uploaded on the common portal, unlike Rule 110 of the CGST Rules.
The GSTAT President has used Rule 123 to ease early filing. As recorded in the material:
- Order dated 20 January 2026: Registry to raise defects of substance only, not mere form. Documents generated digitally through the GSTN system need not be certified; scanned copies of physical documents must be signed.
- Instructions dated 10 March 2026: APL-05 must carry soft copies of the SCN, order-in-original, order-in-appeal, statement of facts and grounds. Pre-deposit and court fee are mandatory unless a higher court has exempted them. The appellant must upload the authorisation for the tax professional, or the vakalatnama for an advocate.
- Order dated 14 May 2026: the above relaxations continue until 31 December 2026.
Appeals by the department need the SCN, both orders, the Commissioner's opinion directing the appeal, statement of facts and grounds, and carry no court fee or pre-deposit.
Outer date for backlog appeals. The material records a notification dated 30 June 2026 under section 112(1) and (3) that set 31 July 2026 as the outer date for appeals against orders communicated before 1 May 2026, with a token mechanism (Order No. 156/2026 dated 10 July 2026) giving 60 days to complete filing. That date has now passed. For orders communicated on or after 1 May 2026, the normal three-month period from communication applies. Check for any later notification before relying on an older date.
Scrutiny and defects
If the Registry finds the appeal defective, it is returned with notice. Failure to comply within seven working days from the date of return sends it to the Registrar (Rule 24(1)). The Registrar may allow reasonable time, but not beyond thirty days from the date of filing (Rule 24(2)). The two periods start from different events: seven days from return, thirty days from filing. If the defect is not cured, the Registrar may decline to register the appeal, and the appellant can ask for a listing before the Bench, which may accept or reject it (Rule 24(3) and (4)). Once registered, the appeal is numbered.
Every application in a pending appeal (stay, early hearing, condonation, extension, exemption from producing the order) goes in GSTAT FORM-01 with a supporting affidavit (Rule 29). The appellant cannot urge grounds not in the appeal without leave, although the Tribunal itself is not confined to those grounds, provided the affected party has had an opportunity to be heard (Rule 31). The Commissioner is made respondent in a taxpayer's appeal, and the appellate authority that passed the order is never the respondent (Rule 33).
Reply, rejoinder and listing
| Step | Rule | Time |
|---|---|---|
| Respondent files reply and documents | 36 | Within one month of receipt, or as specified by the Tribunal |
| Rejoinder to new facts, if the Bench allows | 37 | Within one month or as the Bench specifies |
| Daily cause list | 38 | Published for the next working day, on notice board and portal |
| Urgent matter | 12 | Filed before 12 noon, complete, listed the next working day |
Cause list priority: orders for pronouncement, clarification, admission, orders or directions, part-heard cases, then numerical order. Sitting hours are ordinarily 10.30 a.m. to 1.30 p.m. and 2.30 p.m. to 4.30 p.m. (Rule 8).
Hearing, default and adjournment
The appellant is heard first, then the respondent if necessary, with a right of reply (Rule 41).
| Situation | Rule | Result |
|---|---|---|
| Appellant absent | 42 | Tribunal may dismiss for default or decide on merits; must restore if sufficient cause for absence is shown |
| Respondent absent, appellant present | 43 | Tribunal may hear and decide ex parte |
| Party dies, is insolvent or company wound up | 44 | Appeal abates unless a continuance application is made within 60 days (condonable for sufficient cause) |
| Additional evidence | 45 | Not as of right; allowed for recorded reasons |
On adjournment, Rule 47 lets the Tribunal adjourn at any stage on such terms as it thinks fit. Section 113(2) of the Act, however, allows adjournment only for sufficient cause recorded in writing and no more than three times to a party. Treat three as the practical limit and do not plan on seeking more.
A difference of opinion between Members sends the appeal to a larger Bench (Rule 50). Representatives need a vakalatnama or authorisation in GSTAT FORM-04 (Rule 72). Rectification of an order on application is made online in FORM-01 within one month of the final order (Rule 108).
Need help with a Tribunal appeal?
A Tribunal appeal is decided on the record you file, so the first filing has to be right. Our team can prepare the appeal, assemble the document set and appear through the hearing stages; start with our GST appeal service. For the demand that led to the order, see GST notices and litigation.
Key takeaways
- File online on the GSTAT Portal; one appeal per order-in-original and per aggrieved person.
- Certified copy of the order plus paged, indexed, relied-upon documents.
- Defects: 7 working days from return; Registrar's outer limit 30 days from filing.
- Reply and rejoinder each take one month unless the Bench directs otherwise.
- Do not miss a hearing: Rule 42 allows dismissal for default, and Rule 43 allows an ex parte decision if the respondent is absent.
Read next
- Appeal Against a Penalty-Only Order: Pre-Deposit
- Section 112: Appeal to the GSTAT and the Second Pre-Deposit
- Rule 110: APL-05, APL-02A and GSTAT E-Filing
- Section 73 GST Notice: Time Limits for FY 2017-18 to 2023-24
Disclaimer: Positions stated as on 30 September 2026, based on the CGST and IGST Acts and Rules as amended, the Finance Act 2026, and the ICAI Background Material on GST (14th Edition, July 2026). Verify current notifications before acting.